An office feasibility study answers two questions a lender cannot settle from a national headline. First, which segment of the office market does the subject building compete in, because the gap between a 6 percent and a 20 percent vacancy rate is a question of building class, building size and market, not of timing. Second, does the project service its debt at the program's DSCR hurdle under the occupancy, equity and eligibility rules that apply to it, whether that is SBA 7(a) or 504, USDA Business and Industry or Community Facilities, or a conventional construction loan.
MMCG Invest prepares office feasibility studies for borrowers, developers and lenders nationwide. Every study is signed by the firm, prepared under USPAP discipline, and built around the exhibits a credit committee reads: a DSCR schedule by year, a break-even occupancy test, a net effective rent derivation, a tenant improvement and leasing commission reserve, a rollover map and a replacement reserve. The study places the subject in its correct competitive set before any of that arithmetic begins.
Which office project is yours
Office is not one asset class for lending purposes. The rules and the market data split by use, and so do our pages.
| Project | Lender path | Page |
|---|---|---|
| Physician, dental, veterinary or specialty clinic; medical office building; rural health clinic or FQHC | SBA 504 and 7(a) through an EPC/OC structure; USDA Community Facilities for nonprofit and public clinics; USDA B&I for for-profit rural clinics; conventional and health system ground leases | Medical Office and Clinic Feasibility Study |
| Law, accounting, engineering, insurance or other professional firm buying or building its own office | SBA 504 and 7(a) under the 51 percent and 60 percent occupancy rules | SBA Owner-Occupied Office Building Feasibility Study |
| Coworking, flex office, executive suites, rural innovation hub | SBA only for a membership-only model; USDA grants to a public or nonprofit sponsor; landlord management agreements | Coworking and Flex Office Feasibility Study |
| Office to residential, office to hotel, office to owner-occupied medical, adaptive reuse | Construction lenders, HUD 221(d)(4), municipal abatements and TIF, historic tax credits; SBA for operating-business conversions | Office Conversion and Adaptive Reuse Feasibility Study |
| Multi-tenant office, new construction or repositioning, in a rural area | USDA B&I lease facility under 7 CFR 5001.105(b)(12), subject to the control and speculation tests below | This page, rural USDA section |
| Multi-tenant office, new construction or repositioning, in a metro area | Conventional, life company, CMBS, debt funds; SBA does not apply | This page |
Why national office vacancy is not your vacancy
The two numbers a lender sees most often describe different buildings. CoStar's Office National Report dated October 4, 2026 puts national office vacancy at 13.8 percent. Cushman and Wakefield's second quarter 2026 report puts it at 20.1 percent. Neither is wrong. CoStar's published methodology counts office buildings of every class and size, single-tenant and multi-tenant, including owner-occupied buildings. Cushman and Wakefield's national MarketBeat defines inventory as space in buildings above a size threshold set market by market that can be rented by a third party, and states that owner-occupied and federally owned buildings are generally not included. The broker figure describes the competitive multi-tenant market. The CoStar figure describes the whole stock.
For an SBA or USDA office borrower this distinction is the study. The owner-occupied share of a building sits inside CoStar's denominator and is, by definition, occupied. The leased share competes in the third-party market the brokers measure. A study that applies one blended vacancy figure to both shares is wrong in both directions.
Within CoStar's figure, the segments diverge sharply. The same report shows 4 and 5 Star buildings at 20.3 percent vacancy, 3 Star at 12.3 percent, and 1 and 2 Star at 6.2 percent. Small markets run far below gateways: Lebanon, Pennsylvania at 1.7 percent, Kenosha at 2.1 percent, Hickory at 2.4 percent and Gainesville at 3.3 percent, against San Francisco at 20.2 percent, Houston at 19.4 percent, Denver at 17.9 percent, Washington at 17.5 percent and Chicago at 17.1 percent. Distress is concentrated rather than general. CoStar reports that buildings at least 25 percent vacant now hold 80 percent of all vacant office space. Cushman and Wakefield's June 2024 Mid-Year Macro Outlook found the bottom 10 percent of office assets account for more than 730 basis points of national vacancy, and that 30 percent of Class A buildings have essentially no vacancy. The 20 percent headline is mostly the problem of buildings an owner-user borrower will never compete with.
Distress is still real where it sits. Trepp reported the office CMBS delinquency rate at 11.91 percent in July 2026. A study for a metro multi-tenant building has to work at the submarket and building-class level, because the national figure averages two markets that no longer behave alike.
The office market in October 2026
The figures below are from the CoStar Office National Report dated October 4, 2026, licensed to MMCG Invest, unless another source is named. They are the baseline MMCG uses in every office study, refreshed to the subject's market and submarket at engagement.
Demand has turned. Net absorption over the trailing twelve months was 15.7 million square feet, positive for four consecutive quarters, closing a five-year period in which occupancy losses totaled nearly 250 million square feet, about 3 percent of inventory. New leasing volume in the first half of 2026 was about 220 million square feet, near pre-pandemic averages, and the number of lease deals was the highest in a decade. The average deal is about 15 percent smaller than in the late 2010s. The recovery has a narrow geographic base: financial services in New York, Dallas and Charlotte, and AI-related leasing in San Francisco, San Jose and New York, while Atlanta, Chicago, Los Angeles, Seattle and Washington remain depressed.
Supply is shrinking. Deliveries were 22.6 million square feet over twelve months. The construction pipeline is 47.6 million square feet, close to the lowest level on record and below the early 2011 trough. Demolitions have averaged more than 9 million square feet per quarter for eleven quarters and exceeded deliveries over the past year. CoStar projects that inventory could contract by as much as 1 percent by the end of the decade. For an owner-user building this is the most useful fact in the report: little new competitive supply is coming.
Rents and concessions. National asking rent is $37.85 per square foot, up 2.0 percent year over year; 4 and 5 Star asking rent is $50.70, 3 Star $32.81 and 1 and 2 Star $27.30. Effective rents sit well below asking. CoStar reports that concessions of one month of free rent per year of lease term are now common, against one month per two years in the late 2010s, and that tenant improvement allowances for first-generation shell space have increased by as much as 50 percent, typically against commitments of ten years or more. Since the beginning of 2024, more than 80 percent of leases under 10,000 square feet in institutional-grade buildings have been for move-in-ready spec suites on terms of 3 to 7 years.
Pricing. The national market cap rate is 8.7 percent (4 and 5 Star 8.1 percent, 3 Star 8.9 percent, 1 and 2 Star 9.4 percent). Market price is $279.66 per square foot nationally and $193.54 per square foot for 1 and 2 Star buildings. Trailing sales volume was $60.1 billion, up 31 percent year over year in July, with private investors making about half of all transactions and owner-users about 20 percent.
Employment behind the demand. Education and Health Services employment is growing 1.87 percent against total employment growth of 0.43 percent, while Information is contracting 2.81 percent and Financial Activities 0.87 percent (Oxford Economics data reported by CoStar). The office users that serve local populations, medical practices, professional firms and insurance agencies, have demand drivers unlike the technology and finance tenants behind gateway vacancy.
What a lender-grade office study contains
The exhibits are the study. Every figure in the narrative traces to a workbook cell, and the workbook is delivered with the report.
Segment placement. The subject is placed by class, size, submarket and tenancy against the matching competitive set, with the owner-occupied share and the leased share benchmarked separately.
Two-population underwriting. The owner-occupied share is underwritten on the operating company's cash flow, with the rent the company pays its real estate holding entity treated as debt service coverage rather than market income. The leased share is underwritten at multi-tenant vacancy and credit loss for its class and market, at net effective rent, with tenant improvement and leasing commission reserves at each rollover.
Net effective rent. Free rent is spread across the lease term. At one month free per year of term, a five-year lease loses 5 of 60 months, or about 8.3 percent of face rent, before any tenant improvement cost. Spec suite delivery on 3 to 7 year terms shortens the rollover interval and raises the reserve.
DSCR by year. Coverage is reported for every projection year, not only the stabilized year, against the hurdle the program applies. For USDA loans the ratio follows the 7 CFR 5001.3 definition: EBITDA less reasonably expected replacement capital expenditures, divided by annual debt service, which means the pro forma carries a replacement reserve line supported by the property condition report.
Break-even occupancy. Operating expenses plus debt service, divided by potential gross income, shown for the whole building and for the leased share alone.
Rollover map. Each third-party lease expiry mapped against the loan term, with any year in which more than one third of leased income rolls over flagged and reserved.
Equity sufficiency. Tested against the SBA injection for the structure and, for USDA, against Table 1 to 7 CFR 5001.105(d), with pro forma ratios compared with the RMA Annual Statement Studies median quartile where an equity reduction is sought under 5001.105(d)(5)(ii).
Construction cost verification. Project costs are verified against contractor bids and a third-party cost review for the subject project. MMCG does not publish a generic cost per square foot table for office, because the public ranges in circulation are contractor marketing rather than cost data.
The method is set out in full in MMCG's feasibility study methodology.
Program rules at a glance
Each rule below carries its citation and a verification status. "Verified" means the text was read in the Code of Federal Regulations. "Reported" means the figure comes from lender and practitioner summaries of SOP 50 10 8.1 and has not yet been checked against SBA's own text.
SBA 7(a) and 504
- The SBA feasibility study is discretionary. 13 CFR 120.160(b) states that SBA may require professional appraisals, a survey or a feasibility study. There is no rule that requires one for office. Lenders order a study when repayment depends on projections: start-up firms, new construction, a change of use, or a leased share that must absorb. Verified.
- Occupancy, existing building: the borrower must permanently occupy and use no less than 51 percent of the rentable property and may permanently lease up to 49 percent. 13 CFR 120.131(b). Verified.
- Occupancy, new construction: the borrower must permanently occupy and use no less than 60 percent, may permanently lease up to 20 percent, and must plan to occupy some of the remaining space within three years and all of it within ten. 13 CFR 120.131(a). Verified.
- Eligible Passive Company: the real estate may be held by an EPC that leases to one or more Operating Companies under a written lease with a remaining term at least equal to the loan term, with the Operating Company as guarantor. 13 CFR 120.111. Verified.
- Passive real estate: businesses primarily engaged in owning real estate and leasing it are ineligible, so speculative multi-tenant office, investment office and apartment conversions sit outside SBA. 13 CFR 120.110(c). Verified.
- SOP 50 10 8.1 with Technical Updates applies to loans receiving an SBA loan number on or after October 1, 2026, issued under Information Notice 5000-880695 (August 14, 2026) and superseded by Information Notice 5000-882227 (September 25, 2026). Verified on SBA's document page.
- DSCR under SOP 50 10 8.1: 1.25x on historical cash flow for initial acquisitions, owner buyouts and ESOP transactions under Appendix 15, with projections not relied on; 1.15x for business expansions; 1.10x for 7(a) Small Loans. Reported. For a pure owner-occupied office purchase with no business acquisition, Appendix 15 does not apply and the general 7(a) or 504 cash flow test governs.
USDA Business and Industry
- Eligible purposes include the purchase and development of land and buildings for private commercial enterprises, 7 CFR 5001.105(b)(1); business acquisitions, start-ups and expansions if jobs will be created or saved, (b)(2); constructing or equipping facilities for lease to private businesses engaged in commercial or industrial operations, (b)(12); mixed-use properties where not less than 50 percent of projected revenue comes from business use, (b)(13); and leasehold improvements where the lease term equals or exceeds the loan term, (b)(14). Verified.
- Ineligible: any speculative real estate investment, 5001.115(a); properties used primarily for commercial rental when the borrower has no control over tenants and services offered, 5001.115(g); buildings primarily for housing federal, state or quasi-federal agencies unless typical of the area, 5001.115(j); apartments and other residential housing where the primary purpose is independent housing, 5001.118(a). Verified.
- A feasibility study by an independent qualified consultant acceptable to the Agency is required for guaranteed loans greater than $1,000,000 to a new business. 7 CFR 5001.306(a)(3)(i). Verified.
- Equity, Table 1 to 5001.105(d): existing businesses 10 percent balance sheet equity or a 10 percent investment; new businesses 20 percent balance sheet equity or a 25 percent project investment; 25 percent where the guarantee is requested before construction is complete. The Agency may raise the requirement based partly on the strength of the feasibility study, 5001.105(d)(5)(i). Verified.
- DSCR is EBITDA less reasonably expected replacement capital expenditures, divided by annual debt service, 7 CFR 5001.3. Refinancing requires a historical DSCR of not less than 1.1 times, 5001.102(d)(4)(iii). Verified.
USDA Community Facilities
- Essential community facilities include health care, 7 CFR 5001.3. Inherently commercial enterprises are ineligible, with a carve-out for nonprofit health care, 5001.116(b). Space leased to ineligible users must stay under 25 percent of floor space, 5001.103. An independent feasibility study is required for guaranteed loans greater than $1,000,000 to a new entity or an entity conducting a new activity, and the Agency may require one below that threshold, 7 CFR 5001.304(a)(4)(i) and (ii). Verified.
Rural office under USDA
USDA will finance a rural office building that SBA will not, and the line it draws is control and purpose rather than tenancy. Four provisions set the boundary. 7 CFR 5001.105(b)(12) makes facilities for lease to private commercial businesses an eligible purpose. 5001.115(a) bars any speculative real estate investment. 5001.115(g) bars property used primarily for commercial rental where the borrower has no control over tenants and the services offered. 5001.126(a)(1) allows leases where they are customary practice and provide for the borrower's management control of the project. Read together, a rural multi-tenant office or lease facility qualifies when the borrower selects and controls its tenants, the tenants are identified private commercial businesses, ideally under pre-leases, and the project's purpose is job creation in the community rather than passive yield. The regulation does not define "speculative," so the determination is the State office's, and a feasibility study carries the pre-leasing and absorption evidence that supports it.
Three cautions follow from the text. A building leased mainly to government agencies falls under 5001.115(j). Equity for a new business rises to 20 percent of the balance sheet or 25 percent of project cost, and to 25 percent where the guarantee is requested before construction completes. And a guaranteed loan above $1,000,000 to a new business requires the independent study under 5001.306(a)(3)(i), with scope set by the Agency.
Two further USDA routes apply to rural office. Community Facilities finances clinics, rural health clinics and FQHCs owned by nonprofits and public bodies, and has funded office buildings converted to clinic use; that material sits on the medical office page. Rural Business Development Grants and Rural Innovation Stronger Economy grants fund coworking spaces, incubators and innovation hubs through public and nonprofit sponsors; that material sits on the coworking page. The Rural Energy for America Program finances energy efficiency improvements to an existing rural office building where the project will use less energy on an annual basis than the original building and sits in a rural area, 7 CFR 5001.107, with an energy assessment by a qualified auditor above $80,000 of project cost; 5001.122(n) expressly permits a REAP applicant to lease the improved building to tenants.
MMCG has not located a published USDA B&I guarantee for a multi-tenant office project. The eligibility analysis above rests on the regulation text, not on precedent, and a study prepared for a rural office project states that.
Rules that circulating pages get wrong
The office lending pages that rank for these searches repeat several errors. A study prepared on them fails at credit committee.
- SBA 504 new construction does not require the borrower to occupy 80 percent within two years. The rule is 60 percent at the outset, with some of the remaining space occupied within three years and all of it within ten. 13 CFR 120.131(a).
- SBA 504 cannot finance investment property. The occupancy rules in 13 CFR 120.131 apply to every 504 real estate loan, and passive real estate businesses are ineligible under 13 CFR 120.110(c).
- The 51 percent test is "no less than 51 percent," not "more than 51 percent." 13 CFR 120.131(b).
- SBA does not require a feasibility study for an office loan. 13 CFR 120.160(b) says SBA may require one. Pages that describe a study as mandatory under SOP 50 10 8.1 for special-use property overstate the regulation.
- A USDA Community Facilities feasibility study is not mandatory in every case. It is required above $1,000,000 for a new entity or an entity conducting a new activity, and discretionary otherwise. 7 CFR 5001.304(a)(4).
- A USDA Community Facilities grant has no regulatory maximum. The $150,000 figure that circulates is a cap on a specific set-aside, not on the program (Congressional Research Service, R48462).
- National office vacancy of about 20 percent is a multi-tenant, larger-building figure. It is not the vacancy of a 12,000 square foot professional building in a county seat.
Fees, turnaround and what the lender receives
Office feasibility studies start at $4,900, fixed fee quoted at proposal stage. Standard delivery is 9 to 16 business days, with rush turnaround from 5 business days. A senior analyst responds to proposal requests within 12 business hours.
The lender receives a signed report with the exhibit workbook: market and segment placement, competitive set and lease comparables, demand analysis, the pro forma with DSCR by year, break-even occupancy, sensitivities, and the conditions under which the determination holds. Where a program's independence requirement applies, as it does for USDA under 7 CFR 5001.306 and 5001.304, the study is prepared and signed as an independent consultant's report.
Frequently asked questions
Is a feasibility study required for an SBA office loan?
No. 13 CFR 120.160(b) makes the study discretionary. Lenders order one when the loan is repaid from projections rather than history: a start-up firm, new construction, a change of use, or a building with a leased share that has to absorb.
When does USDA require one?
For a B&I guaranteed loan greater than $1,000,000 to a new business, 7 CFR 5001.306(a)(3)(i), and for a Community Facilities guaranteed loan greater than $1,000,000 to a new entity or an entity conducting a new activity, 7 CFR 5001.304(a)(4)(i). The Agency may require one in other cases.
Can I lease part of the building I buy with an SBA loan?
Yes. Up to 49 percent of an existing building and, on a declining schedule, up to 40 percent of new construction. The study underwrites the leased share as multi-tenant space.
Which vacancy figure does the study use?
The one that matches the space the subject competes for. The owner-occupied share is benchmarked against the whole stock for its class and market; the leased share is benchmarked against the third-party rentable market.
Does USDA finance office buildings?
B&I can finance a rural lease facility for private commercial tenants under 7 CFR 5001.105(b)(12), subject to the speculation and control tests in 5001.115. Community Facilities finances clinic buildings for nonprofit and public owners. Neither finances apartments.
What about coworking?
Only a membership-only model with no assigned or lockable space passes the SBA office suites test. The coworking page sets out the six-question test and the USDA sponsor route.
Start a study
Michal Mohelsky, J.D., FMVA, Practicing Affiliate of the Appraisal Institute, Principal in charge. MMCG Invest, LLC, 27 Maiden Lane, Suite 625, San Francisco, CA 94108. (628) 225-1110. michal@mmcginvest.com. Book a 30-minute scoping call or send the five-question quick start.
Sources: CoStar Office National Report, United States, October 4, 2026 (licensed to MMCG Invest); Cushman and Wakefield, U.S. National Office MarketBeat, Q1 and Q2 2026, and Mid-Year Macro Outlook, June 2024; Trepp CMBS Delinquency Report, July 2026; 13 CFR 120.110, 120.111, 120.131 and 120.160; 7 CFR Part 5001 (current through October 1, 2026); SBA Information Notices 5000-880695 and 5000-882227; Congressional Research Service R48462.
Where we work
The same study, prepared to the lender requirements of the state the project sits in.
What a study costs
Research on office
- NeueHouse’s Sudden Closure: A Coworking Club’s Rise, Fall, and Industry Reckoning
- US Medical Office Market Outlook 2026: Full Waiting Rooms, Empty Pipelines
- CMBS Office Case Study: From “Safe Asset” to a $257 Million Loss, 229 W 43rd St (Times Square)
- San Francisco’s Big Bet on Turning Empty Offices Into Homes
