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The Jacksonville 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

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

Jacksonville 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.

Duval County is a consolidated city-county, and Florida tax law gives it its own class. Article VIII, Section 3 of the Florida Constitution lets the government of a county and the government of one or more municipalities inside it be consolidated into a single government, and Section 6(e) keeps the 1885 local government provisions alive for a county that consolidated under them. The 1885 text the Florida Senate reproduces gives the Legislature power to establish a municipal corporation known as the City of Jacksonville extending territorially throughout the present limits of Duval County, in the place of any or all county, district, municipal and local governments, and to divide that territory into subordinate districts with their own system of taxation. The Legislature's own Office of Economic and Demographic Research records the result. Florida local governments may otherwise levy ten mills for county purposes and ten mills for municipal purposes; because Duval and Jacksonville are a consolidated government, the office states the unit has a twenty mill cap since it operates as both a county and a municipal government. The same office states that a county whose government is consolidated with one or more municipalities, currently Duval, is the one county eligible for the Consolidated County Convention Development Tax, a 2 percent tax on transient rental transactions, estimated at $12.1 million in the 2025-26 state fiscal year. Half of what that tax collects inside a municipality not consolidated with the county must be remitted to that municipality on request. A study that models a county government and a city government bargaining separately in Duval is describing a structure Florida law does not have there.

The county sales surtax changes at every county line in this metro and follows the delivery address. Florida adds a county discretionary sales surtax on top of the state sales and use tax, and the Department of Revenue publishes the county by county table each November as Form DR-15DSS. For calendar year 2026 the five counties of this metro do not share a rate: Duval is at 1.5%, Clay is at 1.5%, Baker is at 1%, Nassau is at 1%, and St. Johns is at .5%. The Department states that rates currently range from .5% to 2% and that some counties impose none at all. Two rules matter for a project budget. First, the surtax is collected on the county where delivery is made: the Department's own guidance says a selling dealer collects when it delivers taxable goods or taxable services in or into a county with a surtax, and that where a dealer sells and delivers into counties with different rates, the surtax is collected at the county rate where the delivery is made. A supplier in Duval delivering materials to a site in St. Johns therefore bills the St. Johns rate. Second, there is a cap: the surtax applies to the first $5,000 of the sales amount on the sale, use, lease, rental, or license to use any item of tangible personal property, and section 212.054 of the Florida Statutes says the sales amount above $5,000 on any item of tangible personal property is not subject to the surtax. The Department adds that the $5,000 cap does not apply to transient rentals or to sales of services.

St. Johns County has already published its impact fees out to 2030. St. Johns County publishes a Master Impact Fee Schedule that is not one number but five, one per phase, each with its own effective date. Phase I takes effect 3/4/2026 and Phase V takes effect 3/4/2030, and the county has published the Phase V table now. The fee is assessed by ITE land use code and split across roads, schools, public buildings, fire rescue, law and jail, parks and conservation. Under Phase I a Hotel/Motel room carries $3,927, a Fast Food Restaurant w/Drive-Thru carries $29,790 per 1,000 sf, and Warehousing carries $1,270 per 1,000 sf. Under Phase V the same rows read $4,716, $39,721 and $1,531. Florida law constrains how fast a local impact fee can move: section 163.31801 of the Florida Statutes says an increase of not more than 25 percent of the current rate must be implemented in two equal annual increments, an increase exceeding 25 percent but not more than 50 percent must be implemented in four equal installments beginning with the date the increased fee is adopted, an increase may not exceed 50 percent of the current rate, and an impact fee may not be increased more than once every 4 years. For a St. Johns project this means the fee line in a feasibility study is a function of the permit date, and both the current and the future numbers are published rather than estimated.

A state permitting line runs through three of this metro's five counties. Section 161.053 of the Florida Statutes directs the Department of Environmental Protection to establish coastal construction control lines on a county basis along the sand beaches of the state fronting on the Atlantic Ocean, the Gulf of America, or the Straits of Florida, and to set those lines so as to define the portion of the beach and dune system subject to severe fluctuations based on a 100-year storm surge. Once a control line is filed, the statute provides that no person, firm, corporation, or governmental agency shall construct any structure whatsoever seaward of it, or make any excavation, remove beach material or otherwise alter ground elevations, except as the statute allows. The harder constraint is the erosion projection: the department may not issue a permit for any structure, other than a coastal or shore protection structure, a minor structure or a pier, proposed for a location that, on the department's projections of erosion, will be seaward of the seasonal high-water line within 30 years after the date of application. DEP states that control lines are established in 25 of Florida's coastal counties with sandy beaches, and its CCCL permit manager roster lists Duval and Nassau under one manager and Flagler, St. Johns and Volusia under another; Baker and Clay appear on no permit manager's list of coastal counties served. A site plan that clears county zoning on the Atlantic side of this metro can still be unbuildable as drawn.

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

In fiscal year 2025 the Jacksonville metro recorded 391 7(a) approvals for $226,439,500 and 67 504 approvals for $67,296,000, filed largely through the NORTH FLORIDA DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were TD Bank, National Association (37 loans); Northeast Bank (36 loans); The Huntington National Bank (31 loans); Newtek Bank, National Association (27 loans); Readycap Lending, LLC (19 loans); Live Oak Banking Company (18 loans); United Midwest Savings Bank National Association (15 loans); BayFirst National Bank (13 loans). The most active 504 Certified Development Companies were Florida First Capital Finance Corporation, Inc. (47 loans, $44,182,000); Florida Business Development Corporation (17 loans, $21,222,000); Sunshine State Economic Development Corporation (2 loans, $899,000); Small Business Growth Corporation (1 loan, $993,000).

SBA 7(a) and 504 lending in the Jacksonville 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 motels67$182,045,5000.0%22$54,834,000cohort under 30
Car washes14$23,673,400cohort under 3010$9,473,000cohort under 30
Self-storage7$10,290,500cohort under 30under 5
RV parks and campgroundsunder 5under 5
Assisted living and continuing care14$19,230,100cohort under 309$13,129,000cohort under 30
Gas stations and convenience stores15$15,450,500cohort under 30under 5
Restaurants, full and limited service245$144,191,90019.3%74$68,642,000cohort under 30
Fitness and recreational sports centers68$33,924,10022.9%10$4,031,000cohort under 30
Marinasunder 5under 5
Child day care services68$71,620,9000.0%31$20,132,000cohort under 30
All ten asset classes in this table504$518,456,90012.4%161$177,503,0005.2%

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 Jacksonville

Where a research publisher has put a market figure on a public page, this brief may carry it, cited to the page that carries the figure, with the publisher named in the sentence and the report's own source line printed below it. Cushman and Wakefield, MarketBeat Jacksonville Retail Q2 2026, reports Jacksonville totals of 102,841,766 square feet of inventory, 5,430,982 square feet available, 5.2% overall vacancy and $25.19 asking rent, and states that annual asking rents recorded a 1.4% increase YOY, slightly below the U.S. average of 1.8% YOY, with market asking rent now averaging $25.19 per square feet (psf). The report is Cushman and Wakefield, MarketBeat Jacksonville Retail Q2 2026, covering Q2 2026.

Source: CoStar via Cushman and Wakefield; the report's own lines read "Source: CoStar" and "Source: CoStar, Moody’s".

Two qualifications travel with that figure and belong on the page rather than in a footnote. The report prints Source: CoStar beneath its rent narrative and again beneath its submarket statistics table, and Source: CoStar, Moody's beneath its key lease and sales transaction panels. Its economic indicators panel is sourced separately to BLS and to BEA and the Census Bureau, which are not CoStar lines and are named here for completeness rather than because the figure rests on them. 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 Jacksonville region

USDA Business and Industry and Community Facilities credit runs on a statutory geography rather than 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 Jacksonville urbanized core is therefore out. What can remain in this metro is the outer parts of the member counties, beyond the urbanized area that runs with the core. Because 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 Jacksonville 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. Florida Legislature, Office of Economic and Demographic Research
  5. The Florida Senate, Constitution of the State of Florida, Article VIII Local Government
  6. Florida Department of Revenue
  7. Florida Department of Revenue, Discretionary Sales Surtax
  8. The Florida Senate, The 2026 Florida Statutes, s. 212.054
  9. St. Johns County, Florida, Growth Management Department
  10. St. Johns County, Florida, Impact Fee Tables Phase 5 effective March 4, 2030
  11. The Florida Senate, The 2026 Florida Statutes, s. 163.31801
  12. The Florida Senate, The 2026 Florida Statutes
  13. Florida Department of Environmental Protection, Locate the Coastal Construction Control Line
  14. Florida Department of Environmental Protection, CCCL Permit Managers and Program Support
  15. Cushman and Wakefield, MarketBeat Jacksonville Retail Q2 2026
  16. 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 Jacksonville Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/jacksonville-feasibility-market-2026

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