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The Baltimore Feasibility Market: SBA, USDA and Its Structural Variables

Michal Mohelsky, J.D., Principal of MMCG InvestMichal Mohelsky, J.D., FMVA, Practicing Affiliate of the Appraisal InstitutePublished September 23, 20268 minute read

Summary

Baltimore underwrites outside a national template on a set of statute and government rooted structural variables. This research post carries each at the level a primary source supports, plus the USDA eligibility line and the Baltimore metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the Baltimore feasibility study hub.

8 minute read.

Data as of June 2026. This companion research post carries the full structural, market and capital-markets detail behind the Baltimore feasibility study hub. Every figure traces to a primary source named in the Sources list. Statutes, ordinances, tax rates, population and the SBA record come from government publishers. The market layer comes from a research report the publisher has put on a public page, named in the sentence that carries it.

The structural variables that reset Baltimore underwriting

Baltimore carries its own set of statute and government rooted variables that redefine the underwriting envelope for a commercial real estate, SBA or USDA feasibility study. Each is stated here at the level a primary source supports.

The real property tax step at the Baltimore city line. Maryland sets real property tax rates jurisdiction by jurisdiction, and the State Department of Assessments and Taxation publishes them in one table each August. Its 2026-2027 table, in effect for July 1, 2026 tax bills, puts the county real property rate at 2.2480 for Baltimore City, 1.1000 for Baltimore County, 1.0440 for Howard, 1.0180 for Carroll, 0.9779 for Harford, 0.9680 for Anne Arundel and 0.8000 for Queen Anne's, with the state rate of 0.1120 added to every one of them. Baltimore city and Baltimore County are separate jurisdictions with separate rates, and the city carries the highest of the seven member jurisdictions of this metro. The gap widens on business personal property, which Maryland counties tax and the state does not: the same table gives 5.6200 for Baltimore City against 2.7500 for Baltimore County and 2.4200 for Anne Arundel. The city's own Bureau of the Budget and Management Research states the Fiscal 2027 rates as $2.248 per $100 of assessed value on real property and $5.62 per $100 on personal property, and lists Special Benefits District surcharges that sit on top of that bill, including $0.2239 for the Downtown Management Authority and $0.1700 for the Waterfront Partnership. In a feasibility study the operating expense line, the equipment assumption and the choice between a city site and a county site an hour apart all turn on which of these figures applies.

The local income tax is set by the county the worker lives in. Maryland Code, Tax - General Article, Section 10-103 gives each county a county income tax on the Maryland taxable income of each resident who, on the last day of the taxable year, is domiciled in the county or maintains a principal residence or a place of abode in the county. The same section bars a county, municipal corporation, special taxing district or other political subdivision from imposing any other general local income, earnings or payroll tax, occupational licence tax, or licence or permit tax based on income, earnings or gross receipts. So Maryland has no Philadelphia-style wage tax on the work site: the rate follows the worker home. The Comptroller of Maryland's Central Payroll Bureau publishes the rates as a Percentage of MD Taxable Wage against the City or County of Residence. For 2026 it gives Baltimore County 3.20, Baltimore City 3.20, Howard County 3.20 and Queen Anne's County 3.20, Harford County 3.06 and Carroll County 3.03, while Anne Arundel County is bracketed rather than flat: 2.70, then 2.94, then 3.20 for single, married filing separately or dependent taxpayers. Employees who file no certificate default to the highest local rate, 3.30%, and a non-Maryland resident is withheld at a Nonresident rate that includes a Special 2.25% Nonresident rate. For a study this bears on the household income of the catchment rather than on the project's own tax line, and it means a labour-shed crossing several county lines does not carry one rate.

The Chesapeake Bay Critical Area, a statutory 1,000 foot band on tidal frontage. Maryland Code, Natural Resources Article, Section 8-1807 sets the planning area for the Chesapeake Bay Critical Area as the waters and lands under the Bay and its tributaries to the head of tide, the State and private wetlands, and all land and water areas within 1,000 feet beyond the landward boundaries of those wetlands and the heads of tides. The Department of Natural Resources Critical Area Commission states that land inside the Critical Area is assigned one of three classifications. Inside a Resource Conservation Area, which the Commission says makes up approximately 80% of the Critical Area, new development is limited to residential uses and uses associated with resource utilization activities, new commercial, industrial and institutional uses are in general not permitted, residential density is limited to one dwelling unit per 20 acres and lot coverage is generally limited to 15% of the parcel or lot. Programmes are run locally: the Commission's own list of Critical Area planning and zoning offices names Anne Arundel County, Baltimore City, Baltimore County, Harford County and Queen Anne's County, five of this metro's seven member jurisdictions. A site search in this metro therefore has a statutory band along its tidal edge in which the use itself, not just the density, may be barred, and MMCG settles the classification with the local programme before a site is carried into a study.

Ground rent, a leasehold layer under Baltimore City title. Maryland still carries colonial-era ground rent. The Department of Housing and Community Development describes a ground lease as a lease for a term of years, usually 99 years, that is renewable forever and is subject to the periodic payment of ground rent by the leasehold tenant to the ground lease holder, and states that ground rents are most prevalent in Baltimore City but are held in some other counties as well. The state fixes the buy out price by dividing the annual ground rent by a capitalisation rate keyed to the year the lease was created, and a lease originally labelled irredeemable becomes redeemable unless the holder files a Notice of Intention to Preserve Irredeemability in the land records every 10 years. Maryland Code, Real Property Article, Section 8-703 requires the Department of Assessments and Taxation to maintain an online registry of all properties subject to ground leases and to note the expiration date of each irredeemability renewal notice, and Section 8-707 provides that if a ground lease is not registered the holder may not collect or attempt to collect ground rent, late fees, interest or collection costs and may not bring a civil action against the leasehold tenant. For a Baltimore City project this is a title question, not a market one: whether the collateral is fee simple or leasehold, and what the redemption cost is, has to be settled at intake rather than assumed.

Baltimore SBA capital markets, computed from the FOIA file

Nationally, the U.S. Small Business Administration closed fiscal year 2025 having guaranteed 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. The Baltimore metro cut below is computed in-house from the SBA 7(a) and 504 FOIA release by county membership across the Baltimore-Columbia-Towson, MD Metropolitan Statistical Area, never read from an SBA district total.

In fiscal year 2025 the Baltimore metro recorded 699 7(a) approvals for $233,853,100 and 18 504 approvals for $24,456,000, filed largely through the BALTIMORE DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were Manufacturers and Traders Trust Company (297 loans); Northeast Bank (58 loans); Newtek Bank, National Association (34 loans); Readycap Lending, LLC (30 loans); Celtic Bank Corporation (17 loans); The Huntington National Bank (17 loans); BayFirst National Bank (17 loans); Live Oak Banking Company (16 loans). The most active 504 Certified Development Companies were Business Finance Group, Inc. (9 loans, $10,308,000); Rappahannock Economic Development Corporation (4 loans, $2,724,000); Chesapeake Business Finance Corporation (3 loans, $7,885,000); 504 Capital Corporation (1 loan, $2,925,000); Prince George's Financial Services Corporation (1 loan, $614,000).

SBA 7(a) and 504 lending in the Baltimore MSA by asset class, fiscal years 2010 to 2026 disbursed, computed from the SBA FOIA release (as of June 30, 2026).
Asset class7(a) loans7(a) gross approval7(a) charge-off rate504 loans504 gross approval504 charge-off rate
Hotels and motels37$118,186,000cohort under 307$18,886,000cohort under 30
Car washes33$41,021,200cohort under 30under 5
Self-storage6$9,862,000cohort under 30under 5
RV parks and campgroundsunder 5under 5
Assisted living and continuing care25$22,048,800cohort under 30under 5
Gas stations and convenience stores24$10,698,500cohort under 30under 5
Restaurants, full and limited service440$176,124,10014.4%16$11,578,000cohort under 30
Fitness and recreational sports centers125$48,541,2008.5%under 5
Marinasunder 5under 5
Child day care services109$104,792,9005.5%9$9,129,000cohort under 30
All ten asset classes in this table803$537,461,70010.1%47$56,452,000cohort under 30

Source: U.S. Small Business Administration, 7(a) and 504 FOIA release (label as of June 30, 2026); computed by MMCG from the SBA FOIA loan file. Charge-off rate shown only where the resolved cohort has at least 30 loans; a cell under five loans is suppressed.

What one published market report says about Baltimore

The figure below is cited to the publisher's public page, with the publisher named in the sentence and the report's own source line printed below it. Cushman and Wakefield, MarketBeat Baltimore Industrial Q2 2026, reports a vacancy rate of 9.3% and an asking rent of $10.97 per square foot. The report is Cushman and Wakefield, MarketBeat Baltimore Industrial Q2 2026, covering Q2 2026.

Two qualifications travel with that figure and belong on the page rather than in a footnote. The asset class is industrial, which is NOT one of the ten asset classes counted in this table. Most of this metro's SBA and USDA borrowers are building restaurants, hotels, day care, self-storage, car washes and the like, not industrial space, so this figure describes a different stock and is carried as metro context only. Cushman and Wakefield publishes no retail MarketBeat for this market, which is why the industrial report is the one used. And a metro-level vacancy or rent figure describes the stock a broker tracks, which is not the asset class a single SBA or USDA borrower is building; it sets context for the file and nothing in the file rests on it.

USDA eligibility geometry in the Baltimore region

USDA Business and Industry and Community Facilities credit runs on a statutory geography, not on a county line. Under 7 U.S.C. 1991(a)(13)(A) the terms rural and rural area mean any area other than a city or town that has a population of greater than 50,000 inhabitants and any urbanized area contiguous and adjacent to such a city or town. The urbanized core of this metro, running with Baltimore city and out through the inner parts of Baltimore County, Anne Arundel and Howard, is therefore out. What can remain is the outer parts of the member counties, beyond the urbanized area, and the test turns on the subject address and the urbanized-area boundary around it rather than on the name of the town. MMCG verifies eligibility at the address on the USDA Rural Development eligibility map at intake, before any work on the study begins, and no town is named on this page as eligible on a model's say-so. The 50,000 inhabitant test is the statute's general rule, and the statute sets its own different threshold for community facility DIRECT loans and grants, so a borrower pursuing that programme rather than a guaranteed one is tested against the lower figure. MMCG's work here is for guaranteed lenders, and the address is checked against the programme actually being used.

A note on what this post does not claim

The market figures above are one publisher's reading of one asset class in one quarter, and they are carried because that publisher put them on a public page, not because they settle anything. They are not a substitute for the rent and expense evidence a study builds at the subject address, and this post does not extend them to the asset classes the report does not cover. What carries the weight here is the statute, the federal program frame and the SBA record computed from the primary file, which is the part of a Baltimore study a lender can check line by line.

Sources

  1. U.S. Small Business Administration, News Release 25-83, September 30, 2025
  2. U.S. Small Business Administration, 7(a) and 504 FOIA release (label as of June 30, 2026)
  3. U.S. Census Bureau, Population Estimates Program, Metropolitan and Micropolitan Statistical Areas, vintage 2024
  4. Maryland State Department of Assessments and Taxation; City of Baltimore, Bureau of the Budget and Management Research
  5. Maryland State Department of Assessments and Taxation, Tax Rates (the page that posts the annual table)
  6. City of Baltimore, Bureau of the Budget and Management Research, City Tax Rates (Fiscal 2027)
  7. Maryland General Assembly, Maryland Code, Tax - General Article; Comptroller of Maryland, Central Payroll Bureau
  8. Maryland General Assembly, Maryland Code, Tax - General Article, Section 10-103 (statute text, 2026 Regular Session)
  9. Comptroller of Maryland, Maryland Withholding Tax Facts, January 2026
  10. Maryland General Assembly, Maryland Code, Natural Resources Article; Maryland Department of Natural Resources, Critical Area Commission for the Chesapeake and Atlantic Coastal Bays
  11. Maryland Department of Natural Resources, Critical Area Commission, Background and History (land classifications, IDA, LDA and RCA)
  12. Maryland Department of Natural Resources, Critical Area Commission, Local Government Contacts, Planning and Zoning Offices
  13. Maryland Department of Housing and Community Development; Maryland General Assembly, Maryland Code, Real Property Article
  14. Maryland General Assembly, Maryland Code, Real Property Article, Section 8-707 (unregistered ground lease), statute text, 2026 Regular Session
  15. Maryland General Assembly, Maryland Code, Real Property Article, Section 8-703 (online registry of ground leases), statute text, 2026 Regular Session
  16. Cushman and Wakefield, MarketBeat Baltimore Industrial Q2 2026
  17. U.S. Government Publishing Office, govinfo, 7 U.S.C. 1991 (2024 edition)
Michal Mohelsky, J.D., Principal of MMCG Invest

Cite this

Michal Mohelsky, J.D., FMVA (2026). The Baltimore Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/baltimore-feasibility-market-2026

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