SBA Qualified Source: who can sign a 7(a) business valuation

Published October 25, 2026 · Rules checked against SBA and IRS sources as of October 2026

The Qualified Source definition is short, but each part does work. A valuation by someone who misses any one of them can't support an SBA change-of-ownership loan.

The five tests

The credentials

Note the SOP's ASA wording: the American Society of Appraisers' senior designation. The society also has other designations; check that the individual's credential is one SBA lists.

Each credential in brief

The SOP names the credentials but not what earning them involves. A 2025 American Bar Association overview of valuation credentials summarizes the main requirements; the table below draws on it. Requirements change, so check the issuing body for current rules.

Two practical points follow. First, the ASA wording in the SOP refers to the American Society of Appraisers' senior designation; the society's Accredited Member (AM) designation requires less experience and isn't named. Second, because new CBAs haven't been issued since 2016, most CBA holders you meet have been practising for years, which is fine, but confirm the credential is current.

Credential holders who still don't qualify

The credential is one test of five. These are the situations where a credentialed appraiser still can't sign an SBA valuation:

Independence in practice

• No role in originating, selling or approving the loan.
• No financial interest in the deal: no success fee, no fee contingent on value or closing.
• No relationship with buyer, seller or broker that could appear to affect judgment.
• Disclosure of prior work for any party.
• Engaged by the lender, report addressed to the lender.

OKtoLend publishes its independence and conflicts policy for this reason.

Vetting checklist for lenders

1. Verify the credential with the issuing body's directory where available.
2. Ask for a short list of recent business valuation engagements (types, not client names) to evidence regular compensation.
3. Get a signed independence and conflict statement per order.
4. Confirm the engagement letter names the lender as client.
5. Keep these in the file with the report.

Related: SBA valuation requirements and what independence means.

What independence means in practice

An independent business valuation is one prepared by a qualified appraiser who has no stake in the outcome: no interest in the deal, no fee that depends on the value, and no role in selling, buying or approving the transaction. For SBA 7(a) acquisitions, the Qualified Source must be independent of the loan production function, not involved in approving the deal, and free of any appearance of conflict, and the valuation must be requested by and prepared for the lender.

Four tests of independence

Why it matters on an SBA loan

SBA's point is plain in the SOP: a change of ownership creates new debt unrelated to operations and new intangible assets, so the price has to be supported by someone with no reason to support it. If the price exceeds the valuation, the gap must be covered by equity. A valuation that isn't independent can't do that job and leaves the lender exposed if the guaranty is ever reviewed.

Independence in the professional standards

SBA's definition isn't the only source of independence expectations. The IRS's own business valuation guidelines (IRM 4.48.4) tell its appraisers to "employ independent and objective judgment in reaching conclusions" and to decide matters "free from bias, advocacy, and conflicts of interest." The model certification in those guidelines goes further: the appraiser states they have no present or prospective interest in the property, no personal interest with respect to the parties, no bias, and that their compensation is not contingent on the analyses, opinions or conclusions. That certification is a good template for what a lender should expect any valuer on an SBA deal to sign.

What independence looks like across a deal

Handling a disagreement with the value

Buyers and sellers sometimes believe the appraiser got it wrong, and sometimes they're right. The independent way to deal with it is to give the lender specific factual corrections (a missed contract renewal, a misread expense, a one-time cost that wasn't recognized) with documents, and let the lender put them to the appraiser. Pressure on the number itself, without new facts, is exactly what independence rules exist to stop. If the appraiser accepts the new facts, they revise and explain; if not, the lender decides whether the file supports the loan as structured.

Lenders can also order a review of the report by a second credentialed appraiser where something looks wrong; see how lenders review a valuation.

When the lender values the business itself

At a Business Purchase Price of $350,000 or less, and where there's no close relationship between buyer and seller, the SOP lets the lender perform its own valuation instead of hiring a Qualified Source. The independence logic still applies even if the SOP's Qualified Source definition doesn't: the analysis is stronger when someone other than the loan officer who sourced the deal prepares it, documents the method and the earnings used, and ties those earnings to the seller's IRS transcripts. A one-line "price looks reasonable" note in the credit memo is the kind of support that looks thin if the loan later defaults. See the $350,000 lender valuation option.

Red flags

• The broker "has a valuation guy."
• The fee rises with the concluded value.
• The appraiser shares drafts with the seller.
• The report is addressed to the buyer but delivered to the lender.

Read the OKtoLend independence policy and the Qualified Source rules.

Common questions

Related guides

• SBA valuation requirements for lenders on change-of-ownership loans
• Certified Valuation Analyst (CVA): what the credential means
• Business valuation services: what you're actually buying
• Business appraisal: how it differs from a valuation, a calculation and a broker opinion

This guide explains rules and practice in plain English. It isn't legal, tax or credit advice, and SBA and IRS rules change. Check the current SOP, regulations and your lender's requirements before you rely on anything here. Examples with made-up businesses are illustrations, not real deals.