Our independence policy
SOP 50 10 8.1 requires the QoE to be performed by an independent qualified financial professional, for the benefit of the lender, and not by or for the seller. Because we also provide CFO and advisory services, we hold ourselves to a stricter written standard.
We decline a lender QoE when
- StrategX Advisory or Intermountain CFO Group has served the seller or target business in any capacity in the prior 24 months, including CFO, controller, bookkeeping, tax, exit-readiness, or sell-side work
- We have any relationship with the business broker on the transaction
- The buyer is a current CFO or controller client. In that case we can prepare a buyer-side QoE, and the lender's own vendor reviews it
How we enforce it
- A written conflict check across all entities before any engagement letter is signed
- Fees are fixed and owed regardless of the QoE's conclusions, the loan amount, or whether the loan closes
- No referral fees paid to or accepted from brokers, lenders, or buyers
- Every report includes an independence representation stating these facts
"The QoE must be performed by an independent qualified financial professional and must be conducted for the benefit of the Lender."
SBA SOP 50 10 8.1, glossary. Appendix 15 adds that the report "must not be prepared by or for the seller."
Our independence representation
"StrategX Advisory, a dba of Intermountain CFO Group, LLC, confirms that neither it nor its personnel have provided services to [Target] or its owners within the 24 months preceding this engagement, have no relationship with any business broker on this transaction, receive no referral fees in connection with it, and are compensated by a fixed fee that is not contingent on the conclusions of this report, the loan amount, or the closing of the transaction."
Questions about a specific conflict?
Ask before you engage. We'll run the check and tell you within one business day.