8
Capital sources covered
SBA, USDA, bank, CMBS, life company, agency, HUD/FHA, mezzanine.
About the Practice
About FSC Consulting: Independent Feasibility Studies Built for Every Capital Source
FSC Consulting, Inc. is an independent third-party feasibility practice serving commercial real estate borrowers, lenders and capital sources across SBA, USDA, conventional bank, CMBS, life insurance company, agency multifamily, HUD/FHA and mezzanine or preferred equity debt. Every study is built so that one document can travel through the entire capital stack without rework.
We are the independent feasibility study consultant a lender can rely on because the practice has nothing to gain from the answer.
Independent third-party advisorNot a lenderNo operator interestNo advocacy work
15
Bankable checklist criteria
Every engagement scoped against the same checklist.
4
Review passes per study
No deliverable leaves before the fourth pass.
24 hrs
To a fixed-fee engagement letter
After a 30-minute scoping call.
24 mo
No-advisory window
No operator advisory on properties we evaluated.
Who Is Responsible for Every Study
Every credit file starts with the same question: who stands behind this report. At FSC Consulting the answer is printed on the certification page of every deliverable. It names the lead analyst who performed the research and modeling, the senior reviewer who checked it, the data sources used, the independence representations made and the date of each conclusion. Both the lead analyst and the senior reviewer sign.
The engagement letter names the same people before work begins, so the lender knows who will sign the study before the borrower pays for it.
Sarrah Allen, MAI
Sarrah Allen, MAI, is the principal of the practice and the author of its feasibility studies. She signs every study the practice issues, and her name appears on the certification page of each deliverable and in the engagement letter before work begins. After delivery she answers the lender's, the certified development company's or the agency reviewer's questions on the study as part of the fee. The bylines on the practice's guides, case studies, state pages and service pages refer to her.
Why Lenders Engage an Independent Consultant
Every capital source we serve applies its own test of who may prepare the analysis it relies on. The tests differ in wording and agree in substance: the preparer must be qualified for the specific task and must have no stake in the outcome.
USDA Rural Development
The OneRD guaranteed loan regulation defines a feasibility study as a report conducted by an independent qualified consultant evaluating the economic, market, technical, financial and management feasibility of the project, and defines a qualified consultant as an independent third party with the knowledge, expertise and experience to perform the specific task. A study is mandatory for Business and Industry loans above $1,000,000 to a new business and for Community Facilities loans above $1,000,000 to a new entity or new activity, and the Agency may require one on smaller loans when the lender's analysis does not establish feasibility.
SBA 7(a) and 504
SBA regulation 13 CFR 120.160(b) allows SBA to require a feasibility study, and in practice the lender decides when one is needed, most often for start-ups, special-purpose properties, changes of ownership and ground-up construction. Because the lender is relying on the study to support its own credit decision, the preparer's independence from the borrower is what gives the report its weight.
HUD/FHA Multifamily
Under the MAP Guide, the MAP lender selects and is responsible for its third-party market analyst, and every third party must be free of any identity of interest with the borrower, the sponsor or any affiliate. An analyst who has worked for the sponsor is not an option.
CMBS and Rating Agencies
Rating agencies do not adopt third-party figures. They rebuild net cash flow and value on their own assumptions, and their conclusions routinely land well below issuer and appraisal figures. A study written to the most conservative reviewer's standard is the one that survives that process.
Agency Multifamily and Life Companies
Fannie Mae requires market studies to be prepared by a qualified real estate professional, and life company and agency lenders apply their own third-party report standards on top. A consultant who is also a party to the deal cannot meet any of them.
The Bankable Framework
Multi-lender capital stacks are normal in commercial real estate: an SBA CDC behind a conventional bank, a USDA guarantee behind a community lender, a CMBS conduit taking out bank construction debt, a life company refinancing a bridge loan. A feasibility study that satisfies one of those lenders and fails the next costs the borrower a second study and the deal a month.
The bankable framework solves that with one design rule: build to the strictest reviewer in the stack. Every engagement is scoped against a 15-criterion bankable checklist covering market evidence, site and technical capacity, revenue and expense support, debt service coverage and debt yield, absorption and capture, management capacity and sensitivity. Each criterion is set at the threshold of the most demanding capital source on the deal, then reported in the format each lender expects: SOP-cited for SBA, Part 5001-cited for USDA, MAP Guide-formatted for HUD, NCHMA-aligned for tax credit work and rating-agency-aligned for CMBS.
How an Engagement Runs
01 Scoping Call
A 30-minute call before any engagement letter confirms asset class fit, the capital sources in the stack, the regulatory framework that governs each, the required turnaround and the fee.
02 Fixed-Fee Engagement Letter
A fixed-fee engagement letter follows within 24 hours. It names the intended users, the capital sources the study must satisfy, the signing analyst and reviewer, and any potential conflict of interest.
03 Document Request
A document checklist tailored to the asset class and loan program goes to the borrower on signature, so the study is not delayed by documents requested one at a time.
04 Primary Research and Fieldwork
Site inspection, competitive property survey, operator and broker interviews, and verification of rents, rates and operating data against primary sources.
05 Analysis Against the Checklist
Market, technical, financial and management analysis, each scored against the 15-criterion bankable checklist at the strictest threshold in the stack.
06 Four-Pass Quality Review
The lead analyst's work is reviewed by a senior analyst, then re-reviewed by a second senior reviewer who took no part in the primary analysis.
07 Signature and Certification
The lead analyst and senior reviewer both sign. The certification page documents the review chain, the data used and the independence representations.
08 Lender and Agency Comments
Comments from the lender, the CDC or the agency are answered in writing under the terms of the engagement letter, and the study is updated where the evidence supports a change.
Independence Covenants
Independence at FSC Consulting is written into the engagement letter, and each covenant answers a specific test a capital source applies.
No Ownership or Operating Interest
The practice does not own, operate, manage or hold equity in any property it evaluates.
No Referral Fees
The practice accepts no referral fees from operators, brand franchisors or third-party vendors.
24-Month No-Advisory Rule
The practice does not provide ongoing advisory services to operators of properties it has evaluated within the prior 24 months.
Conflicts Disclosed Before Work Begins
Any prior engagement with a comparable-set property, prior work for a competing sponsor in the same submarket, or family or business relationship with a party to the transaction is disclosed in the engagement letter. The sponsor and the lender may terminate at that disclosure with a full retainer refund.
No Advocacy Work
The deliverable is an evidence-led conclusion of feasibility, whatever it concludes. The practice does not write studies designed to reach a sponsor's preferred answer.
What We Do, and What We Do Not
What we do
- Bankable feasibility studies for commercial real estate financing across the 15 asset classes most often financed through institutional capital.
- Cross-program scope across SBA 7(a) and 504, USDA OneRD (B&I, CF, REAP), conventional bank, CMBS conduit and SASB, life insurance company, agency multifamily, HUD/FHA, and mezzanine or preferred equity layered with senior debt.
- Market analysis and demand modeling: submarket vacancy, absorption, comparable supply, demand drivers, demographic catchment and capture rate.
- Financial projections and sensitivity testing: five-year pro forma, debt service coverage and debt yield at every relevant lender threshold, loan-to-value stress testing and capital stack analysis.
- Lender-format deliverables: SOP-cited for SBA, Part 5001-cited for USDA, MAP Guide-formatted for HUD, NCHMA-aligned for tax credit work, rating-agency-aligned for CMBS.
What we do not
- Appraisals or opinions of value. Where a lender requires a value opinion, it is obtained from a separately engaged appraiser.
- Phase I or Phase II environmental site assessments.
- Business plans presented as feasibility studies.
- Advocacy work for sponsors.
- Engagements outside our asset-class coverage; specialty assets are referred to specialists.
- Ongoing operator advisory on properties evaluated within the prior 24 months.
Standards We Build To
Every engagement is scoped to the regulatory and professional standards that govern each capital source on the deal. These are the operating floor, current as of October 2026.
SBA SOP 50 10 8.1
SBA Standard Operating Procedure 50 10 8.1, with its Technical Policy Updates, took effect October 1, 2026; loans processed before the transition remain under SOP 50 10 8, effective June 1, 2025. It governs 7(a) and 504 eligibility, change-of-ownership requirements, special-purpose property treatment and the documentation lenders use to decide when a feasibility study is needed.
USDA OneRD, 7 CFR Part 5001
The OneRD guaranteed loan regulation, as amended through the technical amendments published December 11, 2025 at 90 FR 57351. The feasibility study is defined at section 5001.3, the Agency's authority to require an independent study sits at section 5001.303(c)(4), the mandatory triggers for Business and Industry and Community Facilities loans sit at sections 5001.306(a)(3) and 5001.304(a)(4), and the five study components are detailed in Appendix A to Subpart D.
HUD MAP Guide
The Multifamily Accelerated Processing Guide (4430.G), 2020 edition, revision of March 19, 2021, as amended by Mortgagee Letters through 2026. It governs market study scope and third-party standards for Section 221(d)(4) construction and Section 223(f) refinance lending.
Fannie Mae and Freddie Mac Multifamily Guides
The Fannie Mae Multifamily Selling and Servicing Guide and the Freddie Mac Multifamily Seller/Servicer Guide set the third-party report requirements for agency multifamily lending, including who may prepare a market study and what it must establish.
NCHMA Model Content Standards
The National Council of Housing Market Analysts Model Content Standards, updated September 2025, govern market study scope for tax credit and affordable housing work and are increasingly cited by HUD and agency reviewers.
CMBS Rating Agency Methodologies
The KBRA North American CMBS Property Evaluation Methodology, dated January 9, 2026, and the published CMBS methodologies of S&P Global Ratings, Fitch Ratings, Moody's Ratings and Morningstar DBRS. Studies for conduit and SASB execution are reconciled to the agencies' net cash flow conventions.
USPAP
Our feasibility studies are not appraisals and contain no opinion of value, so the USPAP Standards governing appraisal development and reporting do not apply to them. Where a study is signed by a credentialed appraiser, that individual performs the work in conformance with the USPAP ETHICS RULE, COMPETENCY RULE and JURISDICTIONAL EXCEPTION RULE. Where a lender requires a value opinion, it is obtained from a separately engaged appraiser.
Key Figures by Capital Source
The thresholds and conventions that most often decide what a study must contain, grouped by the capital source that sets them. Current as of October 2026.
October 1, 2026
SOP 50 10 8.1 in force
Earlier loans remain under SOP 50 10 8, effective June 1, 2025.
$3 million
Quality of Earnings line
Business acquisitions at or above this purchase price require a Quality of Earnings report alongside the business valuation.
$1,000,000
Mandatory feasibility study line
B&I loans above this amount to a new business, and CF loans above it to a new entity or activity, require a study by an independent qualified consultant.
$600,000
B&I full application threshold
Guaranteed loan requests above this amount must submit the complete application package.
5
Required study components
Economic, market, technical, financial and management feasibility.
90%
CF occupancy ceiling
Projections for assisted living, skilled nursing and similar residential facilities may assume no more than 90 percent occupancy.
4430.G
Current MAP Guide
2020 edition, revision of March 19, 2021, amended by Mortgagee Letters through 2026.
$120 million
Large Loan Risk Mitigation base
Set by Mortgagee Letter 2023-14 and indexed annually; larger loans carry added credit requirements.
3
Fannie Mae market study essentials
Absorption rate, lease-up period and rent levels for comparable market-rate properties, prepared by a qualified real estate professional.
September 2025
NCHMA Model Content Standards
The current update of the market study standard for tax credit and affordable housing work.
January 9, 2026
KBRA Property Evaluation Methodology
The current KBRA North American CMBS methodology for net cash flow and value.
35% to 39%
KBRA value haircut
In KBRA's 2026 BBCMS 5C41, 5C42 and 5C43 conduit presales, KBRA values ran 35.2% to 39.3% below third-party appraised values.
Data Infrastructure
Every market analysis, comparable set and financial projection draws on licensed third-party data. The active subscription stack is listed in every engagement letter and reviewed annually.
CoStar
Office, retail, industrial and multifamily comparables; submarket vacancy and absorption.
STR
Lodging competitive sets, ADR, occupancy and RevPAR by chain scale and market.
IBISWorld
Industry growth rates, operating margins and sector demand drivers.
RMA Annual Statement Studies
Industry operating ratios for SBA and conventional pro forma validation.
Esri Business Analyst
Demographic catchment, drive-time analysis and consumer demand modeling.
Moody's Analytics
Macroeconomic forecasts, employment projections and regional economic data.
NCHMA methods
Capture rate, penetration and rent comparability standards for multifamily and senior housing.
Specialty data
Asset-class subscriptions for self-storage, seniors housing and outdoor hospitality, added per engagement.
Professional Liability and Quality Review
Errors and Omissions Insurance
Errors and omissions insurance is in place with $1 million in coverage. The carrier, the policy type and the per-claim and aggregate limits are documented in the engagement letter, and a certificate of insurance is available to the sponsor and lender on request before the letter is signed. The policy covers the analytical work in the deliverable and the certification representations made in the conclusion of feasibility.
Four-Pass Quality Review
No deliverable reaches a sponsor or lender without four review passes. The lead analyst completes the primary research, market analysis and financial modeling. A senior analyst reviews methodology, comparable set selection, sensitivity assumptions and regulatory citations. A second senior reviewer, not involved in the primary analysis, re-reviews comparable set defensibility, financial model integrity and citation accuracy. The lead analyst and senior reviewer both sign, and the certification page records the full review chain.
Corrections
If a lender or agency identifies a factual error in a delivered study, the correction is issued in writing, dated and signed by the same review chain.
The Record
The fastest way to judge a feasibility consultant is to read the work.
Sample Reports
Redacted examples of delivered studies by asset class and capital source.
Case Studies
More than 40 case studies across asset classes and loan programs.
Engagements by Loan Program
SBA 7(a), SBA 504, USDA B&I, REAP, CF and conventional.
Engagements by Asset Class
From hotels and RV parks to cold storage, childcare and data centers.
Lender Matrix
Which capital source requires what, side by side.
Feasibility Study Consultant: The Complete Guide
How sponsors and lenders select, scope and use an independent consultant.
Frequently Asked Questions
An independent consultant tests whether a proposed project can be built, leased or operated, and financed on the proposed terms, then reports the conclusion to the lender whatever it is. The work covers market demand, site and technical capacity, projected cash flow, debt service coverage and management capacity. Independence means the consultant has no ownership, operating, referral or advisory interest in the project.
No. FSC Consulting prepares feasibility studies, which contain no opinion of value. Where a lender requires a value opinion, it is obtained from a separately engaged appraiser, and our study is built to sit beside that appraisal in the same credit file.
Under 7 CFR Part 5001, a study by an independent qualified consultant is required for Business and Industry guaranteed loans above $1,000,000 to a new business and for Community Facilities guaranteed loans above $1,000,000 to a new entity or new activity. On smaller loans the Agency may require one when the lender's analysis does not establish feasibility or the project will significantly affect an existing operation.
SBA regulation allows SBA to require a feasibility study, and lenders decide case by case under SOP 50 10 8.1. Studies are most often requested for start-up businesses, special-purpose properties, changes of ownership with projection-dependent repayment and ground-up construction.
A bankable study is one every lender in the capital stack can rely on without commissioning a second report. That requires primary-source market evidence, projections supported line by line, coverage and sensitivity tested at the strictest lender threshold on the deal, an independent preparer and a format each reviewer recognizes.
Yes, when it is scoped for all of them from the start. The bankable framework sets each criterion at the most demanding capital source's threshold and reports it in the format each lender expects, so the same study can sit in every credit file on the deal.
In the engagement letter, which states the independence covenants and discloses any potential conflict before work begins, and on the certification page of the study, which records the independence representations and the signing review chain.
After a 30-minute scoping call, the practice issues a fixed-fee engagement letter within 24 hours. The fee depends on asset class, capital sources and scope, and it does not depend on the study's conclusion. Use the feasibility study cost estimator for a range before the call.
Engage the Practice
A 30-minute scoping call. A fixed-fee engagement letter within 24 hours. No obligation and no sales calls.