Who Is Qualified to Prepare an SBA or USDA Feasibility Study?

Lenders ask this question in the same words every time: who is allowed to write the feasibility study? The honest answer is that the two federal programs that generate most of the demand for feasibility studies answer it differently. USDA Rural Development writes the standard into its regulation, names the preparer, and reserves the right to reject that preparer. SBA writes no preparer standard for the feasibility study at all, while writing exacting ones for the appraiser, the business valuator, and now the quality of earnings provider sitting in the same credit file. Understanding both regimes, and understanding why the SBA silence is not the lower bar it appears to be, is what separates a study a credit committee accepts from one a purchase reviewer discounts three years later.

What follows is a primary-source reading of the authorship question across SBA 7(a), SBA 504, USDA Business and Industry, USDA Community Facilities, and USDA REAP, current as of 7 September 2026, with the SOP 50 10 8.1 changes noted where they bear on it.

The SBA text: a permissive hook and a silent manual

The entire codified basis for a feasibility study in SBA lending is one clause. Under 13 CFR 120.160(b), SBA "may require professional appraisals of the applicant's and principals' assets, a survey, or a feasibility study." May, not must. The study sits in a list with surveys, and the regulation says nothing about who prepares it.

The operating manual built on that regulation, SOP 50 10 8, effective 1 June 2025, does not convert the permissive clause into a mandate for any loan class, and it does not fill the authorship gap. Read closely, the SOP is silent on the feasibility study in four ways: no trigger that categorically requires one, no named credential or license for the preparer, no content list or template, and no independence standard for whoever writes it. Each of those silences is routinely papered over in marketing that presents an MAI, a CPA, or some other designation as an SBA requirement for feasibility work. The text does not support that.

SOP 50 10 8.1, issued 14 August 2026 under Information Notice 5000-880695 and effective for applications that receive an SBA loan number on or after 1 October 2026, does not change this. The new edition rewrites change-of-ownership underwriting in a new Appendix 15, adds a quality of earnings requirement at the $3 million business purchase price threshold, and lifts the coverage floor for first-time acquisitions to 1.25x on historical earnings. It leaves the feasibility study provisions where SOP 50 10 8 left them.

So the SBA answer to "who may prepare it" is: the SOP does not say. That is where most commentary stops, and it is the wrong place to stop, because the same manual is unusually specific about three other third-party reports in the same file.

Where SBA does write a preparer standard, and why it matters here

The SOP is famously strict about independence for the reports it does regulate. Three examples define the pattern a lender will apply to the feasibility study whether the SOP tells it to or not.

The going-concern appraisal. For special-purpose property, which the SOP defines as "a limited market property with a unique physical design, special construction materials, or a layout that restricts its utility to the specific use for which it was built," the lender must obtain an appraisal from a Certified General Real Property Appraiser who "must have completed no less than four going concern appraisals of equivalent special use property as the property being appraised, within the last 36 months." The lender orders it. An appraisal prepared for the borrower or the seller cannot be used. The SOP's non-exhaustive special-purpose list runs from hotels and motels, gas stations, and car washes to bowling alleys, golf courses, funeral homes with crematoriums, cold storage, nursing homes and assisted living, marinas, and theaters. These are the same asset classes on which feasibility studies are most often ordered.

The business valuation. Where a change of ownership requires one, the SOP requires a "qualified source," defined as an individual who regularly receives compensation for business valuations and holds one of five named accreditations: ASA through the American Society of Appraisers, CBA through the Institute of Business Appraisers, ABV through the AICPA, CVA through NACVA, or BCA through the International Society of Business Appraisers. The valuation must be requested by and prepared for the lender, and the preparer must be independent of the loan production function, uninvolved in approving the transaction, and free of the appearance of a conflict of interest.

The quality of earnings report, from 1 October 2026. SOP 50 10 8.1 requires a QoE on initial acquisitions and business expansions where the business purchase price is $3 million or more, excluding owner-occupied real estate. The SOP requires the report to be performed by an independent, experienced financial professional for the benefit of the lender. A report prepared by or for the borrower or the seller does not satisfy the requirement, and a sell-side report supplied through a broker does not either.

The full reading of the new edition for the consultant is in SOP 50 10 8.1 and the Feasibility Study Consultant: What Changes on 1 October 2026.

Set those three next to the feasibility study and the architecture is clear. SBA regulates authorship where it regulates the report. Where it leaves the report to lender discretion, it leaves authorship to lender discretion too. It does not follow that the bar is lower. A lender that must obtain a lender-ordered, conflict-free appraisal and valuation on a hotel acquisition is not going to accept a feasibility study from the seller's broker on the same file, and a purchase reviewer reading that file after an early default will not either. In practice, lenders import the same three tests the SOP applies to the regulated reports: the author has no stake in whether the loan closes, the author is not on the transaction team, and the author's work is prepared with the lender's underwriting question in mind.

The USDA text: a codified preparer standard

USDA's OneRD framework, 7 CFR Part 5001, writes down everything the SOP declines to. The definitions in 7 CFR 5001.3 do the work.

A feasibility study is "a report including an opinion or finding conducted by an independent qualified consultant(s) evaluating the economic, market, technical, financial, and management feasibility of the proposed project or operation in terms of its expectation for success as outlined in appendix A to subpart D of this part."

A qualified consultant is "an independent third-party person possessing the knowledge, expertise, and experience to perform the specific task required."

Three words carry the definition: independent, third-party, and qualified. The regulation names no credential. It names a functional standard, tied to the specific task, and it pairs that standard with Agency acceptance.

The operative provisions repeat the standard and add the acceptance test. For Business and Industry guaranteed loans under 7 CFR 5001.306(a)(3)(i), "for guaranteed loans greater than $1,000,000.00 to a new business, a feasibility study prepared by an independent qualified consultant acceptable to the Agency is required. The scope of the feasibility study will be determined by the Agency and is dependent on the complexity of the project and the borrower." For loans of $1 million or less, and for existing businesses, the Agency may require a study where the lender's analysis is not sufficient to determine technical feasibility or economic viability, or where the project will significantly affect an existing business's historic cash flow.

The general application provision at 7 CFR 5001.303(c)(4) uses the same language for any program: where the Agency cannot determine a basis for repayment from the lender's analysis, the borrower's business plan, or other project information, it may require an independent feasibility study, which "should be prepared by a qualified, independent third party using applicable elements of the project, including but not limited to those outlined in appendix A."

Community Facilities adds a layer under 7 CFR 5001.304. Every CF guarantee requires a financial feasibility report "prepared by a qualified firm or individual acceptable to the Agency." That report comes in two forms. A financial feasibility analysis under 5001.304(a) may be prepared by "a qualified firm or individual who may be the lender," and the lender's own credit evaluation can serve if it covers Appendix B. A financial feasibility study with examination opinion under 5001.304(b) "must be prepared in accordance with the standards of attestation of the American Institute of Certified Public Accountants, and the preparer must have the requisite professional liability insurance in place." And for CF loans over $1 million to a new entity or an entity conducting a new activity, the full feasibility study by an independent qualified consultant acceptable to the Agency is required, exactly as in B&I.

REAP is narrower. Under 7 CFR 5001.307(d), a feasibility study is required for renewable energy system projects only "when deemed necessary by the lender or Agency," conducted in conformance with the 5001.3 definition. The preparer standard for the technical report is where REAP gets specific: Appendix C requires the qualifications of the energy auditor or assessor, and for assessments on projects of $80,000 or less not conducted by an energy auditor or assessor, "the individual or entity must have at least 3 years of experience and completed at least five energy assessments or energy audits on similar type projects." Appendix E for larger renewable systems opens with a section on the qualifications of the project team, "their professional credentials, and relevant experience." For the full side-by-side of the two regimes, from trigger and content to scope, review, sensitivity, recency and equity, see SBA Feasibility Study vs USDA Feasibility Study: The Nine Structural Differences.

Read together, the USDA standard has four parts: the author is independent of the transaction, the author is a third party to the borrower, the author has demonstrable knowledge, expertise, and experience in the specific task (which means the asset class and the analysis, not consulting in general), and the Agency can reject the author. That last part is the one borrowers underestimate. The State Office reviewing the application does not have to explain a rejection in terms of credentials. "Acceptable to the Agency" is the whole test.

The agent question: is a feasibility author an SBA "Agent"?

A recurring point of confusion is whether a feasibility study author falls under SBA's agent rules and Form 159 fee disclosure. The answer turns on 13 CFR 103.1(a), which defines an Agent as "an authorized representative, including an attorney, accountant, consultant, packager, lender service provider, or any other person representing an Applicant or Participant by conducting business with SBA." A Packager under 103.1(e) is "an Agent who is employed and compensated by an Applicant or lender to prepare the Applicant's application for financial assistance from SBA," and SBA decides who is a Packager "on a loan-by-loan basis." A Referral Agent under 103.1(f) "identifies and refers an Applicant to a lender or a lender to an Applicant."

The operative test is representation: conducting business with SBA on someone's behalf. A consultant engaged to produce an independent analysis of a project's market, financial, technical, and management feasibility is not representing the applicant to SBA. The consultant is producing evidence, not advocacy, and does not assemble the application, negotiate with the lender, or communicate with the agency on the borrower's behalf. On a plain reading of the regulation, that consultant is not an Agent and the study fee is not a Form 159 agent fee.

The distinction collapses the moment the same party does both. A consultant who also packages the loan, refers the borrower to the lender for a fee, or communicates with SBA on the borrower's behalf is an Agent for those activities, and the two-master rule in 13 CFR 103.4(g) governs whether that party can be paid by both sides on the same loan. SBA's own rulemaking record describes "at a minimum, an appearance of a conflict of interest when an Agent represents both the applicant and the lender on the same loan application." A feasibility study authored by a party that is also being paid to get the loan approved is not independent in any sense a reviewer will credit, whether or not the Form 159 is filed correctly.

The practical rule for a lender is simple. Ask the study author two questions: are you being compensated in any way that depends on this loan closing, and are you performing any other role on this transaction? If the answer to either is yes, the study is not independent, and the lender should treat it as borrower advocacy rather than third-party evidence.

Who is disqualified in practice

Neither regulation publishes a disqualification list. The combined logic of 7 CFR 5001.3, 13 CFR 103, and the SOP's own preparer rules for appraisals, valuations, and QoE reports produces one that credit committees and USDA State Offices apply consistently.

The borrower and its employees. A study written in-house is a business plan. USDA's own application provisions treat the borrower's business plan as a separate document from the feasibility study, and the SOP's independence logic for every regulated report excludes the borrower as preparer.

The seller. On a change of ownership, a seller-commissioned study fails for the same reason a seller-commissioned appraisal, valuation, or QoE fails under the SOP: the party with the strongest interest in the transaction closing cannot supply the evidence that it should.

The franchisor. Hotel, restaurant, and car wash franchisors run their own market evaluations before granting franchise approval, and those evaluations are written to answer the franchisor's question, which is whether the site protects the brand, not the lender's question, which is whether the operator repays the debt. A franchisor evaluation is useful input to a study. It is not a study, and a franchisor-prepared document supplied as the feasibility study fails the third-party test on its face.

The broker, packager, or referral agent on the deal. Covered above. Compensation tied to closing is the definition of a financial interest in the outcome.

The developer, general contractor, equipment vendor, or management company. Each is paid from the project the study is supposed to evaluate. REAP's technical report appendices rely on vendor and installer certifications for small projects, but the feasibility study definition does not, and on a B&I or CF study the Agency will not accept a preparer whose fee comes out of the construction or equipment budget.

The lender's loan production staff. The SOP's business valuation rule makes the point explicitly: the qualified source must be independent of the loan production function. USDA permits the lender to prepare the CF financial feasibility analysis, but not the full feasibility study required over $1 million for a new entity.

The borrower's regular accountant. This one is not a per se disqualification under either program. A CPA firm can be independent in the AICPA sense while performing recurring services for the borrower, and USDA's examination-opinion report for Community Facilities is expressly an attestation engagement. But a reviewer will ask, and the question is easier to avoid than to answer. Where the accountant holds any interest in the borrower, has prepared the projections the study is supposed to test, or is compensated on a basis tied to the loan, the study is not independent.

Anyone the Agency has declined. Under USDA, "acceptable to the Agency" is a live condition. A consultant a State Office has previously rejected, or whose prior work was returned as incomplete against Appendix A, is a risk the lender should price before engagement.

What "qualified" means when no credential is named

Because neither regulation names a credential for the feasibility author, the qualification test is functional. USDA's phrasing, "the knowledge, expertise, and experience to perform the specific task required," is the standard both programs effectively apply, and it is asset-specific. A consultant with a hotel track record is not qualified for a meat processing plant by virtue of being a consultant.

Credentials still matter, for two reasons. First, the surrounding reports in the file are credentialed, and a lender comparing a feasibility study to a Certified General appraisal and an ASA or CVA valuation will notice a study whose author states no qualifications at all. Second, USDA's own appendices show what the Agency treats as evidence of qualification: years of experience, count of comparable assignments, professional credentials and licenses, and professional liability insurance. Those are the proxies a lender should ask for.

The credentials that carry weight in feasibility work are the ones that speak to the analysis rather than to the profession in general: real property appraisal licensure or Appraisal Institute affiliation for the market and site components, business valuation accreditation for going-concern and change-of-ownership economics, financial modeling certification for the projection work, engineering credentials where technical feasibility is the binding question. None is required for the feasibility author under SBA or USDA. All of them answer the question "qualified to perform the specific task" better than a general consulting background does.

Two credentials are worth a specific note because they are so often misdescribed. An MAI designation is not required for the feasibility study author under either program. It is a relevant qualification for the market and valuation components, and the SOP requires Certified General licensure, not MAI, for the going-concern appraisal. A CPA license is not required for the feasibility author under SBA, and under USDA a CPA is required only where the CF examination-opinion report is triggered, because that report is an AICPA attestation engagement. A CPA without a valuation accreditation is not a qualified source for an SBA business valuation, a change SBA made in 2014 and carried forward since.

Whether a generated draft can meet that standard at all is the subject of Can AI Write a Lender-Grade Feasibility Study?.

The audit trail: where authorship gets tested

The reason authorship matters is what happens after the loan closes. On the SBA side, 13 CFR 120.524(a) releases SBA from its guaranty, "in whole or in part, within SBA's exclusive discretion," where the lender "has failed to comply materially with any Loan Program Requirement," and purchase does not waive SBA's right to recover afterward. The Office of Inspector General has documented the file deficiencies that trigger that clause for more than a decade through its High Risk 7(a) Loan Review Program.

The findings are stable across editions. In Report 18-21, OIG found lenders "did not provide adequate documentation to substantiate financial projections." In Report 19-22, the review of eight early-defaulted loans in fiscal year 2019 "identified material lender origination and closing deficiencies that justified denial of the guaranty for five loans in the amount of approximately $8.7 million," with repayment ability among the recurring issues and "unsupported projected sales" itemized as a deficiency. Since fiscal year 2014 the program had reviewed 27 loans totaling nearly $23.2 million through 2018 and recommended recoveries on 11 of them, more than $8.5 million.

"Unsupported projected sales" is the audit name for a projection with nothing independent behind it. A feasibility study written by the borrower, the seller, the broker, or the franchisor does not cure that deficiency. It restates it with a cover page. The study that cures it is the one a reviewer can read as evidence: independently authored, sourced assumption by assumption, and signed by someone with no stake in the outcome.

On the USDA side the test comes earlier. The State Office reviews the study against Appendix A before conditional commitment, and 7 CFR 5001.315(a) allows the Agency to "require the lender to obtain additional assistance in those areas where the lender does not have the necessary expertise." A study by a preparer the Agency does not accept is not a study for Part 5001 purposes, and the application is incomplete until one is supplied.

Who may rely on the study once it is written, and what the author's signature warrants, is covered in Reliance, Certification and Liability: Who May Rely on a Feasibility Study.

A qualification checklist for the credit file

Lenders and CDCs that want a defensible record on the authorship question can document it in ten lines. Each item maps to a requirement in the SOP, Part 103, or Part 5001, or to the reviewer question those requirements anticipate.

1. The author has no ownership, employment, or financial interest in the borrower, the seller, the franchisor, the developer, the contractor, or any vendor to the project.
2. The author's fee is fixed and not contingent on loan approval, closing, or loan amount.
3. The author performs no other role on the transaction: not packager, referral agent, broker, lender service provider, or borrower representative to SBA or USDA.
4. The author did not prepare the borrower's business plan or the projections the study tests, or, if the same firm did both, the study states which is which and tests the projections independently.
5. The author is a third party to the lender's loan production function and did not participate in approving the credit.
6. The author states knowledge, expertise, and experience in the specific asset class and analysis, with a count of comparable assignments and the years over which they were completed.
7. The author states relevant professional credentials, licenses, or affiliations, and does not claim that any of them is required by SBA or USDA for feasibility work.
8. The author carries professional liability insurance, and the study says so.
9. The study contains a signed certification of independence and of the sources relied on, dated, with the author's name and firm.
10. For USDA, the lender has confirmed with the State Office that the author is acceptable to the Agency before the study is commissioned, not after.

A file that carries these ten lines has answered the authorship question before it is asked, by a credit committee at origination or by a reviewer after default.

What this means for the consultant's role

An independent feasibility study consultant is defined by what it is not. It is not a packager, not a broker, not a lender service provider, not the borrower's planner, and not the franchisor's site evaluator. That is not a marketing position. It is the condition under which the study functions as evidence in an SBA or USDA file, and it is the reason a lender orders one.

The work product follows from the role. A qualified independent author states its qualifications, sources every load-bearing assumption, tests the projections rather than adopting them, and signs a certification the reviewer can rely on. Under USDA the author also builds the study to the five components in Appendix A, because that is the checklist the State Office will grade against. Under SBA the author builds to the questions the credit committee and the purchase reviewer will each ask, because no checklist exists, and the absence of one is exactly why preparer quality matters more on the SBA side, not less.