A feasibility study in New York City starts from a premise most markets never test: the rent roll, the tax bill and the construction budget are each set in part by statute before the first comparable is pulled. MMCG Invest, LLC prepares lender-ready feasibility studies for SBA 504, SBA 7(a), USDA Rural Development and conventional financing across the New York-Newark-Jersey City metro, a region of 19,940,274 people by the Census Bureau's 2024 estimate that spans the five boroughs, Long Island, the lower Hudson Valley and northern and central New Jersey. Every report is written to the standard its reader will apply: SBA SOP 50 10 8 for a 7(a) or 504 credit, 7 CFR Part 5001 for a USDA guarantee, and USPAP for the analysis a bank or Certified Development Company expects to be able to check line by line. New York City underwrites differently because its statute is different. The Housing Stability and Tenant Protection Act of 2019 made rent stabilization permanent and repealed the deregulation exits as of June 14, 2019, so a stabilized unit no longer moves to market rent on turnover. Fees start at $4,900.
The New York-Newark-Jersey City, NY-NJ metro is home to about 19,940,274 residents per the U.S. Census Bureau Population Estimates, led by Kings County at 2,617,631; Queens County at 2,316,841; New York County at 1,660,664; Suffolk County at 1,535,909.
Why a New York City feasibility study sits outside a national template
A national feasibility template assumes market rent on turnover, a property tax that follows the assessment at one rate, a construction budget priced at the regional wage and no operating charge tied to a building's carbon. New York City breaks each of those assumptions by statute, across a metro led by Kings County, which is Brooklyn, at 2,617,631 residents, Queens County at 2,316,841, New York County, which is Manhattan, at 1,660,664 and Suffolk County at 1,535,909. The four variables below are drawn from New York State Homes and Community Renewal, the New York State Senate's text of the Real Property Tax Law, the New York City Department of Finance and the New York City Department of Buildings, and each moves a line in the pro forma a lender will test.
Rent stabilization and the Housing Stability and Tenant Protection Act of 2019. Rent stabilization generally covers buildings built after 1947 and before 1974, plus buildings taking J-51, 421-a and 421-g tax benefits, with annual increases capped through local Rent Guidelines Boards and lease renewal guaranteed. The 2019 act, Senate Bill S6458, repealed high-rent vacancy decontrol and high-income deregulation as of June 14, 2019 and made the framework permanent. A stabilized building therefore cannot be underwritten on mark-to-market rent growth, unit deregulation or aggressive turnover, which resets achievable value.
The 421-a to 485-x property-tax-exemption regime. Class 2 rentals carry a heavy as-of-right tax burden, so ground-up rental long relied on the 421-a Affordable New York Housing Program exemption. That window closed and Real Property Tax Law 485-x replaced it, granting the exemption only against affordability set-asides of not less than twenty-five, twenty or fifty percent of units. The construction wage floors turn on project size: HPD states that eligible sites with at least 100 units must offer a minimum wage of $40/hr rising 2.5% annually, that eligible sites with at least 150 units in Zone A must offer the lesser of $72.45/hr or 65% of the greatest prevailing rate, and that eligible sites with at least 150 units in Zone B must offer the lesser of $63/hr or 60% of that rate. Below 100 units the set-aside applies without the wage floor, and sites under a Project Labor Agreement are exempt, so the unit count is an intake question and a new-development pro forma carries the wage line only once it is crossed.
New York City's four-class property tax system. The Department of Finance assesses Class 1, one-to-three-unit homes, at 6 percent of market value and Classes 2, 3 and 4 at 45 percent, Class 2 being rentals, cooperatives and condominiums and Class 4 commercial and industrial property. Tax bills flow from class-specific assessed values, class tax shares and multi-year phase-ins rather than one flat rate. Because tax is often the largest operating line for a Class 2 or Class 4 asset, and the phase-in lags market value, a single effective rate misstates net operating income.
Local Law 97 building carbon emissions limits. Local Law 97 of 2019 requires most buildings exceeding 25,000 gross square feet to meet greenhouse gas emissions limits beginning in 2024, tightening in 2030 on the way to steep reductions by 2050. A building over its annual limit faces a penalty the city reports at 268 dollars per metric ton of carbon dioxide equivalent above the cap. For office and large multifamily underwriting this adds an ongoing compliance charge and potential retrofit capital expenditure found in few other US markets, cutting net operating income and raising hold-period capex.
SBA 504 feasibility study New York City and SBA 7(a) studies
An SBA 504 feasibility study New York City Certified Development Companies and their participating banks can rely on is written to SBA SOP 50 10 8, the operating procedure that governs both 7(a) and 504 underwriting, and it is written to be checked. MMCG builds the market and financial sections on primary and government sources and on the SBA's own 7(a) and 504 FOIA release, labeled as of June 30, 2026, computed in-house by county membership across the 22 counties of the New York-Newark-Jersey City MSA: Bronx, Kings, New York, Queens and Richmond, which are the five boroughs; Nassau, Suffolk, Westchester, Rockland and Putnam in New York; and Bergen, Essex, Hudson, Hunterdon, Middlesex, Monmouth, Morris, Ocean, Passaic, Somerset, Sussex and Union in New Jersey. A metro figure is the sum over those member counties, never an SBA district total, and the FY2025 7(a) rows show why the distinction matters: 3,586 were filed through the New York District Office and 2,233 through the New Jersey District Office, with five more filed through offices outside the region. For the national frame, the SBA closed fiscal year 2025 with 84,400 7(a) and 504 loans for $44.8 billion, comprising 77,600 7(a) loans for $37 billion and 6,750 504 loans for $7.8 billion, per SBA News Release 25-83 dated September 30, 2025.
In fiscal year 2025 the New York City metro recorded 5,824 7(a) approvals for $2,197,992,500 and 181 504 approvals for $291,056,000, up from 5,325 7(a) approvals for $1,754,191,200 and 173 504 approvals for $268,805,000 in FY2024. The most active 7(a) lenders by FY2025 approval count were TD Bank, National Association with 1,202 loans, Northeast Bank with 703 and Manufacturers and Traders Trust Company with 483. On the 504 side, Empire State Certified Development Corporation led the metro with 99 loans for $154,863,000. Across the ten asset classes tracked in the SBA record, the metro's disbursed record from FY2010 to FY2026 runs to 5,358 7(a) loans for $3,333,507,600 at an 11.5% charge-off rate and 268 504 loans for $348,196,000 at 4.1%. The full lender and CDC lists, the asset-class table and the FY2023 to FY2026 approval series are in the New York City feasibility market research post, and the figures a lender sees in an MMCG study are the same figures, computed the same way.
USDA feasibility study New York City
A USDA feasibility study New York City borrowers ask about almost always concerns a site at the far edge of the metro, because the program's geography is set by regulation. USDA Rural Development guaranteed programs run under 7 CFR Part 5001 and reach rural areas with populations of up to 50,000, barring a project in a city or town of more than 50,000 or in an urbanized area adjacent to one, which rules out the five boroughs outright. Even inside this New York and New Jersey metro, though, the outer counties, such as Putnam County in New York and Sussex and Hunterdon counties in New Jersey, hold small municipalities that plausibly qualify. Plausible is not confirmed. MMCG verifies eligibility at the subject address on the USDA eligibility map at intake, because a parcel inside the adjoining urbanized area is ineligible however rural the road looks. When the address qualifies, the study is built to 7 CFR Part 5001 and formatted for the USDA guaranteed-loan file with the same lender-facing structure MMCG uses for SBA work, so a project being shopped to both a bank and Rural Development does not need two reports; when it does not qualify, MMCG says so at intake and reframes the scope for SBA or conventional financing.
Hotel feasibility study New York City
A hotel feasibility study New York City lenders will accept has to carry the city's own cost lines before it reaches demand. A hotel building exceeding 25,000 gross square feet sits inside Local Law 97, so the study carries the annual greenhouse gas limit that began in 2024, the 268 dollars per metric ton penalty above the cap and any retrofit capital the 2030 tightening implies. The property tax line follows the four-class system, with Class 4 commercial property assessed at 45 percent of market value and the bill shaped by class tax shares and multi-year phase-ins rather than one effective rate, and a sale carries the state real estate transfer tax of 2 dollars per 500 dollars of consideration plus the further transfer taxes that apply inside New York City. The SBA record shows hotels are a financed class in this metro: hotels and motels in the New York City MSA drew 178 7(a) loans for $585,206,300 at a 1.8% charge-off rate and 34 504 loans for $100,230,000 over the FY2010 to FY2026 disbursed record, and that 1.8% is the lowest 7(a) charge-off rate disclosed for any of the ten asset classes in the metro record. MMCG's hotel study addresses each of these lines in a form written for SBA 7(a), SBA 504 or conventional hotel financing.
Underwriting realities behind a defensible New York City study
A New York City pro forma parts from the national template at a handful of predictable points. Each item below is drawn from the statute or the federal file cited on this page, and each is modeled in the study as a line with a source and a date rather than absorbed into a regional assumption.
- The rent roll is regulated before it is projected. For a rent-stabilized building the study takes annual increases from the Rent Guidelines Board framework and assumes no deregulation on turnover, because the Housing Stability and Tenant Protection Act of 2019 repealed high-rent vacancy decontrol and high-income deregulation as of June 14, 2019 and made the framework permanent.
- The 485-x wage floor is a threshold test, not a flat cost. At 100 units or more new rental construction is priced at $40/hr rising 2.5% annually; at 150 units or more it is the lesser of $72.45/hr or 65% of the prevailing rate in Zone A and the lesser of $63/hr or 60% in Zone B; below 100 units there is no 485-x wage floor, and a Project Labor Agreement exempts the site. The affordable set-aside of not less than twenty-five, twenty or fifty percent of units is carried at locked-in affordable rents in every case.
- Property tax is built from the class, not from a rate. Class 2 and Class 4 assets are assessed at 45 percent of market value against 6 percent for Class 1, and the bill follows class tax shares and multi-year phase-ins of assessment changes, so the study reconstructs the tax line from the assessment rather than applying one effective rate to value.
- Carbon is an operating line. A building exceeding 25,000 gross square feet meets Local Law 97 greenhouse gas limits from 2024, tightening in 2030 toward steep reductions by 2050, and the study carries the 268 dollars per metric ton penalty on any exceedance and the retrofit capital that avoids it.
How a New York City feasibility study engagement runs
A New York City feasibility study engagement opens with three inputs: the project address, the asset class and the lender or CDC contact who will receive the report. The address fixes the borough or county and the state, and with them the transfer-tax regime; it tells us whether the building sits in the rent-stabilized stock or the 485-x pipeline, which tax class it is assessed in, whether it crosses the 25,000 gross square foot Local Law 97 threshold, and whether USDA eligibility is even possible at that address. The asset class selects the demand model and the slice of the SBA record we compute for the metro. The lender or CDC contact sets the format, because a 504 file for a Certified Development Company, a 7(a) file for a bank, a USDA guaranteed-loan file and a conventional credit memo do not ask for the same exhibits in the same order. Within 12 business hours of an inquiry you have a first response; the written scope, fixed fee and delivery date follow a short intake call. Fees start at $4,900. Standard turnaround is 9 to 16 business days from receipt of the project documents, and a rush track delivers in 5 business days when a commitment date or a CDC board meeting requires it. The delivered report carries an executive summary the credit officer can read first, the four structural variables stated with their source and date, the market and financial analysis, the metro SBA record computed from the FOIA file, and a sources list naming the publisher and date of every figure, and MMCG stays available to the underwriter after delivery to walk through how any figure was derived.
Cities and counties served in the New York City region
- Manhattan (New York County): Midtown, Financial District, Hudson Yards, Chelsea, Upper East Side, Upper West Side, Harlem, Washington Heights, East Village, Tribeca
- Brooklyn (Kings County): Downtown Brooklyn, Williamsburg, Bushwick, Bedford-Stuyvesant, Park Slope, Sunset Park, Bay Ridge, Flatbush, Red Hook, East New York
- Queens: Long Island City, Astoria, Flushing, Jamaica, Jackson Heights, Forest Hills, Elmhurst, Bayside, Ridgewood, Far Rockaway
- The Bronx: Mott Haven, Hunts Point, Fordham, Riverdale, Kingsbridge, Morris Park, Pelham Bay, Throggs Neck, Co-op City
- Staten Island (Richmond County): St. George, Stapleton, Port Richmond, New Dorp, Great Kills, Tottenville, Mariners Harbor
- Hudson County, NJ: Jersey City, Hoboken, Bayonne, Union City, North Bergen, West New York, Secaucus, Kearny
- Essex County, NJ: Newark, East Orange, Irvington, Bloomfield, Montclair, West Orange, Livingston
- Bergen County, NJ: Hackensack, Fort Lee, Paramus, Teaneck, Englewood, Ridgewood, Mahwah
- Passaic County, NJ: Paterson, Clifton, Passaic, Wayne, Little Falls
- Union County, NJ: Elizabeth, Union, Plainfield, Linden, Rahway, Westfield, Cranford
- Middlesex County, NJ: New Brunswick, Edison, Woodbridge, Perth Amboy, Piscataway, Sayreville
- Monmouth County, NJ: Freehold, Red Bank, Long Branch, Asbury Park, Middletown, Neptune
- Ocean County, NJ: Toms River, Lakewood, Brick, Jackson, Point Pleasant
- Somerset County, NJ: Somerville, Bridgewater, Franklin Township, Bernardsville, Bound Brook
- Morris County, NJ: Morristown, Parsippany, Dover, Madison, Boonton, Randolph
- Sussex County, NJ: Newton, Branchville, Sparta, Hopatcong, Vernon, Franklin
- Hunterdon County, NJ: Flemington, Frenchtown, Milford, Lambertville, Clinton, Califon
- Westchester County, NY: White Plains, Yonkers, New Rochelle, Mount Vernon, Peekskill, Tarrytown, Port Chester
- Rockland County, NY: Nyack, Spring Valley, Suffern, New City, Haverstraw, Pearl River
- Putnam County, NY: Carmel, Brewster, Cold Spring, Nelsonville, Mahopac
- Nassau County, NY: Hempstead, Mineola, Garden City, Long Beach, Glen Cove, Great Neck, Freeport
- Suffolk County, NY: Huntington, Islip, Babylon, Smithtown, Patchogue, Riverhead, Bay Shore
Related New York City and program resources
- The New York City feasibility market research post, the deep dive that carries the FOIA table and the sources.
- The New York feasibility study statewide page.
- The SBA feasibility study program page.
- The USDA feasibility study program page.
- The feasibility study index.
About MMCG
Michal Mohelsky, J.D., FMVA, Practicing Affiliate of the Appraisal Institute, leads MMCG Invest, LLC, which specializes in SBA and USDA feasibility studies for commercial real estate and operating businesses, with hotels and motels, car washes, self-storage, RV parks and campgrounds, assisted living and continuing care, gas stations and convenience stores, restaurants, fitness and recreational sports centers, marinas and child day care among the ten asset classes it tracks in the SBA record. Reports are prepared in accordance with USPAP, with SBA SOP 50 10 8 for 7(a) and 504 credits and with 7 CFR Part 5001 for USDA Rural Development guarantees, and every figure in a report traces to a named primary, government or FOIA source with its date. In the New York City metro that means New York State Homes and Community Renewal, the New York State Senate's text of the Real Property Tax Law, the New York City Department of Finance, the New York City Department of Buildings, the New York State Department of Taxation and Finance, the New Jersey Division of Taxation, the Code of Federal Regulations, the Census Bureau's population estimates and the SBA's 7(a) and 504 FOIA release.
Frequently asked questions
How much does a feasibility study cost in New York City?
MMCG's fees start at $4,900 and are quoted as a fixed amount once the project address, the asset class and the lender or CDC format are known. A rent-stabilized multifamily study, a 485-x new-development study and a hotel study do not carry the same scope, so the quote follows a short intake call rather than a rate card.
How long does a New York City feasibility study take?
Standard turnaround is 9 to 16 business days from receipt of the project documents. A rush track delivers in 5 business days when a commitment date or a CDC board meeting requires it, and every inquiry receives a response within 12 business hours.
Do I need a feasibility study for an SBA 504 loan in New York City?
That is decided by SBA SOP 50 10 8 and by the credit policy of the lender or the Certified Development Company for the project type and loan size, so ask the lender or CDC contact early. When a study is required, MMCG writes it to the SOP standard so the CDC and the participating bank can rely on the same document.
Is New York City eligible for USDA business loans?
The five boroughs are not. USDA Rural Development guaranteed programs under 7 CFR Part 5001 reach rural areas with populations of up to 50,000 and bar a project in a city or town of more than 50,000 or in an urbanized area adjacent to one. Small municipalities at the metro's edge, in outer counties such as Putnam County in New York and Sussex and Hunterdon counties in New Jersey, are plausibly eligible, and MMCG verifies the exact address on the USDA eligibility map at intake.
Which banks make the most SBA 7(a) loans in the New York City area?
By fiscal year 2025 approval count across the 22 counties of the New York-Newark-Jersey City MSA, computed from the SBA FOIA release, the most active 7(a) lenders were TD Bank, National Association with 1,202 loans, Northeast Bank with 703 and Manufacturers and Traders Trust Company with 483. The full list, with each lender's approval count and dollar volume, is in the New York City feasibility market research post.
Which CDCs handle SBA 504 loans in New York City?
In fiscal year 2025 the most active 504 Certified Development Company in the New York City MSA, computed from the SBA FOIA release, was Empire State Certified Development Corporation with 99 loans for $154,863,000. The other CDCs active in the metro that year are listed with their counts in the New York City feasibility market research post.
Does a New York City feasibility study account for rent stabilization and Local Law 97?
Yes. For a rent-stabilized building the study carries Rent Guidelines Board increases and assumes no deregulation on turnover, because the Housing Stability and Tenant Protection Act of 2019 repealed high-rent vacancy decontrol and high-income deregulation as of June 14, 2019 and made the framework permanent. For a building exceeding 25,000 gross square feet the study carries the Local Law 97 greenhouse gas limit, the 268 dollars per metric ton penalty above the cap and any retrofit capital, as explicit lines rather than a regional assumption.
Can a hotel project in New York City get an SBA 7(a) or 504 loan?
The credit decision belongs to the lender or CDC under SBA SOP 50 10 8, but the record shows hotels are a financed class in this metro. Over the FY2010 to FY2026 disbursed record, hotels and motels in the New York City MSA drew 178 7(a) loans for $585,206,300 at a 1.8% charge-off rate and 34 504 loans for $100,230,000. MMCG's hotel feasibility study is written for that file, carrying Local Law 97, the four-class property tax and the transfer taxes that apply to the subject.
Asset classes we study in New York City
Where we work
The same study, prepared to the lender requirements of the state the project sits in.
