Prepared by Michal Mohelsky, J.D., Practicing Affiliate of the Appraisal Institute, FMVA
MMCG Invest, LLC · San Francisco, CA
Published May 18, 2026 · Last updated May 21, 2026
The methodology behind every feasibility conslusions.
Three pillars behind every bankable feasibility study
Every feasibility study MMCG Invest delivers rests on three analytical pillars. Each pillar carries a distinct burden of proof, and a report is bankable only when all three clear at once. The framework is the reason a single report can move through an SBA credit committee, a USDA Rural Development field office, a conventional bank, a CMBS conduit, a life insurance company, and an agency multifamily desk without rework.
The Bankable Framework. The reporting discipline that satisfies the documentation expectations of every U.S. commercial real estate capital source in one deliverable. Standardized exhibit set, standardized section sequence, and standardized scope of opinion, so the same report file can be presented to any lender the sponsor may eventually approach.
Market Analysis Discipline. The market-side pillar. Primary market area definition, demographics analysis and demand quantification, competitive set construction, supply pipeline reconciliation, capture and penetration analysis, and rent or rate positioning. Calibrated to NCHMA Model Content Standards for multifamily and senior housing, and to lender-grade comparable methodology for every other asset class.
Financial Projections Discipline. The project-level financial pillar. Revenue projection by asset-class metric, operating expense benchmarking against RMA, IBISWorld, IREM, and asset-class specialty sources, NOI build and stabilization timeline, seven-source DSCR threshold analysis, debt yield testing, three-tier sensitivity, optional Monte Carlo simulation, and equity returns analysis for institutional capital.
The pillars do not operate in sequence so much as in tension. The market analysis sets the revenue ceiling the financial projections are permitted to assume. The financial projections convert that ceiling into the coverage and return tests the capital source applies. The bankable framework governs how both are documented so that the conclusion survives review. A report that is strong on two pillars and weak on the third is not a bankable report, and the discipline exists precisely to prevent that asymmetry.
A single feasibility report accepted across every U.S. capital source
The feasibility study is the only third-party report a lender, credit committee, or rating agency reads end to end before approving a commercial real estate loan. The bankable framework is the reporting discipline that lets one report serve every capital source the sponsor might eventually approach. Section sequence, exhibit conventions, scope of opinion, and supporting documentation are standardized to the strictest common denominator across SBA SOP 50 10 8, USDA 7 CFR Part 5001, the HUD MAP Guide, NCHMA Model Content Standards, and the published criteria of KBRA, S&P, Fitch, Moody's, and DBRS Morningstar.
The practical consequence is optionality. A sponsor who begins an SBA 504 process can pivot to a conventional bank or a CMBS execution without commissioning a second feasibility study. A USDA B&I applicant can resubmit to USDA Community Facilities under a different program structure with the same report. The reporting framework is the moat. The program-level calibration sits inside it.
That calibration is specific rather than cosmetic. SBA 7(a) and SBA 504 require explicit conformity to SOP 50 10 8 documentation and job-creation logic. USDA B&I and Community Facilities require the structure prescribed by 7 CFR Part 5001 and Rural Development field-office practice. CMBS conduit execution requires reconciliation to the rating agencies named above. Life insurance lenders apply the in-place stress framework of the underwriting desk. Agency multifamily requires NCHMA Model Content Standards and Fannie Mae or Freddie Mac DUS-equivalent documentation. The same report serves multiple programs because it is built to the strictest of them from the outset, not retrofitted to each in turn.
Market analysis the lender's credit team cannot reject
The market analysis pillar answers the threshold question every credit officer asks before reading the financial projections. Is there sufficient demand in the primary market area to absorb the project at the assumed rent or rate, against the existing and pipeline competitive set, within the assumed lease-up or ramp period. If the answer to that question is not documented and defensible, the financial projections that follow are an exercise in arithmetic rather than analysis, and the credit team will treat them accordingly.
The discipline begins with primary market area definition by radius or drive-time, calibrated to the asset class and the local geography. PMA definition is the single most consequential methodological choice in any market study, because every demand figure that follows is bounded by it. A market drawn too wide overstates demand. A market drawn too narrow understates it. The definition is justified in the report and stress-tested against alternative boundaries so that the conclusion does not rest on a convenient line on a map.
From the defined market, the discipline proceeds through demand quantification, competitive set construction, supply pipeline reconciliation, and capture-rate or penetration analysis. It closes with a rent or rate positioning that the comparable set supports rather than the positioning the project would prefer. The competitive set is field-verified rather than assembled from a database alone, and the supply pipeline reconciliation accounts for the projects that will compete for the same tenant or customer before the subject reaches stabilization.
The calibration differs by asset class. For multifamily and senior housing, the discipline conforms to NCHMA Model Content Standards as published in September 2025, including comp-set selection criteria, capture and penetration analysis, and the prescribed exhibit set. For hospitality, the discipline reconciles demand segmentation with local employer and tourism inputs. For self-storage, it applies the concentric Radius Study methodology and square-foot-per-capita benchmarking. For retail and food service, it relies on trade-area analysis calibrated to drive-time and foot-traffic data. For every asset class, the comparable set is field-verified and the data sources are cited at the exhibit level, so a reviewer can trace each conclusion to its source.
Financial projections and seven-source DSCR analysis the credit committee can sign on
The financial projections pillar answers the project-level question: will the specific project carry debt service, satisfy the lender's threshold tests, and produce equity returns appropriate to the capital structure. The discipline builds revenue from the asset-class-appropriate metric, whether that is RevPAR, rent per unit, rent per square foot, occupancy multiplied by ticket, monthly rent per stall, or fueling-station throughput. It benchmarks operating expenses against RMA Annual Statement Studies, IBISWorld, IREM, and asset-class specialty sources, then reconciles the result to local market conditions.
The NOI build resolves into a stabilization timeline that the lender can match to the loan amortization. Debt service coverage ratio is tested against seven capital-source thresholds in parallel. Debt yield is tested as the post-2008 second filter that CMBS and life-co lenders apply alongside DSCR. Sensitivity analysis runs downside, base, and upside scenarios on revenue, expense, and stabilization-timing inputs. When the deal warrants institutional capital, Monte Carlo simulation and equity returns analysis (IRR, equity multiple, cash-on-cash) are layered on top.
Debt service coverage is then tested against seven capital-source thresholds in parallel. The same NOI build is run through the published DSCR threshold for each capital source the sponsor may approach, returned as a pass or fail against the projected NOI, and re-tested under the sensitivity framework. The lender reading the report can see the deal's position against every capital source the sponsor might pivot to, not against a single placeholder ratio. Debt yield is tested as the second filter that CMBS and life-company lenders apply alongside DSCR, the discipline that the market adopted after 2008 precisely because coverage alone proved insufficient.
Sensitivity analysis runs downside, base, and upside scenarios on the variables that actually drive the conclusion, typically revenue, operating expense, and stabilization timing. The analysis isolates the inputs to which the project is genuinely exposed and distinguishes them from the inputs that move the conclusion very little. When the deal warrants institutional capital, Monte Carlo simulation and equity returns analysis, including IRR, equity multiple, and cash-on-cash, are layered on top. The result tells the credit committee not only what the project produces under the expected case, but how far conditions can deteriorate before the financing comes under pressure.
The institutional data subscriptions every feasibility report draws on
Every analytical conclusion in every report MMCG Invest delivers is sourced from a paid institutional subscription or a primary research process. The data infrastructure is the reason the practice can produce reports the credit committee will not send back for sourcing, and it is the line that separates a feasibility study from an opinion.
The subscription stack includes ESRI Business Analyst, STDB (Intellisite), CoStar, Placer.ai, IBISWorld, STR-equivalent hospitality data, RMA Annual Statement Studies, IREM, Smith Travel Research methodology, the Federal Reserve FRED series, U.S. Census ACS, BLS QCEW, and demographic snapshot data. Each source carries a defined role in the analysis, and each conclusion drawn from it is cited at the exhibit level rather than aggregated into an unsourced figure.
Primary research is layered on top of every subscription source. Field comp verification, operator interviews, lender criteria collection, and zoning and entitlement confirmation are performed for each engagement. The subscriptions are the floor. The primary research is the differentiator. A database tells the analyst what a market looked like at the moment the data was compiled. The field tells the analyst what the market looks like now, which is the only condition a credit committee is willing to lend against.
Independence is the product in every third-party feasibility study
MMCG Invest is engaged on two parallel tracks. Sponsors and developers retain the practice directly to produce the feasibility study their named lender requires. Lenders, CDCs, USDA Rural Development field offices, and SBA Certified Development Companies retain the practice directly when they require an independent third-party report on a deal already in their pipeline. In both engagement models the analytical work, the deliverable, the methodology, and the standard of independence are identical.
Independence is preserved structurally rather than situationally. The practice does not accept brokerage fees, lender referral fees on borrower-engaged work, success-based compensation tied to loan funding, or equity participations in the projects it analyzes. The conclusion of value, the demand quantification, and the financial projections are governed by the analyst's professional standards and by the published methodology, not by the identity of the party that signs the engagement letter. The report's audience is the credit committee in either case, and if the analysis does not support the deal, the report says so.
Four reviews before the report leaves the practice.
01 — Analyst draft. The lead analyst produces the working draft against the engagement scope, the asset-class methodology, and the loan program criteria.
02 — Senior analyst review. A senior analyst with sector specialty (industrial, hospitality, retail, multifamily, or USDA-eligible assets) reviews the draft against the published methodology and the comparable set.
03 — Principal review. The principal, a J.D. and Practicing Affiliate of the Appraisal Institute, reviews the conclusion of value, the scope of opinion, and the lender-side documentation.
04 — Lender-side reconciliation. Before delivery, the report is reconciled against the named lender's published documentation requirements, the loan program criteria, and the credit committee's standard report-acceptance checklis
Frequently Asked Questions
What makes a feasibility study "bankable"?
A study is bankable when the named lender, the credit committee, and any downstream rating agency or guarantor can accept the report without requesting rework. In practice that requires three conditions met at once. A market analysis the credit team cannot reject on sourcing or comp-set grounds, a financial projection that survives the lender's DSCR and debt yield tests under a documented sensitivity framework, and a reporting framework calibrated to the strictest common denominator across SBA SOP 50 10 8, USDA 7 CFR Part 5001, the HUD MAP Guide, NCHMA Model Content Standards, and major CMBS rating agency criteria. MMCG Invest produces every report against all three conditions simultaneously.
How long does a feasibility study take to deliver?
Standard delivery is nine to sixteen business days from receipt of the executed engagement letter and advance fee. Rush turnaround is available from five business days. Complex multi-phase or multi-program engagements require additional time and are scoped individually in the engagement letter.
How does the methodology differ across SBA, USDA, conventional, CMBS, life-co, and agency multifamily?
The analytical pillars are identical across programs. The calibration changes. SBA 7(a) and SBA 504 require explicit conformity to SOP 50 10 8 documentation and job-creation logic. USDA B&I and Community Facilities require the structure prescribed by 7 CFR Part 5001 and Rural Development field-office practice. CMBS conduit requires reconciliation to KBRA, S&P, Fitch, Moody's, and DBRS Morningstar published criteria. Life insurance requires the in-place stress framework of the underwriting desk. Agency multifamily requires NCHMA Model Content Standards and Fannie Mae or Freddie Mac DUS-equivalent documentation. The same report serves multiple programs because the framework is built to the strictest of them.
Do multifamily and senior housing studies conform to NCHMA Model Content Standards?
Yes. Every multifamily and senior housing engagement is produced to NCHMA Model Content Standards as published in September 2025, including PMA definition methodology, comp-set selection criteria, capture and penetration analysis, rent positioning, and the prescribed exhibit set. The same standards are applied whether the capital source is HUD, agency multifamily, conventional bank, or USDA Rural Development.
How is DSCR tested across multiple capital sources in one report?
The financial projections pillar runs the same NOI build through the published DSCR threshold for each capital source the sponsor may approach, including SBA 7(a), SBA 504, USDA B&I, USDA Community Facilities, conventional bank, CMBS conduit, life insurance company, agency multifamily, and bridge lenders where applicable. Each threshold is tested in parallel, returned as a pass or fail against the projected NOI, and re-tested under the sensitivity framework. The lender reading the report can see the deal's position against every capital source the sponsor might pivot to.
How is the primary market area defined, and why does it matter?
PMA definition is the single most consequential methodological choice in any market analysis. The practice defines the PMA by drive-time, radius, or political boundary depending on the asset class, the local geography, and the lender's published expectations. Hospitality typically uses a competitive-set-derived market, multifamily and senior housing follow NCHMA radius or drive-time conventions, self-storage applies the concentric Radius Study methodology, and retail and food service rely on trade-area analysis calibrated to drive-time and foot-traffic data. The PMA definition is justified in the report and stress-tested against alternative boundaries.
Lets Discuss Your Project
Every project has its own program, lender, and documentation context. Book a working session and we will review the site, the comparable set, and the lender requirements together. No prepared pitch, no obligation.
Engagements are led by Michal Mohelsky, J.D., Practicing Affiliate of the Appraisal Institute. Feasibility studies are prepared under USPAP discipline, aligned with SBA SOP 50 10 8 for 7(a) and 504 loans and with 7 CFR Part 5001, Appendix A to Subpart D for USDA Business and Industry, REAP, and Community Facilities financing. Engagements start at $4,900 with fixed-fee scoping. Standard delivery is 9 to 16 business days, with rush turnaround available from 5 days. A senior analyst responds to proposal requests within 12 business hours from the firm's San Francisco office at 27 Maiden Lane, Suite 625.