SBA 8(a) Application Review & Compliance Consultant (Successor Business)

We are seeking an experienced SBA 8(a) consultant to conduct a pre-submission compliance and risk review of a nearly completed SBA 8(a) Business Development application.

This engagement is review and validation only — not drafting from scratch, not SAM.gov setup, and not a generic advisory role.

Background:

Applicant company formed in September 2024

Acquired the operating assets, goodwill, contracts, employees, and client relationships of a long-established property management company in December 2024

Business has continued uninterrupted operations as a residential / HOA property management firm

Application is being submitted without requesting a two-year waiver, relying on successor-business continuity under 13 C.F.R. § 124.107

Scope of Work – Review & Validation:

The consultant will review the existing application and provide written, regulation-based feedback on the following high-risk areas:

1. Two-Year Rule & Successor Business Eligibility

- Validate whether the applicant qualifies as a successor operating concern for purposes of 13 C.F.R. § 124.107

- Confirm whether a two-year waiver is legally required given the asserted successor-business continuity, or whether the current posture is defensible without a waiver.

- Identify any RFI or denial risks related to continuity of operations, asset acquisition structure, or timing

2. Business Tax Returns & Revenue Continuity (Critical)

- Review compliance and sufficiency of business tax returns submitted, including:

Three (3) years of predecessor company tax returns

One (1) year of successor company tax return

- Confirm whether this tax return set is appropriate and sufficient to support:

Successor-business treatment, and

The two-year operating history requirement without requesting a waiver

- Identify any risk of SBA objection or RFI related to attribution of operating revenue between predecessor and successor entities

- Advise whether any additional reconciliation or explanatory narrative is recommended, or whether the current submission is sufficient as-is

3. NAICS Code Strategy

- Review appropriateness of primary NAICS selection (Residential Property Management) for SBA 8(a) purposes

Assess any risk or compliance implications related to NAICS consistency across SAM registration, tax filings, and contract documentation

4. Contracts, Revenue & Reporting

- Review treatment of monthly-fee contracts

- Confirm proper reporting of:

Total Contract Value vs. Award Revenue

Ongoing vs. completed contracts

Contracts originating with the predecessor entity but continuing post-acquisition

- Flag any entries that could appear projected, inflated, or inconsistent under SBA review

5. Management & Control Disclosures

- Validate disclosure of non-owner officers and key management personnel

- Confirm treatment of W-2 vs. 1099 personnel for SBA disclosure purposes

- Review license-holder disclosures for SBA control compliance

6. Disadvantaged Status (Social & Economic)

- Confirm that the applicant’s owner qualifies as socially disadvantaged under SBA’s presumed groups pursuant to 13 C.F.R. § 124.103

- Confirm whether the current concise social disadvantage statement is sufficient as submitted, or whether SBA would require or reasonably expect any expansion beyond confirmation of presumed status, absent a specific SBA request

Deliverables:

Written review memo or annotated feedback identifying:

- Compliance gaps (if any)

- SBA red flags

- Recommended corrections or confirmations

- Brief call to walk through findings

Required Qualifications

- Demonstrated experience reviewing or preparing SBA 8(a) applications

- Strong working knowledge of:

13 C.F.R. Part 124

Successor-business and acquisition scenarios

SBA control and potential-for-success analysis

- Experience with property management or real estate–related SBA applicants strongly preferred

- Ability to cite SBA regulations or policy guidance when giving advice

Not a fit if:

- You only use AI for evaluation

- You only assist with SAM.gov registration

- You rely on generic templates

- You do not have hands-on 8(a) regulatory review experience

- You are unfamiliar with successor-business eligibility issues

To apply, please Include:

- Brief description of your SBA 8(a) experience

- Examples of similar reviews (no confidential details)

- Your approach to successor-business eligibility

- Estimated timeline for review

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