Borrower guide · SBA and USDA

    Feasibility Study Document Checklist: What a Consultant Needs From the Borrower, by Asset Class and Loan Program

    A feasibility study can only be as good as the documents behind it. This checklist sets out what a lender-grade consultant needs on SBA 7(a), SBA 504 and USDA B&I loans, how the request changes for start-ups, construction, acquisitions and expansions, the asset-class records that decide hotel, gas station, car wash, RV park, self-storage and senior living studies, and the recency rules that determine whether a document can still be used.

    By Sarrah Allen, MAI · October 1, 2026

    Most feasibility studies that run late do not run late because of the analysis. They run late because the analysis is waiting for a document. An interim balance sheet is four months old. The construction budget is a single line from the contractor. The franchise approval letter is "coming." The seller's monthly numbers exist only inside a point-of-sale system nobody has exported. Each gap is small, and each one stops a section of the study, because every conclusion a consultant reaches has to trace back to something the lender and the agency can read.

    The documents a study needs are not a matter of consultant preference. A large share of them are fixed by the loan programs themselves. USDA's OneRD rule, 7 CFR Part 5001, lists the financial statements, projections, appraisals, credit reports and technical documentation a Business and Industry (B&I) application must contain, and sets how current each must be. SBA's regulations set the baseline for 7(a) and 504 applications, and SBA's Standard Operating Procedure fills in the detail. A revised version, SOP 50 10 8.1, took effect on October 1, 2026 for loans that receive an SBA loan number on or after that date. Rules outside lending fix the rest: the Federal Trade Commission's Franchise Rule for franchised projects, EPA's underground storage tank rules for fuel sites, and state campground and health care licensing for RV parks and senior living.

    This checklist sorts the request in the order a consultant uses it: the baseline every program expects, the additions each transaction type requires, the records each asset class depends on, and the recency rules that decide whether a document can still be relied on. Throughout, it separates two kinds of item. Some documents are required by a rule, and a reviewer will look for them. Others are required by good practice, because the study cannot answer the reviewer's questions without them. Both matter. Knowing which is which tells a borrower where there is room to substitute and where there is none. It is written as a companion to the complete guide to working with a feasibility study consultant.

    Why the Document Request Decides the Study

    A feasibility study is a chain of findings, and each link is a document. The market section rests on traffic counts, competitor surveys and demographic data the consultant gathers independently. The financial section rests almost entirely on what the borrower provides: historical statements, the construction budget, the operating plan, and the contracts that fix revenue and cost.

    USDA states the standard plainly. Under 7 CFR 5001.202(b)(6), financial projections that deviate from historical performance must be substantiated and documented, with comparisons to industry standards such as Dun & Bradstreet or the Risk Management Association. A consultant cannot measure deviation from history without the history, and cannot substantiate a projection without the contracts, budgets and operating data behind it. Where a document is missing, the consultant has to replace it with an assumption, and assumptions are exactly what reviewers question.

    The cost of getting it wrong is also written down. Under 5001.303(d), once USDA accepts an application, any modification to it is treated as a new application, with the submission date reset to the date the new information arrives. A feasibility study revised mid-review because a document surfaced late can cost an applicant its place in the queue. On an SBA file the consequence is less formal but just as real. A delegated lender that finds a gap after its credit memo is written has to reopen the memo, and a non-delegated file goes back and forth with SBA's loan processing center.

    The practical lesson is simple: assemble the package before the engagement starts, not during it.

    The Baseline Every Program Expects

    SBA 7(a) and 504

    SBA's regulation sets out the core. Under 13 CFR 120.191, a business loan application must contain a description of the history and nature of the business, the amount and purpose of the loan, the collateral offered, current financial statements, historical financial statements (or tax returns where appropriate) for the past three years, IRS tax verification, and a business plan when applicable, together with personal histories and financial statements from the principals. For 504 loans, 13 CFR 120.882 adds a specific description and itemization of each business expense being financed, which is the regulatory basis for the detailed sources and uses table every 504 study needs.

    SOP 50 10 8.1 supplies the detail, and its document rules are still bedding in. The National Association of Government Guaranteed Lenders has advised that until SBA updates its application forms, lenders must collect everything required by both the existing forms and the new SOP. Where the two differ, the stricter rule governs the file. Published industry summaries of the new SOP report that personal financial statements for owners of 20 percent or more and for guarantors must now be dated within 90 days of submission, down from 120 days, while business interim statements remain on a 120-day window. The printed SBA Form 413 still carries the older 120-day language, which is precisely the kind of conflict NAGGL's guidance resolves in favor of the SOP.

    The 504 application form shows what lenders collect in practice: a personal financial statement for each principal, a current balance sheet and income statement for the business, projected annualized income statements with assumptions where appropriate, statements for affiliates, a personal history form, and for franchises, the franchise agreement and the franchisor's disclosure document. On the tax side, lenders verify returns through IRS Form 4506-C, and the IRS must receive the form within 120 days of the borrower's signature. The verification is the lender's task, but the consultant should reconcile the historical figures in the study to the same returns. A study built on numbers the transcripts later contradict loses its credibility in one step. How an SBA feasibility study consultant works within the delegated and non-delegated processes is covered separately.

    USDA B&I

    USDA's B&I requirements are longer and more precise. The core application forms are Form RD 5001-1, the Application for Loan Guarantee, and Form RD 5001-2, the Lender's Agreement. Form RD 5001-12, the Certification of Non-Relocation and Market and Capacity Information Report, applies to loans over $1,000,000 that will increase direct employment by more than 50. Projects with five or more residential units, including nursing homes and assisted living, need an Affirmative Fair Housing Marketing Plan, and real estate collateral needs a FEMA flood hazard determination.

    The financial requirements sit in 5001.303(b)(4):

    • A current balance sheet and year-to-date income statement for the borrower and any guarantors, dated within 90 days of submission of the complete application.
    • Historical balance sheets, income statements and cash flow statements for the lesser of the last three fiscal years or all years of operation.
    • Projections running through a minimum of two years of the project performing at full capacity or stable operations, supported by a list of assumptions, and including a pro forma balance sheet projected for guaranteed loan closing.

    USDA's B&I application checklist adds a detail that catches borrowers who have only ever dealt with SBA: for historical statements, tax returns are not acceptable. Prepared statements are required.

    Section 5001.303(c) lists provisional items the Agency may require: a draft loan agreement on loans of $600,000 or more, appraisals, credit reports on the borrower, guarantors and 20 percent owners (required for applications of $200,000 or more), engineering documentation, architectural reports, a business plan unless its content is covered in the feasibility study or credit evaluation, a certificate of need where federal or state law requires one, technical reports and organizational documents. The feasibility study itself is mandatory under 5001.306(a)(3)(i) for guaranteed loans greater than $1,000,000 to a new business, prepared by an independent qualified consultant acceptable to the Agency. A technical report is required for renewable energy systems and for projects using other integrated processing equipment and systems.

    Core documentSBA 7(a) and 504USDA B&IWhy the consultant needs it
    Business interim statementsCurrent; 120 days reported under SOP 50 10 8.1Within 90 days of complete applicationEstablishes the trading position the projection starts from
    Historical statementsThree years (13 CFR 120.191); returns may serveLesser of three years or all years; returns not acceptableBaseline against which every projected line is tested
    Personal financial statements90 days reported under SOP 50 10 8.1Within 90 days for guarantorsGuarantor capacity and global cash flow
    ProjectionsWith assumptions where appropriateTwo years at stabilized operations, with assumptions and a closing pro forma balance sheetThe study tests them; it does not adopt them
    Business planWhen applicableUnless covered by the study or credit evaluationManagement intent, staffing and operating model
    Sources and usesItemized for 504 (13 CFR 120.882)Itemized project costsTotal project cost and the equity test
    AppraisalLender and SOP requirementsNot more than one year old (5001.203)Reconciliation of income and value
    Credit reportsLender requirementRequired at $200,000 or moreBorrower and guarantor capacity

    The Strictest-Common-Rule Package

    Borrowers rarely know at the outset whether their project will end up as an SBA 7(a), a 504 or a USDA B&I loan, and lenders sometimes switch programs during underwriting. The efficient approach is to build one package to the strictest rule that applies across all three:

    • Business interim statements and personal financial statements dated within 90 days, refreshed if the file slips.
    • Three years of prepared historical statements, not just tax returns, plus the returns themselves for reconciliation.
    • Projections with written assumptions, reconciled line by line to history, running through two years of stabilized operations, with a pro forma balance sheet at closing.
    • An itemized sources and uses table that ties to the construction budget, the purchase agreement or both.

    A package built this way satisfies USDA, meets SOP 50 10 8.1 as currently reported, and covers most conventional lenders. It also gives the consultant everything needed for the financial section on the first day of the engagement.

    Documents by Transaction Type

    The baseline is the same for every project. What changes most from one engagement to the next is the transaction type, because each type asks the study a different question.

    Start-ups and ground-up construction

    A start-up has no history to test, so the study rests on the project's design, cost and plan. The consultant needs:

    • Site plan and architectural plans, even at schematic stage, showing the building program the projection assumes.
    • A construction budget with contractor bids or a contractor's detailed estimate, not a single lump-sum figure.
    • A construction schedule, with the expected date of the certificate of occupancy.
    • Zoning confirmation and permit status, ideally a zoning verification letter from the jurisdiction.
    • Utility availability letters for water, sewer, electric and gas, with capacity stated where the project is utility-intensive.
    • Sources and uses, with evidence of the equity contribution.
    • Management resumes and, for franchised projects, the franchise agreement and approval.

    Several of these rest on explicit USDA rules. Where a B&I guarantee is requested before construction is complete, 5001.202(b)(6)(vi) requires a construction schedule and a quarterly operational cash flow analysis from the current financial statements through start-up or occupancy, mirroring quarterly construction costs and showing whether each is funded by the loan, equity or other sources. Appraisals for construction must report both the as-is value and the prospective value at completion (5001.203(c)). The lender must ensure facilities are designed to code and that the borrower obtains all necessary permits, rights-of-way, agreements and licenses (5001.205). The minimum equity for a new business on a construction project where the guarantee is issued before completion is 25 percent.

    SBA rules are less prescriptive on construction documents, but the 504 itemization requirement applies, and under SOP 50 10 8 a start-up, defined as a business in operation one year or less, carries a 10 percent minimum equity injection. No program rule names zoning letters or utility availability letters specifically. They are consultant requirements, and they belong in the package because the study's technical section cannot conclude that the project can be built without them.

    Acquisitions of operating businesses

    An acquisition has history, and the study's job is to test whether that history will persist under new ownership. The consultant needs:

    • Three years of historical financial statements and tax returns for the business being acquired (13 CFR 120.191 for SBA; the lesser of three years or all years for USDA).
    • Year-to-date interim statements and the trailing twelve months.
    • Monthly operating data for at least the two most recent years, by revenue line.
    • The purchase agreement and any seller note or earn-out terms.
    • Leases, management agreements, franchise agreements and supply contracts.
    • The seller's own operating reports from the point-of-sale, property management or reservation system.

    Monthly data matters more than its absence from the rules suggests. USDA requires a projected operational cash flow analysis on a quarterly basis for borrowers with seasonal or cyclical cash flow (5001.202(b)(6)(v)), and seasonality cannot be modeled from annual totals. Contracts matter because 5001.202(a) requires the lender to review all applicable contracts, management agreements and leases, and the study's revenue and cost assumptions should rest on the same documents.

    SOP 50 10 8.1 changes how acquisition files are underwritten. According to NAGGL and published summaries of the new SOP, changes of ownership now fall under a new Appendix 15. Coverage must be met on historical or adjusted historical earnings rather than projections, at 1.25x for initial acquisitions and owner buyouts and 1.15x for business expansions, and a lender-ordered quality of earnings report is required where the business purchase price is $3 million or more. Published commentary also reports that the quality of earnings work includes a cash proof reconciling cash activity to reported results for the trailing twelve months and the two most recent fiscal years. The SOP 8 versus 8.1 coverage calculator shows how the change plays out on a single file.

    For the consultant, this means the seller's records carry more weight than ever, because the study's view of durability is now read alongside a historical coverage test rather than in place of one. On a USDA file, any going-concern or business value in the appraisal is deducted from the reconciled market value before collateral is discounted, so the study's evidence on the durability of the business supports the collateral analysis as well as the projection.

    Expansions of existing businesses

    An expansion combines both kinds of evidence: the history of the existing business and the plan for the new capacity. The consultant needs the full acquisition-style history for the existing operation plus the start-up-style project documents for the expansion. USDA requires the lender to analyze the scope of the project in relation to the borrower's overall operations (5001.303(b)), and the Agency may require a feasibility study on loans of $1,000,000 or less where the project will significantly affect the operations of an existing business and its historic cash flow (5001.306(a)(3)(ii)). The study should show the existing operation and the expansion separately before combining them, which is only possible if the borrower's records allow the split.

    TransactionDocuments that decide the studyRule basis
    Start-up or constructionPlans, itemized budget and bids, schedule, zoning and permits, utility letters, sources and uses, management resumesUSDA 5001.202(b)(6)(vi), 5001.203(c), 5001.205; SBA 13 CFR 120.882
    AcquisitionThree years of statements and returns, monthly data, purchase agreement, contracts, seller system reportsSBA 13 CFR 120.191; USDA 5001.303(b)(4), 5001.202(a); SOP 50 10 8.1 Appendix 15 as reported
    ExpansionExisting-business history plus project documents, split by operationUSDA 5001.303(b), 5001.306(a)(3)(ii)

    Documents by Asset Class

    Asset-class records are where rule-based and practice-based items diverge most. Some come straight from federal or state regulation. Others are industry practice that no program requires but that every reviewer expects. The sections below mark the difference.

    Franchised projects of any type

    The franchisor's Franchise Disclosure Document is the most useful single document a franchised project can supply, and its contents are fixed by the FTC Franchise Rule at 16 CFR 436.5.

    • Item 7, estimated initial investment. A table of each expenditure, its amount or range, the method of payment and the timing. It is the consultant's benchmark for the construction and pre-opening budget.
    • Item 19, financial performance representations. Optional, and permitted only where there is a reasonable basis for the figures. The franchisor must state whether a representation covers existing outlets or a subset of them, or is a forecast. The consultant should record which subset and how large it is before using any Item 19 figure as a revenue anchor.
    • Item 20, outlet data. Tables of franchised and company-owned outlets for the last three fiscal years, including transfers, terminations, non-renewals and reacquisitions, plus contact details for current and former franchisees. It supports a system-health analysis and gives the consultant a list of operators to call.

    The franchise agreement and the franchisor's approval of the site and operator belong in the package as well, together with confirmation of the brand's status on the SBA Franchise Directory for SBA loans.

    Hotels

    For the demand model and brand review, see the hotel feasibility study, the STR report versus appraisal analysis, and the hotel franchise-fee and PIP case study.

    No program rule requires hotel-specific documents, but no hotel study can be completed without them: the franchise application or approval letter, the brand's design and prototype standards, the property improvement plan for acquisitions and conversions, the management agreement if a third party will operate the hotel, and for operating hotels, monthly operating statements and the property's competitive set performance reports. The study positions the hotel against a competitive set and projects occupancy and rate by segment, and each of those steps depends on the brand, the product and, for existing hotels, the record.

    Gas stations and convenience stores

    See the gas station feasibility study, the environmental UST case study, and why gas station studies get sent back for the review questions these records answer.

    Fuel sites carry the heaviest rule-based list. EPA's underground storage tank regulations at 40 CFR 280.34 require owners and operators to report notification of UST systems, changes of ownership, releases, corrective actions and closure, and to keep documentation of compatibility, repairs, walkthrough inspections, release detection compliance, closure site investigations and operator training. For an acquisition, the consultant should request:

    • The state UST registration for every tank.
    • Release detection records and recent walkthrough inspection logs.
    • Any release or corrective action history.
    • The plan for notifying the state of the change of ownership.

    USDA's checklist lists a Phase I environmental site assessment among items that may be required for real estate collateral under 5001.207, and appraisals must consider contamination using ASTM standards (5001.203(f)). The fuel supply agreement belongs in the package as a material contract.

    Traffic data comes from the state department of transportation. Under the Federal Highway Administration's Traffic Monitoring Guide, the primary goal of most traffic monitoring programs is an accurate annual average daily traffic (AADT) estimate, and short-term counts must be adjusted to remove seasonal bias when annualized. Each state publishes AADT through its own portal; Florida's, for example, updates annually each April with historical counts. The study should cite the count station, the count year and whether the figure is measured or estimated. For an operating station, monthly fuel gallons by grade, inside sales by category and margin data are what let the consultant test the projection against the site's own record.

    Car washes

    The car wash feasibility study, six assumptions SBA lenders challenge, and membership saturation case study put those operating records in context.

    Car wash documents are mostly practice-based: equipment specifications and the tunnel or bay layout, water and sewer capacity and any reclaim system, the wash menu and pricing, and for operating washes, monthly wash counts and membership data, including active members, monthly churn and revenue per member. USDA's technical report requirement for projects using integrated processing equipment and systems (5001.306(a)(3)(iii)) arguably reaches a tunnel system, and a lender may ask for the manufacturer's specifications on that basis. Traffic counts follow the same AADT rules as fuel sites.

    RV parks and campgrounds

    See the RV park feasibility study, SBA versus USDA B&I financing analysis, and transient versus long-term eligibility case study for how site count and length-of-stay records affect the file.

    Campgrounds are licensed by the states, and the licensing rules define what the site plan must show. In Michigan, a campground license is required for five or more campsites, and construction plans must show roads, water and sewer utilities, sites, site numbers and site dimensions, with the water supply meeting public water supply standards and water and wastewater demand stated. Ohio's plan review rule (OAC 3701-26-05) requires a vicinity map and water supply specifications, requires the sewage disposal plan to be approved by Ohio EPA or the local health district before plans are submitted, and sets a minimum individual site area of 1,000 square feet. Indiana requires campgrounds to use a public water supply where one is available within a reasonable distance, and Wisconsin requires plan approval before construction begins. The study should include the state approval status and the approved site plan, because the number and type of sites the projection assumes must match what the state will license.

    For operating parks, reservation and occupancy data by site type and month is the core record. It is also an eligibility document. SBA's eligibility rules for lodging-type businesses turn on the share of revenue from transient guests, so length-of-stay data from the reservation system helps determine whether the park qualifies for SBA financing at all, before it informs the market analysis.

    Self-storage

    The self-storage feasibility study, 2026 storage study, and physical versus economic occupancy case study show why the rent roll and unit mix matter.

    Self-storage documents are practice-based: the proposed unit mix by size and type, the climate-controlled share, and for operating facilities, the rent roll, occupancy by unit type, street rates against in-place rates, concessions and the management platform's monthly reports. The gap between what new customers are quoted and what existing tenants pay is often the most important number in a storage acquisition, and only the rent roll shows it.

    Senior living

    See the senior housing feasibility study, the USDA Community Facilities guide, and the staffing-margin case study for how licensing and staffing records shape the analysis.

    Senior living carries a rule-based list set mostly by the states. Licensure comes from the state agency; North Carolina's adult care home rules sit in G.S. Chapter 131D, for example, and New York requires a certificate of need from the State Department of Health for assisted living programs. According to the National Conference of State Legislatures, 35 states and Washington, D.C. operate certificate of need programs, with wide variation by state, and several others maintain approval processes that function similarly. USDA requires a certificate of need where federal or state law requires one (5001.303(c)(12)) and an Affirmative Fair Housing Marketing Plan for projects with five or more residential units, including assisted living (5001.303(c)(11)). The staffing plan, the payer mix and the licensed capacity complete the package.

    One useful benchmark comes from USDA's Community Facilities program, which caps projected occupancy for assisted living and skilled nursing at 90 percent (5001.304). It does not bind B&I, but a B&I projection above it will need strong support.

    Asset classRule-based documentsPractice-based documentsWhat they decide in the study
    Any franchiseFDD Items 7, 19 and 20 (16 CFR 436.5); franchise agreementFranchisor site and operator approval; Franchise Directory status for SBABudget benchmark, revenue anchor, system health
    HotelNone specificFranchise approval, brand standards, PIP, management agreement, operating historyPositioning, rate, occupancy, capital needs
    Gas stationUST records (40 CFR 280.34); state registration; Phase I where requiredFuel supply agreement; gallons, inside sales and margins by monthEnvironmental risk, volume, margin
    Car washTechnical report where required for integrated equipmentEquipment specifications, utility capacity, pricing, membership and churn dataCapacity, revenue per car, recurring revenue
    RV parkState campground license and plan approvalReservation and length-of-stay data, utility capacityLicensed site count, eligibility, occupancy
    Self-storageNone specificUnit mix, rent roll, street versus in-place ratesRate gap, lease-up, stabilized revenue
    Senior livingState licensure; certificate of need where required; AFHMP for USDAStaffing plan, payer mixCapacity, cost structure, occupancy ceiling

    Recency Rules: When a Document Expires

    A document that was current when it was gathered can expire before the loan is approved. The rules differ by program, and the USDA rules are the ones verified against the current regulation.

    ItemUSDA B&ISBA 7(a) and 504
    Business interim statementsWithin 90 days of complete application120 days, as reported under SOP 50 10 8.1
    Personal and guarantor statementsWithin 90 days90 days, as reported under SOP 50 10 8.1
    Historical statementsLesser of three years or all years; returns not acceptableThree years; returns may serve
    Credit reportsCurrent within 90 daysLender requirement
    AppraisalNot more than one year old; newer on requestLender and SOP requirements
    Tax transcript requestNot applicableIRS must receive Form 4506-C within 120 days of signature
    ProjectionsTwo years at stabilized operationsNot relied on for acquisition coverage under SOP 50 10 8.1, as reported
    Feasibility studyNo fixed ageNo fixed age

    Neither program sets a fixed shelf life for a feasibility study. In practice a study is as current as its data. A study whose market survey is a year old, or whose financial section rests on statements the program would now reject as stale, will be questioned whatever the date on its cover. When a file slips, the cheapest course is usually an update letter from the consultant that refreshes the financial inputs and confirms or revises the market findings, rather than a new study.

    The rules on missing or stale documents are clear on the USDA side. If an application is incomplete, the Agency notifies the lender in writing of the items needed (5001.303(a)). A lender may need to resubmit or modify an application that does not contain sufficient information, and after acceptance a modification is treated as a new application. Where an appraisal is not complete at filing, an estimated value is allowed, but an acceptable appraisal must support it before the guarantee is issued. On the SBA side, earlier SBA guidance required 504 borrowers to provide updated financial statements dated no more than 120 days before the 504 closing, and NAGGL's current advice is that lenders follow the stricter of the forms and the new SOP until the forms are revised.

    Organizing the Package

    How the documents arrive matters almost as much as which documents arrive. A package that is complete but disorganized costs days, and the days come out of the analysis.

    The approach that works is a single shared folder with an index. Each document is named by type and date, so that the June interim balance sheet cannot be confused with the March version. Statements are marked by who prepared them, whether audited, reviewed, compiled or internal, because the consultant and the lender weight them differently. The index lists every item on the request and marks each as provided, to follow with a date, or unavailable, with a short explanation. An honest "unavailable" lets the consultant plan around the gap. A silent omission is discovered late, when it costs the most.

    Two permissions speed the work considerably. The first is authorization for the consultant to speak directly to the franchisor's development team, the contractor, the proposed manager and, for acquisitions, the seller's accountant. The second, for operating businesses, is read access to the point-of-sale, reservation or property management system, or a full export from it. A consultant who can pull monthly data directly does not have to wait for someone to summarize it.

    A complete package also shortens the engagement and narrows the scope of follow-up work, which is reflected in the fee. The feasibility study cost estimator shows how scope and complexity drive the price.

    When a Document Does Not Exist

    Start-ups and first-time operators often cannot supply the history the checklist asks for. That is not disqualifying, but the study has to say what was used instead and why it is a fair substitute.

    The usual substitutes are:

    • The sponsor's other operations, documented with their own statements.
    • Franchisor data from Item 19, with the subset and sample size stated.
    • Operating data from comparable properties gathered by the consultant.
    • Signed letters of intent or contracts with customers, tenants or suppliers.
    • For construction costs, the franchisor's Item 7 ranges cross-checked against contractor pricing.

    Each substitute carries less weight than the document it replaces, and a careful study says so rather than presenting a benchmark as if it were the subject's own record. Reviewers trust a study that names its gaps far more than one that papers over them.

    Frequently Asked Questions

    What documents does a feasibility consultant need from a borrower?

    At minimum: current interim statements, three years of historical statements and tax returns, personal financial statements for the principals, projections with written assumptions, an itemized sources and uses, and either the project's plans and budget or, for an acquisition, the purchase agreement and the seller's operating records. Asset-class records such as franchise documents, UST records, campground licensing or rent rolls are added on top.

    How recent do financial statements need to be for a USDA B&I loan?

    The borrower's and guarantors' balance sheets and year-to-date income statements must be dated within 90 days of the complete application under 7 CFR 5001.303(b)(4)(i). Historical statements cover the lesser of the last three fiscal years or all years of operation, and USDA's checklist states that tax returns are not acceptable in place of statements.

    How recent do financial statements need to be for an SBA loan under SOP 50 10 8.1?

    Published summaries of the new SOP report a 90-day window for personal financial statements and a 120-day window for business interim statements. Until SBA updates its forms, lenders are collecting what both the forms and the SOP require and following the stricter rule.

    Can tax returns replace financial statements?

    For SBA, the regulation allows tax returns in place of historical statements where appropriate. For USDA B&I, prepared statements are required. A package with prepared statements and returns satisfies both.

    What documents are needed for a ground-up construction feasibility study?

    Site and architectural plans, an itemized construction budget with contractor bids, a construction schedule, zoning and permit status, utility availability letters, sources and uses, and evidence of equity. On a USDA loan where the guarantee is requested before completion, the lender also needs a construction schedule and a quarterly cash flow analysis through start-up.

    What does a consultant need for a gas station acquisition?

    The UST registration, release detection and inspection records, any release or corrective action history, a Phase I environmental site assessment where required, the fuel supply agreement, state DOT traffic counts, and monthly fuel gallons, inside sales and margins for at least two years.

    How long is a feasibility study valid?

    Neither SBA nor USDA sets a fixed age. A study is as current as its data, and when a file slips, an update letter that refreshes the financial inputs and confirms the market findings is usually enough.

    What happens if a document is missing?

    USDA notifies the lender in writing of the missing items, and a modification after acceptance is treated as a new application. On SBA files the lender reopens its credit analysis. In the study itself, the consultant should name any gap, state the substitute used, and explain why it is fair.

    Sources

    1. 13 CFR 120.191, The Contents of a Business Loan Application, Electronic Code of Federal Regulations
    2. 13 CFR 120.882, Eligible Project Costs for 504 Loans, Electronic Code of Federal Regulations
    3. U.S. Small Business Administration, SOP 50 10, Lender and Development Company Loan Programs, Version 8.1 with Technical Updates, effective October 1, 2026
    4. U.S. Small Business Administration, Information Notice 5000-880695, Issuance of SOP 50 10 8.1, August 14, 2026
    5. U.S. Small Business Administration, Information Notice 5000-882227, Issuance of Technical Updates to SOP 50 10 8.1, September 25, 2026
    6. U.S. Small Business Administration, Notice 5000-19002, Questions and Answers for Lenders During the Lapse in Appropriations, 2019
    7. U.S. Small Business Administration, Form 1244, Application for Section 504 Loans
    8. U.S. Small Business Administration, Form 413, Personal Financial Statement
    9. Internal Revenue Service, Form 4506-C, IVES Request for Transcript of Tax Return, revised October 2022
    10. National Association of Government Guaranteed Lenders, SOP Update: SBA Publishes SOP 50 10 8.1 with Technical Policy Updates, September 2026
    11. Doeren Mayhew, SOP 50 10 8.1: What SBA Lenders Should Be Thinking About Before Oct. 1, 2026
    12. Doeren Mayhew, SBA Quality of Earnings Reports: What Lenders Need to Know About SOP 50 10 8.1, 2026
    13. StatementsReady, New SBA Rules Oct. 1, 2026: SOP 50 10 8.1 Explained, September 2026
    14. Starfield & Smith, Best Practices: A Review of Equity Injection Requirements Under SOP 50 10 8, May 2025
    15. 7 CFR Part 5001, Guaranteed Loans, sections 5001.105, 5001.202, 5001.203, 5001.205, 5001.207, 5001.303, 5001.304 and 5001.306, Electronic Code of Federal Regulations, current as of September 2026
    16. USDA Rural Development, Business and Industry Guaranteed Loan Program, Lender Complete Application Checklist
    17. USDA Rural Development, OneRD Guarantee program page
    18. 16 CFR 436.5, Disclosure Items, Franchise Rule, Electronic Code of Federal Regulations
    19. Federal Trade Commission, Amended Franchise Rule Frequently Asked Questions
    20. 40 CFR 280.34, Reporting and Recordkeeping, Electronic Code of Federal Regulations
    21. Federal Highway Administration, Traffic Monitoring Guide, 2022
    22. Florida Department of Transportation, Florida Traffic Online and Traffic Monitoring Handbook, July 2023
    23. Michigan Department of Environment, Great Lakes, and Energy, Starting a Campground in Michigan and New Campground Guidance, October 2025
    24. Ohio Administrative Code 3701-26-05, Campground Plan Review
    25. Indiana Department of Health, 410 IAC 6-7.1, Campgrounds
    26. Wisconsin Administrative Code, ATCP 79, Campgrounds
    27. National Conference of State Legislatures, Certificate of Need State Laws
    28. North Carolina Department of Health and Human Services, Adult Care Licensure Section, Rules and Statutes
    29. New York City Business, Adult Care Facility: Assisted Living Program