Independence and conflicts policy

A valuation or Quality of Earnings report is only useful to a lender if the person who prepared it had no reason to reach a particular answer. This is how we'll run every engagement.

SBA's SOP 50 10 8.1 requires that a business valuation for a 7(a) change of ownership be requested by and prepared for the lender, by a Qualified Source who is independent of the loan production function, not involved in approving the transaction and free of any appearance of a conflict of interest. It also requires the Quality of Earnings to be prepared for the lender's benefit and not by or for the seller. This policy is how we meet those requirements and go a little further. See the Qualified Source guide for the rule itself.

1. Fees are fixed and never contingent

Our fee for a report is agreed before work starts. It does not depend on the conclusion of value, on the purchase price, on whether the loan is approved or closes, or on the size of the loan. We don't accept success fees, referral fees or any other payment tied to a deal outcome.

2. The lender is our client

Valuations and QoE reports for SBA loans are engaged by, and prepared for, the lender. The buyer or seller may upload documents and may pay the fee through the lender's process, but they are not our client and they don't set the scope or see drafts before the lender does.

3. A conflict check on every order

Before we accept an order we check the buyer, seller, business, brokers and other named parties against our records. We decline the order if anyone working on it has a financial interest in the business or the deal, a family or close personal relationship with a party, or any other relationship that could reasonably appear to affect their judgment.

4. Disclosure of prior services within three years

If we or the signing analyst performed any services for the business, the buyer or the seller in the three years before the order, we disclose that to the lender in writing before accepting the engagement and in the report itself. The lender decides whether to proceed.

5. Separate from any buyer-side service

Stargo, Inc. may offer tools for people buying a business. We won't value or prepare a QoE on any deal where we have provided buyer-side services, and buyer-side and lender-side work are kept separate. Information from one is never used in the other.

6. The signing analyst's judgment is final

Software prepares reconciliations and drafts. The credentialed analyst who signs the report reviews the work, forms the conclusion and can change anything in the draft. No one at OKtoLend can override the analyst's conclusion.

Last updated October 25, 2026.