The Situation
The subject was an established RV park being acquired as a going concern, on a parcel near a steady source of long-term demand. Its revenue was dominated by long-term tenancy — seasonal snowbird leases and month-to-month extended-stay guests — which gave it the steadiest occupancy and the lowest turnover in its submarket. The all-in acquisition ran to roughly $3.2 million across the land, the site improvements, the amenities, and going-concern value.
The deal was structured for SBA 7(a) financing — the natural vehicle for a going-concern hospitality acquisition with a working-capital component. Because RV parks are special-purpose property, an independent feasibility study was expected to support the projections, and the going-concern appraisal had to allocate value among the land, the site improvements, the equipment, and the business itself.
The sponsor's pro forma led with stability: high occupancy, low turnover, predictable long-term income. The analytical question was whether that stability was an asset to the credit, or whether — under the program's own rules — it was a problem.
The Conventional Reading
The intuitive way to underwrite a hospitality acquisition is cash-flow stability: low turnover, high year-round occupancy, predictable income, little marketing spend. On that logic the park looked like the safest deal in its market — a long-term tenant base that filled the sites month after month and produced income an underwriter could rely on. A screen for revenue stability would have ranked this park at the top.
It was also the mix most likely to put the park outside the financing program entirely — because for an SBA loan, stability of income is not the test, and a long-term-dominant park can read as something the program cannot lend on at all.
The Analytical Inflection Point
For SBA eligibility, an RV park has to be an active hospitality business, not passive real estate — and the line lenders apply is the share of revenue from short-term stays, which means the long-term mix that maximizes stability can disqualify the loan. As specialist SBA lenders read SOP 50 10 8 together with the agency's ineligible-business rules, a park generally qualifies as an active business when more than half of its revenue comes from stays of thirty days or less; a park whose revenue is predominantly long-term or residential is treated like an apartment complex or a mobile home park — passive real estate, which is explicitly ineligible for SBA financing. The mechanism is exactly inverted from the stability screen: the seasonal and long-term tenancy that produced the steadiest income is the same tenancy that pushes the park below the short-term-revenue line and toward ineligibility, while the transient, nightly business that looks more volatile is precisely what establishes the park as an active, fundable business.
The inflection is that the safest-looking income mix was the one the loan could not accept, and the path to financing ran through more transient exposure, not less. Re-examined against how lenders apply the rule, the subject's revenue mix sat on the wrong side of the short-term-revenue line as configured, and the deal as presented was at risk of being ineligible regardless of how strong the cash flow was. The bankable structure was a deliberate rebalancing — a transient and short-term-stay share carried above the threshold, with extended-stay tenancy structured as month-to-month rather than long-term lease — so the park presented to the lender as the active business the program requires. The relevant analysis was not how stable the income was. It was how the revenue mix mapped to the eligibility line the lender would apply, and what structure put the park on the fundable side of it.
Evidence and Methodology
Revenue mix against the eligibility line. The park's revenue was decomposed by length of stay — nightly transient, monthly extended-stay, and seasonal or annual long-term — and measured against the short-term-revenue share lenders apply under SOP 50 10 8, so the eligibility question was framed before the cash-flow question.
Active-business versus passive-real-estate framing. The analysis set the park against the agency's ineligible-business treatment of passive residential real estate — apartments and mobile home parks — and identified where a long-term-dominant RV park risks being read the same way, so the determination the lender would make was anticipated rather than assumed.
Structure to the fundable side. A rebalanced revenue mix was modeled — a transient and short-term share carried above the threshold, with extended-stay tenancy structured month-to-month rather than as long-term leases — so the park could present as an active hospitality business without abandoning the demand base that supported it.
Cash flow on the qualifying mix. Debt-service coverage was rebuilt on the rebalanced, eligibility-compliant revenue mix rather than on the original long-term-dominant one, confirming the deal carried under the structure that actually qualified.
Going-concern allocation. The appraisal's allocation among land, site improvements, equipment, and business value was tied to the financing, clarifying how much of the loan was collateralized by real estate and how the going-concern value was treated.
Eligibility as a lender determination. Throughout, the short-term-revenue test was treated as a rule the lender and the SBA apply — with documented variation in how lenders read the details — and the feasibility's role was to surface and support it, not to make the eligibility call.
What the Lender Saw
The credit file led with the eligibility question the stability screen would have missed: a decomposition of revenue by length of stay, measured against the short-term-revenue share the program requires, and a rebalanced structure that put the park on the active-business side of the line. The analysis showed why the steadiest income mix was the riskiest for eligibility, modeled the qualifying mix, and rebuilt coverage on it. The lender made the eligibility determination on a revenue mix that supported it, and the going-concern allocation clarified the collateral. The independent study answered the program's threshold question before the cash-flow question, which is where RV park credits are most often misjudged.
The Outcome
The 7(a) financing closed on a deliberately rebalanced revenue mix — transient and short-term share carried above the eligibility line, extended-stay tenancy structured month-to-month — rather than on the long-term-dominant mix the deal began with. The inflection was not that the park's income was weak; it was the steadiest in the market. It was that for an SBA loan, stability is not the test, and the mix that maximized stability was the one the program could not accept — so the bankable structure ran through more transient exposure, not less.
Analytical Posture Takeaways
- 01For SBA eligibility, an RV park must be an active business, not passive real estate. Lenders apply this through the share of revenue from short-term stays, so the eligibility question precedes the cash-flow question.
- 02Stability can disqualify. A long-term or seasonal-dominant mix produces the steadiest income but can push a park below the short-term-revenue line and into the same ineligible treatment as an apartment or mobile home park.
- 03The fundable path can run through more transient exposure. Carrying the transient and short-term share above the threshold — and structuring extended stays month-to-month rather than as long-term leases — is what presents the park as an active business.
- 04Eligibility is a lender determination the feasibility supports. The analysis surfaces the revenue-mix test and structures to it; the lender and the SBA make the call, and lenders vary in how they read the details.
Representative engagement illustrating Feasibility Study Consultant's analytical methodology. Benchmark and market figures are drawn from public and industry sources; deal-specific details are illustrative and do not identify a client. SBA eligibility rules are applied by lenders and the SBA and are subject to interpretation; this firm provides independent feasibility analysis relied upon in that process and does not determine loan eligibility.
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