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The Chicago 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 22, 20268 minute read

Summary

Chicago 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 Chicago metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the Chicago feasibility study hub.

8 minute read.

Data as of June 2026. This companion research post carries the full structural and capital-markets detail behind the Chicago feasibility study hub. Every figure traces to a primary source named in the Sources list. MMCG's city briefs use primary and FOIA sources and do not carry commercial rent, vacancy or occupancy figures.

The structural variables that reset Chicago underwriting

Chicago 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.

Cook County classified property tax. Illinois values property at 33 1/3 percent of fair cash value in every county except counties over 200,000 inhabitants that classify property (35 ILCS 200/9-145). Cook County uses that exception: by ordinance it assesses residential property at 10 percent of market value but commercial and industrial property at 25 percent, then the state applies an equalization multiplier. The Assessor reassesses one third of the county each year on a three-year triennial cycle. Commercial and industrial parcels thus carry 2.5 times the residential assessment ratio, a Chicago tax loading no national underwriting template reflects.

Lake Michigan water diversion cap. Under U.S. Supreme Court consent decrees in Wisconsin v. Illinois (1967, amended 1980), Illinois' diversion of Lake Michigan water is capped at 3,200 cubic feet per second on a 40 year running average, administered by the Illinois Department of Natural Resources. Every municipality and large user must hold an IDNR allocation permit under the Level of Lake Michigan Act, and the agency reviews and reallocates permits roughly every ten years. A project's water source and permitted allocation become a genuine feasibility constraint in this region, unlike metros drawing on legally unconstrained supply.

The nation's rail and intermodal freight hub (CREATE). The U.S. Department of Transportation records that in Chicago six of the seven Class I freight railroads converge and nearly a quarter of the nation's rail shipments arrive or pass through the region, the world's third busiest intermodal hub, covering about 16,000 acres. The federal and state CREATE program (Chicago Region Environmental and Transportation Efficiency), joining USDOT, Illinois, Cook County, Chicago and the railroads, is delivering roughly 70 rail and highway projects to relieve congestion. Industrial, warehouse and intermodal deals here rest on rail infrastructure and access no other metro matches.

Illinois flat-rate income tax regime. The Illinois Department of Revenue sets the individual income tax at a flat 4.95 percent of net income (effective July 1, 2017), with corporations at 7 percent and trusts and estates at 4.95 percent. Every earner faces the same marginal rate, and Illinois municipalities impose no local income tax on wages. For SBA and USDA files this makes owner and guarantor after-tax income simple to model on the Illinois side, while the Indiana portion of the same metro sits under a separate state income-tax regime, so cross-border pipelines need two models.

Multi-state metro (Illinois and Indiana). The federal statistical definition of the Chicago metro crosses a state line. The U.S. Bureau of Labor Statistics reports that the Chicago-Naperville-Elgin metropolitan area includes nine Illinois counties and, in Indiana, Jasper, Lake, Newton and Porter counties. A deal in those Indiana counties falls under Indiana's property-tax caps, income tax and business incentives rather than Illinois' rules. Underwriting a single Chicago-area pipeline therefore requires two separate state frameworks for property assessment, taxation and regulation, a structural split that a one-state national template silently ignores.

Chicago 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 Chicago metro cut below is computed in-house from the SBA 7(a) and 504 FOIA release by county membership across the Chicago-Naperville-Elgin, IL-IN Metropolitan Statistical Area, never read from an SBA district total.

In fiscal year 2025 the Chicago metro recorded 2,532 7(a) approvals for $1,152,626,500 and 258 504 approvals for $280,586,000, filed largely through the ILLINOIS DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were The Huntington National Bank (685 loans); Northeast Bank (285 loans); U.S. Bank, National Association (178 loans); Newtek Bank, National Association (127 loans); JPMorgan Chase Bank, National Association (96 loans); Byline Bank (87 loans); Readycap Lending, LLC (74 loans); Lendistry SBLC, LLC (71 loans). The most active 504 Certified Development Companies were Small Business Growth Corporation (145 loans, $134,929,000); SomerCor 504, Inc. (91 loans, $124,338,000); Regional Development Company (19 loans, $18,534,000); Indiana Statewide Certified Development Corporation (3 loans, $2,785,000).

SBA 7(a) and 504 lending in the Chicago 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 motels266$684,174,9003.5%80$148,154,000cohort under 30
Car washes114$156,507,5006.2%71$62,596,0005.1%
Self-storage32$62,941,900cohort under 3024$25,662,000cohort under 30
RV parks and campgroundsunder 5under 5
Assisted living and continuing care10$23,262,800cohort under 30under 5
Gas stations and convenience stores260$287,144,50010.9%36$31,966,000cohort under 30
Restaurants, full and limited service1,694$890,157,90012.3%292$198,248,0001.7%
Fitness and recreational sports centers399$183,016,60013.8%54$55,900,000cohort under 30
Marinas8$5,625,000cohort under 30under 5
Child day care services369$273,706,3003.8%100$69,696,0000.0%
All ten asset classes in this table3,152$2,566,537,40010.4%660$594,345,0004.3%

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.

USDA eligibility geometry in the Chicago region

For USDA Business and Industry and related guaranteed loans, eligibility is limited to rural areas. The definition 7 CFR Part 5001 implements provides that rural means any area other than a city or town of more than 50,000 inhabitants and any urbanized area contiguous and adjacent to it (7 U.S.C. 1991(a)(13)(A)). Chicago's core is urban, but the metro's outer Illinois counties (Grundy, Kendall, DeKalb, McHenry, Kane) hold many communities far below that threshold; MMCG verifies eligibility at the subject address on the USDA eligibility map at intake.

A note on what this post does not claim

A Chicago market piece would ordinarily carry submarket rents, vacancy and absorption. Those come from commercial market reports, which MMCG's city briefs do not carry, so they are omitted rather than shown on a weaker source. What remains is the statute, the federal program frame and the SBA record computed from the primary file, which is the part of a Chicago study a lender can check.

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. Cook County Clerk (2023 Tax Rate Report); corroborated by Illinois Department of Revenue and 35 ILCS 200/9-145
  5. Illinois Department of Natural Resources (Office of Water Resources)
  6. U.S. Department of Transportation, Federal Highway Administration (Project Profiles: CREATE)
  7. Illinois Department of Revenue (Income Tax Rates)
  8. U.S. Bureau of Labor Statistics (Midwest Information Office)
  9. USDA rural-area definition per 7 U.S.C. 1991(a)(13)(A) implemented by 7 CFR Part 5001 (GPO/govinfo)
Michal Mohelsky, J.D., Principal of MMCG Invest

Cite this

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

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