Independent SBA feasibility studies for 7(a) and 504 credits, built on the SBA's own loan data
SBA Feasibility Study
Lender-grade, independent feasibility studies for SBA 7(a) and 504 loans, prepared to SOP 50 10 8 and reviewed against SOP 50 10 8.1, effective for loan numbers issued on or after October 1, 2026.
An SBA feasibility study is the document an SBA lender or Certified Development Company relies on when repayment rests on projections rather than on operating history. Before we write a word about your project, we position it inside the Small Business Administration's own loan-level records: every 504 approval since 2010, its debenture, its first mortgage, its industry, and how it performed. Your lender sees where your deal sits in the real distribution, not an analyst's impression of it. The study is scoped to the SOP in force on the date your file receives its loan number, independent, fixed fee, and never contingent on the finding.
What an SBA feasibility study consultant does
This page covers the SBA programs specifically; the role in general is set out on our feasibility study consultant overview. An SBA (Small Business Administration) feasibility study consultant is an independent analyst engaged to test whether a project seeking SBA 7(a) or 504 financing can repay its debt before the lender or Certified Development Company commits. The consultant quantifies market demand, reviews the site, costs and management, builds auditable projections, and stresses debt coverage beyond the base case, producing a study the underwriter can cite under SOP 50 10 8. It is not an appraisal, carries no opinion of value, and does not decide eligibility. The best versions are built on evidence a reviewer can check, which is why ours begin with the SBA's own published loan-level data rather than with the sponsor's assumptions.
What an SBA feasibility study is
An SBA feasibility study is an independent, forward-looking analysis of whether a specific project can generate the cash flow required to service SBA-guaranteed debt at the coverage threshold the lender applies. It is commissioned when the credit decision cannot be made on history: a startup, a ground-up build, a major expansion, or a change of ownership where the buyer projects performance above the seller's record. It quantifies demand from primary data, inventories competing supply, reviews the site, cost and management, builds an auditable projection model, and stresses coverage beyond the base case. The output is written for the underwriter, the CDC and the SBA reviewer, and it is cited in the credit memorandum as the independent support SOP 50 10 8 expects a prudent lender to hold.
It is not an appraisal and contains no opinion of value. It is not a business valuation. It is not a Quality of Earnings report, which under SOP 50 10 8.1 is a separate, lender-ordered exhibit on larger acquisitions. It does not determine eligibility. It informs a credit decision rather than making one, and it says so on page one.
What the Small Business Administration's own data shows
Most consultants describe the SBA loan market from experience. We compute it. The SBA publishes, under the Freedom of Information Act, a loan-level record of every 7(a) and 504 approval: borrower industry, project state, debenture and third-party first mortgage amounts, term, business age, franchise affiliation, and current loan status. It is public domain, it is refreshed quarterly, and almost nobody in the feasibility industry actually reads it. We maintain the full file and recompute our benchmarks on every release.
Headlines from the current release, FY2010 through the March 31, 2026 data date, 504 program:
About 116,000 approvals since FY2010, of which roughly 94,000 funded, representing $72.7 billion in CDC debentures and, by lender report, about 959,000 jobs supported. In FY2025 alone the SBA approved about 6,800 504 loans totaling $7.8 billion in debentures.
The median funded 504 debenture, FY2021 to FY2025, is $609,000, with the middle half of loans between $328,000 and $1.16 million. The median accompanying third-party first mortgage is about $753,000.
The median combined bank-plus-debenture financing is $1.37 million, and one loan in ten finances $4.76 million or more before the borrower's equity is counted.
87 percent of recent 504 loans carry the 25-year debenture term. These are long commitments against long-lived real estate, which is exactly why the underwriting leans on projections.
The debenture's statutory cap is visible in the file: the largest debentures sit at $5.5 million, the ceiling for small manufacturers and energy projects, and about one loan in a hundred prices at the $5 million standard cap.
Since FY2018, roughly one 504 borrower in eight has been a startup whose loan proceeds open the business. In the asset classes below, that share runs far higher, and startups are precisely the files where the SOP expects independent support for the projections.
California, Florida, Illinois, Texas and Utah lead recent volume by project count.
Project scale by asset class, from the loan file
When a lender asks whether your project is scaled normally for its class, this is the table that answers, computed from funded 504 loans approved FY2021 through FY2025. Combined financing is the third-party first mortgage plus the CDC debenture; equity is additional.
- Funded FY21-25
- 1,080
- Median debenture
- $1,890,000
- Median combined
- $4,690,000
- Funded FY21-25
- 361
- Median debenture
- $1,048,000
- Median combined
- $2,600,000
- Funded FY21-25
- 346
- Median debenture
- $929,000
- Median combined
- $2,340,000
- Funded FY21-25
- 83
- Median debenture
- $1,106,000
- Median combined
- $2,680,000
- Funded FY21-25
- 42
- Median debenture
- $844,000
- Median combined
- $1,960,000
- Funded FY21-25
- 30
- Median debenture
- $757,000
- Median combined
- $1,830,000
- Funded FY21-25
- 207
- Median debenture
- $769,000
- Median combined
- $1,820,000
- Funded FY21-25
- 352
- Median debenture
- $763,000
- Median combined
- $1,720,000
- Funded FY21-25
- 365
- Median debenture
- $709,000
- Median combined
- $1,640,000
- Funded FY21-25
- 792
- Median debenture
- $711,000
- Median combined
- $1,590,000
- Funded FY21-25
- 127
- Median debenture
- $612,000
- Median combined
- $1,560,000
- Funded FY21-25
- 155
- Median debenture
- $676,000
- Median combined
- $1,500,000
- Funded FY21-25
- 677
- Median debenture
- $628,000
- Median combined
- $1,450,000
- Funded FY21-25
- 1,398
- Median debenture
- $616,000
- Median combined
- $1,370,000
- Funded FY21-25
- 47
- Median debenture
- $543,000
- Median combined
- $1,300,000
- Funded FY21-25
- 74
- Median debenture
- $550,000
- Median combined
- $1,180,000
Three things the table tells a borrower before a single projection is written. Hotels are the program's largest real estate class by dollars, with $2.3 billion in debentures over the last five complete fiscal years and a top decile of deals financing $11.5 million or more. Fifty-six percent of recent 504 hotel borrowers carry a franchise flag, so brand economics belong in the study. And medians are medians: a proposal financing at three times its class median is not disqualified, but its study has to explain the distance, and a study that does not know the distance exists cannot.
What actually goes wrong, by the numbers
The reason lenders commission feasibility studies is visible in the performance data. Take the seasoned cohort, 504 loans approved FY2010 through FY2016, and measure what has happened to date:
- 1.85 percent of funded loans program-wide have been charged off. Add purchases and liquidation payoffs and about 3.6 percent went through distress.
- When a 504 debenture is charged off, the median loss is 82 percent of the debenture balance. These credits do not fail politely. Real estate recovery flows first to the third-party first mortgage; the debenture behind it takes the loss nearly whole.
Failure is concentrated exactly where feasibility scrutiny is concentrated. Charged-off share of the seasoned cohort by class:
The startup concentration compounds it. Since FY2018, startups are 50 percent of 504 car wash borrowers, 51 percent of self storage borrowers, 54 percent of RV park borrowers, and 35 percent of hotel borrowers, against 11 percent program-wide. Special purpose real estate, no operating history, 25-year money: that is the exact intersection where SOP 50 10 8 expects the lender to hold independent support for the projections, and it is most of what we do.
A borrower can read this table two ways. As a warning, which it is. Or as the outline of the credit conversation before it happens: your lender knows these base rates, priced or declined against them for years, and a study that engages them directly, showing why this project sits on the survivor side of its class distribution, is worth more than one that pretends the distribution does not exist.
Why lenders and CDCs ask for a study
SOP 50 10 8 does not carry a checklist line saying "order a feasibility study." It requires the participating lender to underwrite prudently, as it would without the guaranty, and to document how it satisfied itself on repayment. Where repayment rests on projections rather than history, the projections need independent support, and the feasibility study is how that support enters the file. In practice the request arrives when:
- the borrower is a startup or under two years old, which the data above shows is the norm rather than the exception in car wash, storage, RV park and hotel deals;
- the project is ground-up construction or a major expansion, so history does not carry forward;
- a change of ownership projects performance above the seller's record, and the increment is the whole credit question;
- the property is special purpose, with few alternative users if the operation fails;
- the operation is management-dependent or the operator is new to the field.
The cheapest moment to commission the study is while the application is being assembled. After underwriting raises the question, a number has usually been circulated already, and the honest study must confirm it or contradict it in front of the lender. Your lender or CDC is the authority on whether your file needs one, and we will speak with them before you engage us, free.
The SBA feasibility study under SOP 50 10 8 and SOP 50 10 8.1
SOP 50 10 8 has governed 7(a) and 504 origination since June 1, 2025. On August 14, 2026, under Information Notice 5000-880695, the SBA issued SOP 50 10 8.1, which applies to any application that receives an SBA loan number on or after October 1, 2026. Applications that receive a loan number through September 30, 2026 remain under SOP 50 10 8. The trigger is the loan number, not the application date, the letter of intent or the date the package was submitted, which means a file sitting in a lender's queue in late September can be underwritten under either version. We ask which side of that line your file sits on before we scope the study, and we write to that version. Test a deal under both versions with our SBA DSCR calculator.
What carries forward. The core of the feasibility requirement is unchanged. SOP 50 10 8.1 still requires the SBA lender to underwrite prudently, as it would without the guaranty, and to document how it satisfied itself on repayment. The 10 percent minimum equity injection for startups, the special purpose property structure for 504 loans, the Franchise Directory and the 7(a) Small Loan ceiling carry forward. For a startup, a ground-up construction project or a major expansion, the feasibility study remains the independent support the file needs where repayment rests on projections.
What changes, and why it matters to the study. The substantive changes in SOP 50 10 8.1 sit in change-of-ownership lending, now governed by its own Appendix 15 for 7(a) loans. Three of them bear directly on how a feasibility study is scoped:
First, coverage on Initial Acquisitions, Owner Buyouts and ESOP transactions is tested at 1.25x on the business's last fiscal year or an average of the last two years, on a historical or adjusted basis, and post-closing projections may not be used to meet that test. Business Expansions remain at 1.15x. In practice, a feasibility study can no longer cure a historical coverage shortfall on a straight acquisition. Its role there narrows to what the lender's own credit policy requires, to real estate being added or rebuilt as part of the transaction, and to the expansion increment where an acquisition is paired with a Business Expansion.
Second, a Quality of Earnings report is required on Initial Acquisitions and Business Expansions where the business purchase price is $3 million or more, excluding owner-occupied real estate. The QoE must be ordered by and prepared for the lender. It is a backward-looking verification of earnings, and it is not a substitute for a feasibility study, which is forward-looking. On a larger acquisition with an expansion component, the file will now commonly hold both, and the study reconciles its base year to the QoE's adjusted earnings rather than to the seller's own statements.
Third, 7(a) Small underwriting is no longer available for a change of ownership at any size, so every acquisition runs through full Standard 7(a) underwriting, and equity from non-controlling minority investors, combined with seller standby debt, may fund no more than half of the required injection. Both changes tighten the sources-and-uses page that opens every study.
The SOP 50 10 8.1 update also adds flexibility for same-institution debt refinancing and folds in the policy and procedural notices issued since SOP 50 10 8, including the 7(a) and 504 coordination rule for maximum loan limits, citizenship and residency requirements, and the sunset of the SBSS score for 7(a) Small Loans. Where any of these touch the file, the study cites the governing provision by section so the reviewer does not have to look for it.
The practical consequence. For the asset classes that dominate SBA real estate lending, and for the projects in those classes that are startups or ground-up builds, SOP 50 10 8.1 changes almost nothing about what the study must prove and raises the importance of proving it well. For acquisitions of existing operations, it moves the credit test onto history and reserves the feasibility study for the parts of the deal that history cannot answer.
The 504 structure, as the data shows it
The textbook 504 is fifty-forty-ten: a third-party lender takes a first mortgage at about half of project cost, the CDC debenture funds about forty percent, and the borrower injects the rest. The loan file confirms the textbook: across funded FY2021-2025 loans, the median third-party first mortgage is 55 percent of the combined financing, with the debenture at 45, and equity on top. The injection rises for startups and for special purpose property, which the next section prices out.
For 7(a), the FOIA file is thinner on real estate specifics, since the program spans working capital, acquisition and construction in one dataset without a use-of-proceeds field. What the study has to prove there is different in kind: operating projections, management capability, and global cash flow sweeping the guarantors' full obligations, tested at the threshold in your lender's credit policy. We prepare both, and the certification names the program and the intended users.
Special purpose property, priced out
A special purpose property has few alternative users if the current operation fails. Hotels, car washes, gas stations, self storage, senior care, marinas, bowling, wineries: the left half of the tables above. The designation does three concrete things to a 504 file.
It raises the equity injection. The standard borrower contribution is 10 percent of project cost, rising to 15 percent for a startup or for special purpose property, and to 20 percent when both apply. On the median recent hotel deal in the scale table, moving from 10 to 20 percent is roughly an additional half million dollars of cash at closing, decided by a classification many borrowers first hear about in underwriting.
It changes the appraisal. Going-concern assets get value allocated among real estate, equipment and intangibles rather than blended, because no one lends against a blend.
It moves the credit weight onto the market evidence. A generic flex building has an alternative-use fallback; a five-bay tunnel's fallback is another tunnel operator. Combine that with the startup shares above and you have the reason this category draws the SBA's heaviest feasibility scrutiny, and why it is our core territory rather than our exception.
SBA feasibility studies by asset class
The five classes below, together with hotels, account for most of the special purpose real estate the SBA guarantees and most of the feasibility studies we prepare. Each paragraph states what the SBA's own loan data shows for the class, what the SOP treatment does to the file, and what the study has to prove.
SBA feasibility study for an RV park or campground
The SBA's loan file records 127 funded 504 RV park and campground loans approved FY2021 through FY2025, with a median debenture of $612,000 and median combined financing of $1.56 million. Since FY2018, 54 percent of 504 RV park borrowers have been startups, against 11 percent program-wide, and in the seasoned FY2010 through FY2016 cohort 4.2 percent of RV park loans have been charged off, the second-highest rate of any class we track. That combination, a new operator, a special purpose site and 25-year money, is the profile SOP 50 10 8 and SOP 50 10 8.1 both expect to arrive with independent support for the projections.
An RV park feasibility study is built on the demand drivers that actually fill sites: drive-time access from the metropolitan markets that supply weekend and seasonal guests, proximity to a destination anchor (a lake, a national or state park, an event venue, a highway corridor), state and regional RV registration data, and the seasonality curve of the specific location, since a park that is full 14 weeks a year and empty for 30 has a different coverage profile from one with year-round extended-stay demand. The competitive inventory is physically measured: site counts by type (full hook-up pull-through, back-in, tent, cabin), published nightly and monthly rates, amenity sets and observed occupancy through the season. The revenue model separates transient, seasonal and extended-stay segments because they carry different rates, different occupancy and different cost. Ancillary revenue (store, propane, laundry, rentals) is modeled from comparable operations rather than assumed. Cost validation weighs the site-work-heavy budget, where utilities, roads and pads dominate and overruns are common. The study also states plainly whether the project fits better under SBA 504, SBA 7(a) or USDA Business and Industry, since rural parks are frequently eligible for more than one program and the choice changes the equity and coverage tests.
SBA feasibility study for a gas station or convenience store
Gas stations and convenience stores are one of the largest special purpose classes in the SBA's file: 346 funded 504 loans FY2021 through FY2025, a median debenture of $929,000 and median combined financing of $2.34 million. In the seasoned cohort, 3.3 percent have been charged off. The class is unusual in that a large share of SBA fuel-site transactions are changes of ownership rather than new builds, which makes SOP 50 10 8.1 matter more here than in almost any other class. A straight acquisition of an operating station is now tested at 1.25x on the last fiscal year or a two-year average, on historical or adjusted earnings, and projections cannot cure a shortfall. The feasibility study's territory is the ground-up station, the raze-and-rebuild, the branded conversion, the added car wash or quick-service restaurant, and the acquisition paired with an expansion that has to be supported at 1.15x on projections.
A gas station feasibility study starts with fuel volume, and fuel volume starts with traffic. The study uses state DOT counts on the fronting road and the intersecting road, the site's position relative to the dominant commute direction, ingress and egress geometry, and the fuel price posture of every competing site within the relevant drive radius. Gallons are built from a capture rate on that traffic that is defended against comparable stations, not assumed. Fuel margin is modeled from regional rack-to-retail history, which is volatile, and the sensitivity section tests the loan against margin compression specifically. Inside sales are the second engine and often the more important one for coverage: the study builds inside sales from square footage, merchandise mix, foodservice program and comparable per-store sales, and it separates tobacco, lottery, beer and foodservice because their margins differ by an order of magnitude. Environmental review carries unusual weight: Phase I findings, underground storage tank age, registration and compliance history, and any open state remediation case are stated in the site section, because they affect both feasibility and the appraisal's allocation. Fuel supply and brand agreements, their term, their volume commitments and their image requirements, are listed as conditions precedent. The base-rate section engages the class's charge-off record directly and states why this site, this operator and this margin structure sit outside it.
SBA feasibility study for a car wash
Car washes are the second-largest class in the scale table by median financing: 361 funded 504 loans FY2021 through FY2025, a median debenture of $1,048,000 and median combined financing of $2.6 million. Half of 504 car wash borrowers since FY2018 have been startups. The class has drawn heavy SBA volume through the express-exterior tunnel model, and it has drawn equally heavy lender scrutiny, because tunnel economics are membership-driven, capital-intensive and sensitive to local saturation in a way that a lender who has not watched the class closely can underestimate.
A car wash feasibility study is built on capture rate. The study establishes traffic on the fronting road from state DOT counts, adjusts for site access and visibility, and applies a capture rate defended against the operator's comparable sites or published industry ranges for the format, express exterior, flex-serve or full-serve. Population and households within the drive-time trade area are tested against the number of existing and pipeline tunnels, because the single most common reason a car wash file fails is a trade area that already has more tunnel capacity than its households can support. The revenue model separates retail single washes from membership revenue, models membership penetration and churn explicitly, and tests the ramp month by month because tunnel volumes typically take 18 to 36 months to stabilize. Cost validation pays particular attention to the equipment package, which is a large share of project cost and depreciates faster than the real estate, and to the replacement reserve that follows from it; coverage is shown before and after that reserve. Water reclaim, utility cost, chemical cost and labor model are built from the specific equipment specification. Because so much of a tunnel's project cost is equipment and site work with limited alternative use, the study addresses special purpose treatment directly: the equity injection the SOP requires for a startup on a special purpose property, and the allocated appraisal the lender will order. Where the project is an acquisition of an operating wash rather than a new build, the study explains how SOP 50 10 8.1's historical coverage test applies and confines its own projections to any expansion component. The six assumptions SBA lenders challenge first are answered explicitly.
SBA feasibility study for RV and boat storage
RV and boat storage does not carry its own line in the SBA's loan file; it is recorded under the same NAICS code as self storage, and it shares that class's financing profile and its loss record. What it does not share is the demand method. A self storage facility draws from households within a short drive; an RV and boat storage facility draws from the population of registered recreational vehicles and boats within a longer radius, filtered by the share of that population that cannot store at home because of homeowners association restrictions, municipal ordinances or lot size. The study builds demand from state RV and vessel registration data at the county level, from the housing stock and HOA prevalence in the trade area, from proximity to the lakes, coasts and highway corridors where the vehicles are used, and from the observed occupancy and waiting lists at existing facilities.
The competitive inventory distinguishes uncovered, covered and fully enclosed spaces, because rates and construction cost differ by multiples across the three and a project's product mix is a decision the study has to test rather than accept. Revenue is modeled by space type and length, with lease-up shown month by month; storage of this kind leases slower than climate-controlled self storage in a dense market and faster where supply is thin, and the study states which condition applies. Cost validation weighs the land-heavy budget, since land, grading, paving and fencing dominate and the improvements have limited alternative use, which is why lenders treat the property as special purpose for equity and appraisal purposes. Operating expenses are low and labor-light, which flatters coverage in a base case and makes the sensitivity section, which tests lease-up delay and rate softness, the part of the study the lender reads most carefully. Where the project sits on the edge of a metropolitan area, the study also addresses USDA eligibility, because RV and boat storage in rural counties is frequently financed under USDA B&I rather than SBA 504.
SBA feasibility study for self storage
Self storage presents the SBA's most instructive contradiction. In the seasoned FY2010 through FY2016 cohort, only 0.3 percent of 504 self storage loans have been charged off, the lowest rate in the classes we track. Yet since FY2018, 51 percent of 504 self storage borrowers have been startups, nearly five times the program-wide share, and the class recorded 352 funded 504 loans FY2021 through FY2025 at a median debenture of $763,000 and median combined financing of $1.72 million. The record is good because the asset is forgiving once leased; the underwriting risk sits almost entirely in the lease-up period, and that is where the feasibility study earns its fee.
A self storage feasibility study is built on square feet per capita. The study defines a trade area by drive time, typically shorter in dense markets and longer in rural ones, counts every existing and pipeline facility in it with its net rentable square footage, climate-controlled share, unit mix, street rate and observed occupancy, and computes existing and post-construction supply per capita against the household base. That number, compared with the equilibrium range for markets of similar density and against the observed occupancy at existing competitors, is the core of the demand finding, and it is why a consultant's comp set differs from a broker's feasibility report. Household growth, renter share, housing turnover and the presence of nearby multifamily construction are tested as demand drivers. The revenue model builds rate by unit type from the competitive survey, applies concessions and discounting explicitly, and shows physical and economic occupancy separately, with lease-up modeled month by month over the 24 to 36 months a new facility typically takes to stabilize. Coverage during lease-up is the credit question: the study shows the months in which cash flow does not cover debt service, sizes the interest reserve or working capital required to carry them, and tests how a six-month lease-up delay or a 10 percent rate shortfall moves the stabilization date. Cost validation reviews the building type (single-story drive-up, multi-story climate-controlled, conversion) against regional benchmarks, and the study addresses special purpose treatment where the lender applies it. The base-rate section is short here, because the class record is strong, and it says so.
Special purpose property under SOP 50 10 8 and SOP 50 10 8.1
The SOP defines a special purpose property as one with a unique physical design, special construction materials or a layout that restricts its utility to the use for which it was built, and it lists the classes above among the examples. The designation is unchanged in SOP 50 10 8.1, and it does three things to a 504 file. It raises the borrower's minimum equity injection from 10 percent to 15 percent, and to 20 percent where the borrower is also a startup, which on a median recent hotel deal is roughly $500,000 of additional cash at closing. It changes the appraisal, because a going-concern property is valued with the real estate, equipment and intangibles allocated rather than blended. And it moves the credit weight onto the market evidence, because a generic building has an alternative-use fallback and a tunnel, a fuel site or a storage yard does not. The feasibility study is where that market evidence enters the file. Every study we prepare on a special purpose property states the classification, the injection it requires, the appraisal treatment the lender should expect, and the market evidence that substitutes for the alternative-use fallback the property does not have.
How the data enters your study
The loan file is the frame, not the study. Around it, every engagement builds the evidence the reviewer actually has to weigh:
- Positioning.
- Your project's financing, cost and scale placed against its class distribution from the scale table, so "reasonably scaled" is a computed statement with a percentile attached, not an adjective.
- Base rates engaged.
- The class performance record acknowledged and answered: what, specifically, places this project outside its class's failure pattern. Site, operator, structure, contracts, brand.
- Demand from primary data.
- Trade area defined and defended; demand built on the accepted method for the asset class, from traffic counts, demographics, workforce flows and a physically measured competitive inventory, with the arithmetic shown; franchise projections tested against the system's own Item 19 disclosures.
- A model built for audit.
- Ten years, monthly through the ramp, no hardcoded value in any calculation cell, every input sourced, coverage tested at the threshold your institution applies, operating and global, before and after replacement reserves, under sensitivity, rate stress and simulation.
- Conditions named.
- Whatever the deal still needs, an executed franchise agreement, a permit, a named manager, a curb cut, is listed with its curing document, which becomes the closing checklist.
The components of an SBA feasibility study
A study that survives credit committee, SBA review and, if it comes to it, a guaranty purchase file, is built from a fixed set of components. Each of the following appears in every SBA feasibility study we deliver, in this order, with the arithmetic visible.
- 1.Executive conclusion. The finding on page one: feasible, feasible subject to named conditions, or not feasible as proposed. The projected operating and global debt service coverage ratios for each year of the loan, stated against the lender's threshold, and the three or four facts on which the conclusion turns. An underwriter should be able to read the first page and know what the rest of the report will have to prove.
- 2.Project description, sources and uses. The project as it will actually be financed: site, program, square footage or unit count, total project cost by line item, the third-party first mortgage, the CDC debenture or 7(a) note, and the borrower's equity injection reconciled to the SOP's minimum for the borrower type and property type. Any gap between the sponsor's budget and third-party cost evidence is stated here, not buried.
- 3.SBA program positioning. Where the project sits in the SBA's own loan file: financing size, debenture size and structure placed against the class distribution, with a percentile attached. The section also identifies the SOP provisions that govern the file, including whether the loan number will fall under SOP 50 10 8 or SOP 50 10 8.1, and whether the property is special purpose, since that changes the equity injection and the appraisal treatment.
- 4.Trade area definition. The geography from which the project will draw its customers, defined by drive time, traffic pattern, physical barriers and observed competitor draw, and defended in writing. A trade area drawn to flatter the project is the most common defect in a rejected study, and the first thing an experienced reviewer tests.
- 5.Demand analysis. Demand built on the accepted method for the asset class, from primary data: state DOT traffic counts, Census and BLS demographics and workforce flows, tourism and visitation records, vehicle and RV registrations, franchise Item 19 disclosures, and our own national parcel and imagery corpus. The demand estimate is shown as arithmetic, not asserted as a conclusion.
- 6.Competitive supply inventory. Every competing facility in the trade area, physically or remotely inspected, with capacity, rate, occupancy where observable, condition and pipeline. Supply is measured, not described. Proposed and permitted competitors are included, because a lender lending for 25 years is lending into the pipeline, not only into today's inventory.
- 7.Site and technical review. Access, visibility, zoning and entitlement status, utilities, environmental status (Phase I findings, underground storage tank history where fuel is involved), flood zone, and any physical constraint that changes capacity or cost. Plans and contractor estimates are reviewed against regional cost benchmarks.
- 8.Cost validation. Hard cost, soft cost, equipment, working capital, contingency and interest reserve, tested against third-party benchmarks and comparable projects. Under-budgeted contingency is a repayment risk, not a construction detail, and it is treated as one.
- 9.Management and operator assessment. The experience of the sponsor and the named operating team against the demands of the asset class, with particular weight where the operator is new to the field, which the SBA's data shows is the norm in the classes below.
- 10.Financial projections. A ten-year model, monthly through the ramp-up period, with no hard-coded value in any calculation cell and every input sourced to the demand, supply, cost and management sections. Revenue build, operating expenses, replacement reserves, debt service by tranche, and cash flow available for debt service.
- 11.Debt service coverage testing. Operating coverage and global coverage, year by year, before and after replacement reserves, tested at the threshold your lender, CDC and program actually apply rather than at a universal advertised number.
- 12.Sensitivity, stress and simulation. Single-variable sensitivities on rate, occupancy, volume, margin and cost overrun; a combined downside case; an interest-rate stress on the third-party first mortgage; and a Monte Carlo simulation reporting the probability that coverage falls below threshold in any year of the loan. A break-even analysis states how far the key driver can fall before coverage is lost.
- 13.Base rate engagement. The class performance record from the SBA's data, acknowledged and answered: what, specifically, places this project on the survivor side of its class distribution.
- 14.Conditions precedent. Every open item the conclusion depends on, listed with its curing document: an executed franchise agreement, a permit, a fuel supply agreement, a named manager, a curb cut. This list becomes the lender's closing checklist.
- 15.Certification, reliance and sources appendix. The intended users named, the limits of the work stated, a plain statement that the study is not an appraisal and contains no opinion of value, and a sources appendix that lets any reviewer reproduce any number.
A note on coverage ratios
Some firms advertise that every study proves 1.15x operating and 1.00x global coverage. As a buyer, read the second number again: a global test passing at 1.00x passes when the borrower and guarantors have exactly zero margin across everything they owe, and no committee reads that as a pass.
Universal advertised ratios mean the consultant chose the threshold that flatters the study. Thresholds belong to your lender's credit policy, your CDC and the program; they vary; and they are commonly stricter than any floor. We ask for the term sheet first and test at the number your file will actually be measured against, shown year by year, both coverage definitions, before and after reserves.
What you receive
A complete analytical report: conclusion on page one, market and demand analysis with the arithmetic visible, the data positioning described above, competitive supply physically inventoried, site and technical review, management assessment, full projections and stress battery, itemized conditions precedent, sources appendix, and a certification stating plainly that the study is not an appraisal and contains no opinion of value. Plus the fully linked model itself, and reviewer support through closing included in the fee: when your underwriter has a question in month three, we answer it. Standard delivery runs in business days from complete data; rush for files already in underwriting at a fixed add-on quoted up front.
The engagement
- One.Send the project, program, lender and deadline. Fixed written fee within one business day, free, with the lender call if you want it.
- Two.A document request tailored to the deal goes out day one: term sheet, budget and sources and uses, site plan, plans or contractor estimate, resumes, historicals where they exist, franchise or operating agreements, purchase agreement on a change of ownership.
- Three.Market, data positioning and technical analysis.
- Four.Model, stress, reconciliation, and a check against the program's requirements before anything leaves the building.
- Five.Delivery and reviewer support through closing.
Independence, and what this document is not
The fee is fixed before work begins, never a percentage of the project, never contingent on the finding, and a conclusion is never revised under pressure. The study names its intended users and is written for them even when the borrower pays. It is not an appraisal, contains no opinion of value, is not prepared under USPAP, and cannot satisfy an appraisal requirement. It is not a business valuation. It does not determine SBA eligibility, which rests with the lender and the Agency. It informs a credit decision rather than making one. All of this appears on page one of every study we sign.
Who prepares your study
FSC Consulting, Inc. is run by Sarrah Allen, MAI. Feasibility Study Consultant is a commercial real estate consulting practice specializing in independent, lender-facing feasibility studies for SBA and USDA guaranteed credits and conventionally financed projects. The team that writes our studies is the team that maintains our data infrastructure, including the full SBA loan-level file behind every number on this page, a national parcel corpus, aerial imagery, traffic counts and CMBS property-level performance data. That is why our benchmarks are computed rather than described.
Frequently asked questions
What does an SBA feasibility study consultant do?
Independently tests whether a project seeking Small Business Administration financing can repay its debt: quantifies demand, reviews site, costs and management, builds an auditable model, and stresses coverage at the lender's threshold. The deliverable is written for the underwriter under SOP 50 10 8, not for the sponsor.
What is an SBA feasibility study?
An independent, forward-looking analysis of whether a project seeking SBA 7(a) or 504 financing can service its debt at the lender's coverage threshold. It quantifies demand from primary data, inventories competing supply, reviews site, cost and management, builds an auditable ten-year model and stresses coverage. It is written for the lender, the CDC and the SBA reviewer under SOP 50 10 8, and from October 1, 2026, under SOP 50 10 8.1 for files that receive a loan number on or after that date.
What does an SBA feasibility study include?
An executive conclusion, project description with sources and uses, SBA program positioning, trade area definition, demand analysis, competitive supply inventory, site and technical review, cost validation, management assessment, ten-year projections monthly through ramp-up, operating and global coverage testing, sensitivity and simulation, engagement of the class base rates from the SBA's data, conditions precedent, and a certification with a sources appendix.
What changed for feasibility studies under SOP 50 10 8.1?
For startups, ground-up construction and major expansions, the requirement is unchanged: independent support for the projections. For 7(a) changes of ownership, Appendix 15 now tests Initial Acquisitions, Owner Buyouts and ESOP transactions at 1.25x on historical or adjusted earnings and does not allow projections to meet that test, requires a lender-ordered Quality of Earnings report where the business purchase price is $3 million or more, and removes 7(a) Small underwriting for acquisitions. The study's role on a straight acquisition narrows to what the lender's policy requires and to any real estate or expansion component; Business Expansions remain at 1.15x with projections.
Does SOP 50 10 8.1 apply to my loan?
It applies to applications that receive an SBA loan number on or after October 1, 2026. Applications that receive a loan number through September 30, 2026 remain under SOP 50 10 8. The loan number, not the application date, controls. Ask your lender in writing which version governs your file, and tell us, because the study is written to that version.
Is a Quality of Earnings report the same as a feasibility study?
No. A QoE verifies historical earnings on an acquisition and, under SOP 50 10 8.1, must be ordered by and prepared for the lender on business purchases of $3 million or more. A feasibility study tests forward-looking operations. A larger acquisition with an expansion component will commonly need both, and the study reconciles its base year to the QoE's adjusted earnings.
Which asset classes most often need an SBA feasibility study?
The special purpose classes where the SBA's data shows the highest startup shares: car washes (50 percent startups since FY2018), self storage (51 percent), RV parks (54 percent), hotels (35 percent), and gas stations, where changes of ownership are common and ground-up builds and rebuilds still require projection support. RV and boat storage follows the self storage profile with a different demand method.
How big is a typical SBA 504 loan?
From the SBA's own loan-level data, FY2021 through FY2025: the median funded debenture is $609,000, the median third-party first mortgage about $753,000, and the median combined financing $1.37 million before equity. Medians differ sharply by asset class; recent hotel deals run a median $4.7 million combined.
What share of SBA 504 loans fail?
Of 504 loans approved FY2010 through FY2016, about 1.9 percent have been charged off to date and roughly 3.6 percent have been through charge-off, purchase or liquidation, with the median charge-off losing 82 percent of the debenture balance. Rates vary widely by industry, from under half a percent for dental practices to nearly six percent for breweries, and they are as-of measurements on long loans, not final lifetime rates.
Does the Small Business Administration require a feasibility study on every loan?
No. SOP 50 10 8 requires the lender to underwrite prudently and document it. Where repayment rests on projections rather than history, independent support for the projections is expected, and the study is how it enters the file. Startups, construction, ownership changes with a projected step-up, and special purpose properties are where the request arrives. Your lender or CDC decides.
Who orders and pays for the study?
Usually the borrower engages and pays, with the lender or CDC confirming scope before work begins. Some lenders order directly. Who pays does not change who it is written for: the intended users named in the certification.
How much does an SBA feasibility study cost?
Fixed, quoted in writing within one business day, scoped to asset class and complexity, never a percentage of the deal, never contingent on the finding.
How long does it take?
Standard delivery runs from complete project data, with rush available for files already in underwriting. The clock starts at complete data; incomplete document sets are the industry's largest source of delay.
What coverage ratio must the study show?
No single number applies to every credit. Thresholds come from your lender's policy, the CDC and the program, and are frequently stricter than any floor. We test at the threshold your file will be measured against and show operating and global coverage every year, before and after reserves. Treat an advertised universal ratio pair as a warning sign, particularly a global test at 1.00x, which passes at zero margin.
Is a feasibility study the same as an appraisal or a business valuation?
No to both. An appraisal is a USPAP opinion of value by a licensed or certified appraiser; a business valuation prices an existing business, and the SOP separately requires an independent one on certain ownership changes. The feasibility study tests forward-looking operations and contains no value opinion. Many files need two of the three; they are not interchangeable.
What is a special purpose property and why does it matter for my SBA loan?
A property with few alternative users if the operation fails: hotels, car washes, fuel, storage, senior care, marinas, entertainment, wineries. The label can raise the 504 equity injection from 10 toward 20 percent, forces allocated rather than blended appraisal treatment, and shifts credit weight onto the market evidence. On a median recent hotel deal that injection step is roughly half a million dollars.
Where do your statistics come from?
The SBA's public FOIA loan-level dataset for the 7(a) and 504 programs, a US government work in the public domain, refreshed quarterly; this page reflects the March 31, 2026 release and is recomputed on each new one. Demand work draws on federal statistical sources, state DOT traffic counts, franchise disclosure documents, CMBS property filings and our own national parcel and imagery data.
What happens if your conclusion is negative?
You receive it in full and the fee does not change, because it was never contingent. A negative finding usually names what would have to change: scale, site, structure or operator. Sponsors who restructure on it frequently come back and fund.
Sources
Get started
Send the deal, not a form field
Fixed fee quoted in writing within one business day. Never a percentage, never contingent on the finding.