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The Cleveland 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

Cleveland 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 Cleveland metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the Cleveland 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 Cleveland 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 Cleveland underwriting

Cleveland 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.

A regional stormwater fee charged on impervious surface by a court-created district. The Northeast Ohio Regional Sewer District is not a department of any city or county. A court order formed NEORSD in 1972, and its stormwater charge reaches parcels, not water meters. Title V of the District's Code of Regulations, approved July 16 2026 by Resolution No. 116-26, makes impervious surface the parameter: an impervious surface of three thousand (3,000) square feet is one Equivalent Residential Unit, and the base ERU fee is $6.35 per month per ERU effective January 1 2026, moving to $6.60, $6.86, $7.10, $7.35 and $7.61 across the 2027 to 2031 schedule. A Non-Residential Parcel pays for the whole number of ERUs on it, rounded to the next highest ERU. Above the first ten ERUs the Code applies a declining block: the next forty at a 5% discount, the next fifty at 10%, the next one hundred and fifty at 15%, and the remainder at 20%. Stormwater control measures earn credits not to exceed 75% of the fee for quantity and 25% for quality, combinable up to a maximum available credit of 100%. For a feasibility study the recurring charge is set by the site plan, so roof and parking area carry an operating cost a rent roll does not show. And the boundary is the District's own: Title V defines the Stormwater Service Area as all of the District's service area, excluding non-Member Communities and including those non-Member Communities with which the District has entered into an agreement for stormwater-only services. Membership decides whether a site pays, not the county it sits in.

Annual rental registration and an occupancy certificate for every non-owner-occupied unit. Cleveland's Residents First legislation turned rental ownership into an annual licence, and the Department of Building and Housing publishes the conditions. All owners of non-owner-occupied residential properties are required to register; the fee is $70 per unit and covers every property the owner is not living in, including units occupied by family members and friends even where nothing of value changes hands. Registration repeats each year with new documents, fees are due by March 31st, and the Certificate Approving Rental Occupancy is issued only once the file is complete. The file is the underwriting item. A Lead Safe Certificate issued by the City of Cleveland is required for rental units built before 1978. An HVAC certificate or inspection is required for rental properties with four or more units, and for buildings with individual systems per unit the city requires 10% of the HVAC systems to be inspected, with a minimum of five units inspected. An owner who is not located in Cuyahoga, Summit, Lake, Portage, Medina, Lorain or Geauga County must supply a Local Agent in Charge, and the affidavit must be notarized. That seven-county list is the city's own and is not the metro definition: it takes in Summit and Portage and leaves out Ashtabula, so an out-of-area sponsor carries a named local agent as a condition of renting in good standing.

City financial assistance carries a binding community benefits agreement. Cleveland's Community Benefits Ordinance passed City Council in June of 2023 and took effect in September of 2023, and the Mayor's Office of Equal Opportunity publishes the thresholds that trigger it. A Standard CBA is for all projects receiving $250,000 or more in City assistance and under $20 million in cost, including residential tax abatements for projects under $75 million in total cost, and the ordinance sets a list of mandatory community benefits for it. An Expanded CBA is for all projects receiving $250,000 or more in City assistance with a project cost of over $20 million, including residential tax abatement projects over $75 million in total cost, and it must carry additional community benefits to be considered for legislative approval. The Office answers the mandatory question directly: a CBA is required whenever a Developer is awarded a city financial incentive that equals $250,000 or more. Two consequences matter in a feasibility study for this metro. First, the trigger is the incentive, not the project. The Office defines City Financial Assistance as any grant, loan, tax increment financing, residential multi-family tax abatement in compliance with Ordinance No. 482-2022, Section 3, below market-value land transfer, and/or City-funded capital infrastructure improvements associated with a development project, so a TIF or an abatement counts as readily as a cheque. Second, the CBA is a legally enforceable agreement with quarterly report-back obligations, so compliance work continues after closing.

A city wage floor that attaches to a service contract or to city assistance. Cleveland runs its own wage floor under the Cleveland Fair Employment Law, and the city's notice to covered employees states the rate: the Living Wage / Fair Employment Wage Rate is $16.26 per hour. The notice also states who is caught. A person employed by a for-profit contractor or subcontractor on one or more City Service Contracts with an aggregate value of at least twenty-five thousand dollars ($25,000.00) is a Covered Employee unless an exemption has been granted. So is a person employed by a Covered Employer who is a Recipient of Assistance with an aggregate value of at least seventy-five thousand dollars ($75,000.00). The city states that failure to comply may result in termination of a contract as well as disqualification from future contract opportunities or access to financial assistance with the City of Cleveland. The carve outs decide which borrowers this touches. The notice excludes an individual employed in public construction work subject to state or federal prevailing wage law, employees covered by a collective bargaining agreement, employees of commercial retail establishments, employees of residential single and multi-family housing projects, and persons who on average work less than thirty hours per week. A service operator taking a city incentive is therefore inside the law while an apartment project is not, and a staffing model built on the state minimum will be wrong for the first case.

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

In fiscal year 2025 the Cleveland metro recorded 702 7(a) approvals for $240,019,400 and 24 504 approvals for $26,373,000, filed largely through the COLUMBUS DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were The Huntington National Bank (397 loans); U.S. Bank, National Association (48 loans); KeyBank National Association (32 loans); Northeast Bank (27 loans); Northwest Bank (17 loans); Newtek Bank, National Association (16 loans); Readycap Lending, LLC (14 loans); Growth Capital Corp. (12 loans). The most active 504 Certified Development Companies were Growth Capital Corp. (13 loans, $11,617,000); Cascade Capital Corporation (6 loans, $5,625,000); Alloy Development Co., Inc. (4 loans, $7,942,000); Michigan Certified Development Corporation (1 loan, $1,189,000).

SBA 7(a) and 504 lending in the Cleveland 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 motels68$164,881,1000.0%13$33,184,000cohort under 30
Car washes45$26,780,400cohort under 3011$7,230,000cohort under 30
Self-storage17$21,282,500cohort under 30under 5
RV parks and campgroundsunder 5under 5
Assisted living and continuing care9$5,661,000cohort under 30under 5
Gas stations and convenience stores34$29,782,000cohort under 30under 5
Restaurants, full and limited service631$164,906,30011.1%24$11,659,000cohort under 30
Fitness and recreational sports centers162$44,569,10010.2%6$4,121,000cohort under 30
Marinasunder 5under 5
Child day care services109$59,102,20013.5%12$7,844,000cohort under 30
All ten asset classes in this table1,078$518,975,0009.6%73$67,223,000cohort 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 Cleveland

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 Cleveland Industrial Q2 2026, reports a vacancy rate of 3.8%, an asking rent of $5.68 per square foot. The report is Cushman and Wakefield, MarketBeat Cleveland 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 Cleveland region

USDA Business and Industry and Community Facilities credit runs on a statutory geography rather than 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 is therefore out, and so is the built-up area running with it. What can remain eligible is the outer part of the six member counties, beyond the urbanized area, and the test turns on the subject address and the urbanized-area boundary drawn around it rather than on the name of the municipality. 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 Cleveland 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. Northeast Ohio Regional Sewer District
  5. NEORSD, Service Area and Facilities
  6. NEORSD, Regional Stormwater Management Program
  7. City of Cleveland, Department of Building and Housing, Division of Records Administration
  8. City of Cleveland, Residents First
  9. City of Cleveland, Mayor's Office of Equal Opportunity
  10. City of Cleveland, Office of Equal Opportunity, Key Terms and Definitions
  11. City of Cleveland, Mayor's Office of Equal Opportunity
  12. Cushman and Wakefield, MarketBeat Cleveland Industrial Q2 2026
  13. 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 Cleveland Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/cleveland-feasibility-market-2026

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