Summary
Miami 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 Miami metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the Miami 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 Miami feasibility study hub. Every figure traces to a primary source named in the Sources list.
The structural variables that reset Miami underwriting
Miami 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.
Property insurance market and Citizens assessment risk. Miami sits at the center of Florida's property-insurance stress. Citizens Property Insurance Corporation, created by the Legislature in 2002 as the state's insurer of last resort, has absorbed policies private carriers decline to write. Because Florida law lets Citizens assess most Florida policyholders after a large-storm deficit, insurance is a volatile, hard to predict line item in Miami underwriting. In December 2022 the Legislature passed SB 2-A, eliminating one-way attorney fees for property-insurance suits and prohibiting assignment of post-loss benefits, aiming to stabilize rates and return Citizens to a true last-resort role.
Milestone structural inspections and reserve studies (SB 4-D). Senate Bill 4-D, enacted in 2022 after the Champlain Towers South collapse in Surfside, requires condominium and cooperative buildings three or more stories in height to undergo a milestone structural inspection at 30 years of age, or 25 years if within three miles of a coastline, and every 10 years after. Associations must also complete a structural integrity reserve study every 10 years and may no longer waive those reserves. For Miami's aging coastal condo stock this turns deferred maintenance into mandatory, quantifiable capital calls that buyers, lenders and appraisers must price.
High-Velocity Hurricane Zone building code. The Florida Building Code designates Miami-Dade and Broward counties as the High-Velocity Hurricane Zone, a regime strengthened after 1992's Hurricane Andrew. In Miami-Dade the ultimate design wind speed for ordinary Risk Category II buildings is 175 mph, and exterior products such as windows, doors, shutters and roofing must carry a Miami-Dade County Notice of Acceptance confirming they passed impact and pressure testing. These rules raise hard-cost budgets, lengthen product procurement and make national cost templates understate Miami envelope and re-roofing costs, so feasibility models must load HVHZ compliance into construction and reserve assumptions.
Sea-level rise and flood elevation standards. Miami-Dade County relies on the Southeast Florida Regional Climate Compact's Unified Sea Level Rise Projection, under which sea levels by 2040 are expected to be 10 to 17 inches higher than 2000 levels. County flood-criteria rules govern minimum lot and finished-floor elevations, and the Florida Building Code requires freeboard above base flood elevation in special flood hazard areas. Much of the metro lies in FEMA flood zones with mandatory flood insurance, while rising groundwater and king-tide flooding lift drainage and foundation costs, so Miami feasibility must budget elevation and flood-proofing beyond national norms.
No state personal income tax. Florida levies no personal income tax, which the Department of Revenue states plainly: residents have no personal income-tax filing requirement. For commercial real estate, SBA and USDA underwriting this matters because pass-through and individual investors retain more after-tax cash flow than in high-tax states, supporting firmer after-tax pricing. The absence of a state income tax is a durable feature of Florida's regime, so Miami models should reflect the after-tax return premium rather than a national tax baseline.
Miami 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 Miami metro cut below is computed in-house from the SBA 7(a) and 504 FOIA release by county membership across the Miami-Fort Lauderdale-West Palm Beach, FL Metropolitan Statistical Area, never read from an SBA district total.
In fiscal year 2025 the Miami metro recorded 2,551 7(a) approvals for $1,116,881,600 and 209 504 approvals for $229,908,000, filed largely through the SOUTH FLORIDA DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were TD Bank, National Association (420 loans); Northeast Bank (300 loans); Newtek Bank, National Association (297 loans); Readycap Lending, LLC (181 loans); The Huntington National Bank (109 loans); JPMorgan Chase Bank, National Association (107 loans); BayFirst National Bank (97 loans); Bank of America, National Association (89 loans). The most active 504 Certified Development Companies were Florida Business Development Corporation (107 loans, $106,780,000); Florida First Capital Finance Corporation, Inc. (99 loans, $121,061,000); Sunshine State Economic Development Corporation (2 loans, $907,000); Independent Development Services Corporation (1 loan, $1,160,000).
| Asset class | 7(a) loans | 7(a) gross approval | 7(a) charge-off rate | 504 loans | 504 gross approval | 504 charge-off rate |
|---|---|---|---|---|---|---|
| Hotels and motels | 49 | $99,574,500 | cohort under 30 | 26 | $80,057,000 | cohort under 30 |
| Car washes | 77 | $114,445,800 | 9.6% | 6 | $10,192,000 | cohort under 30 |
| Self-storage | under 5 | 7 | $14,569,000 | cohort under 30 | ||
| RV parks and campgrounds | under 5 | under 5 | ||||
| Assisted living and continuing care | 45 | $54,644,700 | cohort under 30 | 14 | $22,110,000 | cohort under 30 |
| Gas stations and convenience stores | 51 | $69,392,500 | 8.3% | 13 | $9,758,000 | cohort under 30 |
| Restaurants, full and limited service | 600 | $329,266,900 | 18.6% | 44 | $46,809,000 | cohort under 30 |
| Fitness and recreational sports centers | 215 | $77,683,700 | 15.5% | 17 | $20,036,000 | cohort under 30 |
| Marinas | 17 | $13,584,200 | cohort under 30 | under 5 | ||
| Child day care services | 252 | $210,545,800 | 8.7% | 71 | $59,401,000 | cohort under 30 |
| All ten asset classes in this table | 1,308 | $974,888,100 | 13.1% | 199 | $264,027,000 | 0.0% |
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 Miami region
USDA Business and Industry and rural-development programs serve rural areas, which under 7 CFR Part 5001 generally means places of 50,000 or fewer people not inside an urbanized area contiguous and adjacent to a city or town of more than 50,000. The Miami metro is overwhelmingly urban, but its western interior, the agricultural Glades region of Palm Beach County around Lake Okeechobee, holds small communities far below that threshold, plausibly USDA-eligible unlike the coastal core; MMCG verifies eligibility at the subject address at intake.
A note on what this post does not claim
A Miami 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 Miami study a lender can check.
Sources
- U.S. Small Business Administration, News Release 25-83, September 30, 2025
- U.S. Small Business Administration, 7(a) and 504 FOIA release (label as of June 30, 2026)
- U.S. Census Bureau, Population Estimates Program, Metropolitan and Micropolitan Statistical Areas, vintage 2024
- Citizens Property Insurance Corporation
- The Florida Senate
- Florida Building Commission (Florida Building Code)
- Miami-Dade County (Office of Resilience)
- Florida Department of Revenue
- U.S. Census Bureau, 2023 Gazetteer Files (Florida places)
- Florida Department of Revenue
Cite this
Michal Mohelsky, J.D., FMVA (2026). The Miami Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/miami-feasibility-market-2026
Where this goes next
- The service page for the program this analysis is aboutMMCG's feasibility study page for this subject.
