Records Search with Risk Assessment (RSRA)

Short answer: A Records Search with Risk Assessment (RSRA) is the records-only environmental report defined in SBA SOP 50 10 8.1: a search of government databases (40 CFR 312.26) and historical records, with an Environmental Professional (EP) rating the property low, elevated or high risk. With the lender’s Environmental Questionnaire, it is the minimum for loans over $250,000 with no Appendix 6 NAICS match. Elevated and high ratings require a Phase I.

When SBA requires an RSRA, and when it is not enough

For every commercial property pledged as real estate collateral, the lender follows the U.S. Small Business Administration’s (SBA) Standard Operating Procedure (SOP) 50 10 8.1, Section A, Chapter 5, Paragraph E.4. It starts with a good-faith check of the property’s current and known prior uses against the environmentally sensitive industry codes (NAICS, the North American Industry Classification System) in Appendix 6. Our SBA NAICS code lookup checks a code or an industry description against that list. The loan amount matters only when there is no match.

For a unit in a non-industrial building of 4 or more units, such as an office condominium, the lender may skip the NAICS step and go straight to the loan-amount rows (Paragraph E.4.a). That shortcut does not override the dry cleaning rule: a unit with on-site dry cleaning, now or in the past, still needs a Phase I followed by a Phase II (Paragraph E.6.b).

The Questionnaire is a separate document. The lender completes or reviews it after a site visit and a good-faith attempt to interview the current owner or operator, who must sign it (Appendix 4). Our guide to SBA environmental requirements covers every step, and the SBA environmental requirement checker applies them to a single loan.

What the RSRA report must contain

SBA defines the RSRA in Appendix 4 of the SOP. A lender can check a report against this list before it goes in the loan file:

1. Government records. A search of the government databases identified in 40 CFR 312.26 for an All Appropriate Inquiries (AAI) Phase I, at the distances in the table below.
2. Historical sources. Aerial photographs, city directories, reverse directories, fire insurance maps or similar records for the property and adjoining properties (including those across a street), chosen by the EP and reaching back to the first developed use or 1940, whichever is earlier, with comments on any data gap. There is no fixed number of sources: the EP reviews as many as are necessary, reasonably ascertainable and likely to be useful.
3. A risk classification. The EP’s conclusion that the property is low, elevated or high risk for contamination.
4. The EP’s name. The report must name the Environmental Professional who performed the risk assessment.
5. The records themselves. Every database report and historical source relied on must be included.
6. A current date. Within one year of the date the SBA loan number is issued (Paragraph E.3).

These are the AAI search distances in 40 CFR 312.26(c). The EP may change a distance on professional judgment but must document the reason (312.26(d)).

For the property itself, the review should also include records of reported releases, storage tanks, hazardous waste generators, spills, and engineering and institutional controls, among others (312.26(b)).

Who may prepare it. The risk assessment must be made by an Environmental Professional as defined in 40 CFR 312.10(b). That rule sets 4 qualification routes, from a current Professional Engineer or Professional Geologist license plus 3 years of full-time relevant experience to 10 years of such experience alone. SBA adds that the EP must be impartial and carry errors and omissions insurance of at least $1,000,000 per claim (or occurrence). A database printout with no EP assessment is not an RSRA, and the SOP names no approved vendors.

Low, elevated or high: what each result means

SBA does not define the criteria for low, elevated or high risk; they are left to the EP’s judgment. The SOP defines only what follows (Paragraph E.4.c).

Because elevated and high lead to the same next step, the label matters less than the EP’s written reasons, which show which listing or past use drove the rating and what the Phase I should examine.

Two situations need care. If the history reveals a prior use listed in Appendix 6, such as a former gas station or auto repair shop, that use is now a known prior use, and the safer reading of Paragraph E.4.a is that a Phase I is required whatever the rating. If the Questionnaire flagged a concern, as it must for an RSRA to be required on a loan of $250,000 or less, the SOP does not say a low rating resolves it. Make sure the EP addresses that concern directly, and take any doubt to local SBA counsel (Paragraph E.9).

Why an RSRA needs no SBA reliance letter

The SOP says an RSRA “need not be addressed to the SBA and need not be accompanied by a Reliance Letter” (Appendix 4). The Appendix 5 letter has check boxes only for a Transaction Screen, a Phase I (or updated Phase I) and a Phase II, and its language may not be modified, so an “Appendix 5 letter” for an RSRA would be an altered form. A lender that wants reliance on an RSRA is applying its own policy, not SBA’s.

If the RSRA leads to a Phase I, that Phase I does need the Appendix 5 letter, even when it is addressed to the lender (Paragraph E.3). Our guide to SBA reliance letters explains the form.

How an RSRA differs from a desktop screen, a Transaction Screen and a Phase I

An RSRA is not an AAI report. AAI also requires interviews, a search for environmental cleanup liens, a visual inspection and the EP’s declaration (40 CFR 312.20), and SBA’s RSRA definition calls for none of them.

That is why an RSRA cannot meet the AAI requirement of a buyer’s defenses under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the federal Superfund law. For most buyers the relevant one is the bona fide prospective purchaser defense, defined in 42 U.S.C. 9601(40) and granted by 42 U.S.C. 9607(r). A Phase I meets only one of its requirements; the defense also depends on the buyer’s own inquiries and on continuing obligations after closing. Whether a buyer qualifies is a question for the buyer’s attorney.

The RSRA vs Transaction Screen vs Phase I guide compares the reports in more depth, and our Phase I ESA page covers the full assessment.

How long an RSRA is valid for an SBA loan

An RSRA must be dated within one year of the date the SBA loan number is issued (Appendix 4; Paragraph E.3). The Environmental Protection Agency’s (EPA) 180-day clock does not apply, because an RSRA is not an AAI report. An RSRA dated November 3, 2026 can support a loan number issued in August 2027, but not one issued in December 2027.

The Questionnaire and any Phase I that follows are on the same one-year clock. SBA will accept for review an otherwise AAI-compliant Phase I dated within one year of the loan number, even though EPA’s update rule uses 180 days. The SOP adds that parties may still wish to meet EPA’s timeframes so as not to jeopardize legal and regulatory protections.

SOP 50 10 8.1 was published September 25, 2026 and took effect October 1, 2026. By our word-by-word comparison, its RSRA rules are the same in substance as those in the 2025 SOP, so the checklist above applies under either version.

Our RSRA: price, timing and what happens if it escalates

We charge $695 flat and deliver in 2 business days from authorization, or the next business day for $150 more. That turnaround comes from proprietary internal technology we built, which collects and organizes the regulatory and historical records the day an order is authorized, so an Environmental Professional who meets 40 CFR 312.10 reviews an organized record instead of assembling one. Before we start, we check the property uses you give us against Appendix 6, so you learn at the outset if the rules call for a Phase I instead.

If the RSRA comes back elevated or high, or you decide you want a Phase I anyway, the full $695 fee is credited toward a Phase I on the same property ordered within 30 days. For a standard-scope property (one parcel of up to 5 acres, up to 3 buildings and 50,000 square feet, and no heavy industrial or manufacturing use), the Phase I is $1,495, so the step up costs $800 more and the total for both reports is $1,495.

For comparison, these are the RSRA prices other firms listed on their own websites when we checked on October 19, 2026:

Scopes differ: our RSRA does not include the Environmental Questionnaire, which the lender completes or reviews. Whatever the price, check the report against the 6-item checklist under “What the RSRA report must contain” above.

Sources

1. SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates, U.S. Small Business Administration (Word file; Section A, Chapter 5, Paragraphs E.2 to E.9, and Appendices 4 to 6), accessed October 2026
2. 40 CFR 312.26, Reviews of Federal, State, Tribal, and local government records, Electronic Code of Federal Regulations, accessed October 2026
3. 40 CFR 312.10, Definitions, Electronic Code of Federal Regulations, accessed October 2026
4. 40 CFR 312.20, All appropriate inquiries, Electronic Code of Federal Regulations, accessed October 2026
5. 42 U.S.C. 9601, Definitions (CERCLA section 101), U.S. Government Publishing Office, United States Code 2024 edition, accessed October 2026
6. 42 U.S.C. 9607, Liability (CERCLA section 107), U.S. Government Publishing Office, United States Code 2024 edition (subsection (r)), accessed October 2026
7. Lender Liability and Applicability of All Appropriate Inquiries, U.S. Environmental Protection Agency (EPA-560-F-23-006, page 2), accessed October 2026
8. ASTM E1528-22, Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process, ASTM International, accessed October 2026
9. SBA RSRA, Records Search With Risk Assessment, Kross Inspectors, accessed October 2026
10. RSRA, Record Search with Risk Assessment, A3 Environmental Consultants, accessed October 2026
11. Phase 1 Environmental Site Assessment Services and Pricing, Phase Enviro, accessed October 2026