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Marina Acquisition Feasibility Study under SOP 50 10 8.1 Appendix 15

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Buying a marina on an SBA loan is an Appendix 15 file with a tenure transfer and a fuel tank attached. MMCG Invest prepares marina acquisition and refinance feasibility studies for SBA 7(a), SBA 504, USDA Business and Industry and conventional financing that test the price at 1.25 times the seller's historical coverage rather than the seller's pro forma, classify the prior year's revenue by stay length against SBA's transient rule before anything else is computed, allocate land, docks and going concern for the 85 percent special use test that decides the term, move the submerged-lands lease or concession to the buyer under the state's own procedure, and report the debt service coverage ratio (DSCR) by year with the conditions written for the lender's counsel.

Why a marina acquisition is its own study

SOP 50 10 8.1, in force for applications received on or after October 1, 2026, stopped SBA lenders closing acquisitions on projections. An Initial Acquisition is tested on the last fiscal year or the two-year average at 1.25 times, and a shortfall cannot be cured by a forecast except where the loan is secured by owner-occupied special use property and the lender documents that historical information cannot be obtained or the appraisal fully secures the loan, or where there is no continuity of operations and the deal is underwritten as a start-up. The 10 percent equity injection cannot be reduced; seller debt on full standby, other standby debt and minority investor equity together may provide no more than half of it. An independent valuation is required on every change of ownership; a Quality of Earnings report is required at a business purchase price of $3 million or more net of owner-occupied real estate; seller consulting may run 24 months; earnouts are prohibited; a change-of-ownership loan amortizes over no more than 10 years unless special use property real estate is 85 percent or more of value, in which case 25 years is available. MMCG's analysis of the rules is in SBA Stopped Lending on Projections.

A marina adds two tests a restaurant or hotel acquisition does not carry. The first is eligibility: a marina is an SBA-eligible rental business only if more than 50 percent of its prior-year revenue came from transients staying 30 days or less, and the acquisition file is the one place where that number is a fact rather than a projection, because the seller's returns show it. The second is tenure: the docks sit on a state lease, a tidal wetlands license, a federal concession or a port ground lease that has to move to the buyer under its own procedure, on its own timeline, with the balance of its own term. The general marina method and the full rule set are on the marina feasibility study hub.

The lending programs and the structure

The business goes on 7(a) and the real estate on 504, and since July 4, 2026 a borrower that secures the 7(a) loan first may hold up to $5 million of each, $10 million combined, under Policy Notice 5000-879058. The 7(a) piece carries the Appendix 15 tests, a maximum rate of Prime plus 3.0 percent above $350,000, 10.00 percent in October 2026, the fiscal 2027 upfront fee of 2 to 3.75 percent and a 0.55 percent annual fee, waived on loans of $700,000 or less in a rural county. The 504 piece carries the marina's special-purpose classification, 15 percent for an existing business or 20 percent for a borrower operating two years or less, the 51 percent occupancy test with slips and docks counted as rentable property, and the October 2026 debenture at 6.97 percent on 20 or 25 years. Where the acquired operating company has more than two years of history and is the borrower or Operating Company, the study tests whether the lower tier applies and asks the CDC to confirm it. A marina inside a Coastal Barrier Resources System unit is ineligible, and a Phase I is required on every file because NAICS 713930 is on SOP Appendix 6 and because the fuel dock dispenses. The rules are on the SBA regulatory spine and the SBA 7(a) and SBA 504 pages.

A rural marina is a USDA Business and Industry acquisition where jobs are created or saved under 7 CFR 5001.105(b)(2), with no transient rule, 20 to 25 percent equity for a new business, 1.1 times historical coverage where the loan is refinancing-majority, and the lease-term clause at 5001.105(b)(14) that makes a Corps concession the credit; see the USDA feasibility study page and the lake and river marina feasibility study page. Conventional lenders underwrite the same study to 1.20 to 1.35 times on a going-concern appraisal and are the fallback for the metropolitan marina that fails the transient rule.

The historical revenue and the transient test

The study rebuilds the seller's revenue from the returns, the slip schedule and the fuel invoices, line by line and by stay length: transient nightly and weekly dockage; monthly contracts; seasonal and annual contracts; dry-stack and land storage; fuel; service; store; rentals; electric and fees. The share on each reading of the transient rule is the first number in the report, because the public record says the typical marina fails it: 6.0 percent transient at the largest US operator in 2024, 10.3 percent of sampled Chesapeake slips available to transients in Maryland's 2004 survey, 2.8 percent of revenue at a Puget Sound port in 2026. Whether fuel sold to transients, month-to-month contracts, rentals and club memberships count is a question SBA has not answered, and the determination states which reading it rests on and conditions the loan on the lender's written confirmation.

The coverage test follows. EBITDA for the last fiscal year and the two-year average is normalized for the owner's wage, related-party rent and one-time items, tested at 1.25 times the proposed debt service, and the price that clears the floor is reported beside the asking price. The seasonal cash profile matters because dockage is prepaid in winter on the Chesapeake and the Great Lakes, Havre de Grace taking half by December 1 and the balance by February 1, so the study shows the fiscal year the lender should use and warns where a storm or low-water year sits inside the two-year window.

Price, valuation and allocation

Price per slip does not support a lending value, and the study says so. Closed and listed Maryland prices in 2025 and 2026 ran from $2.9 million for Baltimore's 278-slip Harborview Marina at foreclosure, about $10,400 a slip after its fixed pier was closed for safety, to $4.6 million for Casa Rio's 35 wet slips and 200 land spaces on 6.5 acres, $10.75 million for Annapolis City Marina's roughly 90 slips with a fuel dock and parking approved by Annapolis Yacht Club's members in September 2026, and $11.9 million asked for a 250-slip full-service Chesapeake marina; Puget Sound listings run $26,000 to $78,000 a slip asked; Table Rock's three sales since 2023 disclosed no price; Safe Harbor traded at about $52,000 a space in 2020 and about $115,900 in 2025. The only disclosed income metric in the Chesapeake record is Mears Point's $1 million of in-place NOI on 540 slips in 2020, about $1,850 a slip including leased restaurants, and a marina whose value sits in its tenants or its slip sales is underwritten on the waterfront mixed-use feasibility study page's method. The study values the marina on income, reports the implied NOI per slip as a cross-check, and treats any cap rate as a labeled assumption because no public survey publishes one for marinas. The institutional yield of about 5.1 percent implied by the Safe Harbor sale is a portfolio figure before service income and overhead and is never used as an exit cap for a single marina.

The allocation decides the term. Appendix 15 requires the appraisal to separate land, site improvements, docks and going concern, and the 25-year route opens only where special use real estate is 85 percent or more of value. County assessments put land at 62 to 85 percent of assessed value, averaging 77 percent, on six Anne Arundel County marinas, so most Chesapeake marinas sit below the line on land alone and the docks and improvements decide it. Whether docks, floating docks, lifts and racks are real property, fixtures or personal property is unsettled in Florida, Washington, Michigan, Maryland, North Carolina, Missouri and Arkansas on MMCG's reading, and the study recommends the mortgage and a UCC fixture filing both describe them. Where the real estate is a leasehold, the appraisal values the leasehold interest only for the term remaining. MMCG's note on why the appraisal and the study are different documents is in When the Appraisal Isn't Enough.

Tenure transfer and the fuel dock

Every state moves the lease differently and the study writes the procedure into the closing conditions. North Carolina's submerged-lands easement transfers to the new upland owner by written notice to the State Property Office within 12 months of the title transfer with a payment equal to the initial payment in years 1 to 25 or twice it in years 26 to 50, with no discretionary consent. Florida's sovereignty submerged lands lease assigns only with the Trustees' prior written consent, the new lease runs for the balance of the original term, renewal is at the lessor's sole option, and Florida counsel report that the Trustees do not customarily consent to mortgages or collateral assignments. Maryland's Board of Public Works transfers a tidal wetlands license on written request from the new riparian owner under COMAR 23.02.04.17, and its license form states that the license transfers no property interest and binds the transferee to all terms. Washington DNR's assignment consent and Michigan EGLE's practice were not found in the public record and are confirmed at scoping. A Corps concession requires the Real Estate Contracting Officer's written approval of any transfer of a controlling interest, on a timeline no district publishes. The study carries six to twelve months for a discretionary consent as a flagged assumption and asks for an estoppel confirming rent, term and no default in every case. The state pages for Maryland, Florida, North Carolina and Washington carry the state requirements.

The fuel dock is the environmental file. Maryland's revised Chapter 26.10 rules, effective June 13, 2022, require every regulated underground tank to be registered with the Department of the Environment with corrosion protection, spill and overfill prevention, monthly leak detection on tanks and piping, inspection by a certified inspector, trained Class A and B operators, an individual oil operations permit at 10,000 gallons of motor fuel or 1,000 gallons of used oil, UL 971 piping from bulkhead to dispenser sleeved in rigid two-hour rated pipe, and no holding clips on fuel nozzles; marina tanks typically run 1,000 to 10,000 gallons. The study requires the registration, the latest certified inspection, the leak detection and tightness records and a Phase I before commitment, a Phase II on any recognized environmental condition, and a seller environmental indemnity, and it budgets replacement from the public record: $358,575 for a single Michigan marina tank, about $1.1 million for a Florida city dock tank, $2 million for two 30,000-gallon underground tanks at the Port of Everett, and a 2020 Annapolis task force estimate of $1 million to $1.5 million for the City Marina fuel dock's tank repairs.

Project cost, capex and the capital stack

An acquisition's cost table is the purchase price, the closing and tenure costs, the fuel system and dock capex the engineer's survey requires, and working capital. Dock replacement is priced from public bids at about $50,000 to $100,000 a slip with outliers to $175,000, a marine engineer's condition survey with a capex schedule is a condition on every file because Harborview's fixed pier closed on safety grounds before its sale, and maintenance dredging is carried at the small-basin rate of $42 to $57 a cubic yard. The capital stack is 10 percent cash equity, of which at most half may be a seller note on full standby, the 7(a) loan on the business on a 10-year term, the 504 first mortgage and debenture on the real estate where the combined request exceeds $5 million, and a reserve sized to the winter. The study shows the price that clears 1.25 times beside the asking price and the equity that closes the gap.

DSCR and the stress cases

The study reports historical DSCR on the last fiscal year and the two-year average at 1.25 times, then projected DSCR by year as information rather than as the eligibility test. The cases are the acquisition's: the transient reading, the normalized owner's wage, a rate increase against the market's posted range, fuel gallons and margin, insurance at the forecast 12 to 18 percent annual escalation and a doubled named-storm deductible, the capex schedule, a storm or low-water year inside the lookback, and the tenure consent timeline. Break-even is stated in annual slips at the contract rate.

Scope, turnaround and fees

A MMCG marina acquisition study includes the eligibility analysis with the prior-year revenue classified by stay length, the historical coverage test on normalized returns, the market and competitive census with posted rates, the valuation discussion with the allocation and the 85 percent test, the tenure transfer procedure and timeline written for counsel, the fuel system and environmental review, the dock condition and capex schedule, the capital stack with the injection and standby rules, the DSCR schedule, the stress cases, the conditions list, and a signed conclusion. Standard delivery is nine to sixteen business days; expedited delivery in five to seven is available. Fees begin at $4,900 for a single-site SBA 7(a) study and run $7,500 to $15,000 for 504, combined and USDA studies. Revisions required by the lender or agency are made at no additional cost under MMCG's written acceptance guarantee. See MMCG's feasibility study methodology and where we work.

Model case studies

Frequently asked questions

Can projections rescue a marina acquisition that does not cover?

No. Under SOP 50 10 8.1 an Initial Acquisition is tested on the last fiscal year or the two-year average at 1.25 times. The remedies are a lower price, more equity, or a seller note on full standby, which may provide up to half of the 10 percent injection.

Does the seller's revenue pass the transient rule?

The returns answer it. The typical marina earns 3 to 15 percent of dockage from transients, so most fail on dockage alone. The study classifies every line by stay length and states the reading the determination rests on; SBA has not said whether fuel, month-to-month contracts, rentals or memberships count.

Is the loan 10 years or 25?

10 years unless special use property real estate is 85 percent or more of value. Land alone averaged 77 percent of assessed value on six Chesapeake marinas, so the docks and improvements decide it, and the study tests the allocation before assuming the term. The real estate can also go onto a 20 or 25-year 504 debenture.

How does the lease move to the buyer?

By notice and payment in North Carolina, by the Trustees' consent in Florida with a new lease for the balance of the term, by Board of Public Works approval in Maryland, by Corps approval of the change in control on a reservoir. The study writes the procedure, the estoppel and a six to twelve month timeline into the closing conditions.

What is a marina worth per slip?

Anything from $10,000 at a distressed Baltimore foreclosure to above $115,000 at the Safe Harbor portfolio sale. Price per slip cannot support a lending value; the study values on income, reports NOI per slip as a cross-check and labels any cap rate as an assumption.

What does the fuel dock require?

A Phase I on every file, the state tank registration and certified inspection, leak detection and tightness records, a Phase II on any recognized condition, a seller indemnity, and a replacement budget of about $360,000 to $2 million by the public record.

When is a Quality of Earnings report required?

At a business purchase price of $3 million or more net of owner-occupied real estate.

What does the study conclude?

Feasible, feasible with conditions, or not feasible, with the transient reading stated first, historical coverage on the normalized returns, the price that clears 1.25 times, the allocation and term, and the tenure and environmental conditions written for the lender's counsel.

Where we work

The same study, prepared to the lender requirements of the state the project sits in.

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Michal Mohelsky, J.D., Principal of MMCG Invest

Michal Mohelsky, J.D., FMVA

Principal in charge · MMCG Invest, LLC

Emailmichal@mmcginvest.com

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