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The Milwaukee 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

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

Milwaukee 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 sales and use tax rate that changes at the county line, and a city rate that crosses three of those lines. The Wisconsin Department of Revenue publishes a 5% state sales tax and then, county by county, a county rate and, for one city only, a city rate. Its Sales Tax Rate Chart carries Milwaukee at 0.90% (1/24) above a struck prior line of 0.50% (4/91-12/31/23); Ozaukee at 0.50% (4/91); Washington at 0.50% (1/99); and Waukesha with the county rate column empty. The department states that Seventy Wisconsin counties have adopted a 0.5% county tax and that Milwaukee County sales and use tax increases from 0.5% to 0.9%, effective January 1, 2024. Separately it states that the city of Milwaukee is the only municipality that imposes a city sales and use tax and that the 2% city of Milwaukee sales and use tax is effective January 1, 2024, and its own footnote records that the city of Milwaukee is located in multiple counties: the 2% (1/24) city line is repeated under Milwaukee, Washington and Waukesha. For a feasibility study the consequence is that there is no single metro rate to price from. Two candidate sites in different member counties face different stacks, the department sources the tax to where the sale takes place rather than to where the retailer sits, and an equipment and fixtures budget built on one blended figure is wrong on one side of a line the study has to locate first.

A Lake Michigan water supply capped by an interstate compact west of the Great Lakes Basin line. The Wisconsin Department of Natural Resources states that the Great Lakes Compact and Agreement ban diversions of Great Lakes water with limited exceptions, and that the exceptions let a straddling community or a community in a straddling county apply to the DNR to move water out of the Great Lakes Basin. It defines a community in a straddling county as one wholly outside the basin but in a county that straddles the basin boundary, and names the City of Waukesha as its example. The DNR approved that diversion at up to 8.2 million gallons per day, and the Compact Council's conditions include a reduced diversion volume of 8.2 million gallons per day and a smaller diversion area of only the area currently served by the Waukesha water utility. The department's own table of Wisconsin approvals lists four in Waukesha County: City of Brookfield 1,944,000, Village of Menomonee Falls 3,217,200, City of New Berlin 2,142,000 and City of Waukesha 8,200,000 gallons per day. For an SBA or USDA file on a water-intensive use, that is a supply with a published ceiling and a published edge. The study has to confirm the subject address sits inside the approved service area and that the utility has capacity within its approved volume, rather than treating municipal water as an open connection the way a national template does.

A regional sewerage district with its own boundary, its own taxing power and a strength-based sewer charge. The Milwaukee Metropolitan Sewerage District describes itself as a regional government agency providing water reclamation and flood management services in 29 communities, serving 423 square miles within six watersheds, established by state law and governed by eleven commissioners with taxing authority. Its own list of the twenty-nine communities runs far beyond the city of Milwaukee and does not follow a county line. The district publishes its user charge parameters as Volume, Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS), sets discharge regulations in MMSD Rules, Chapter 11 and user charges in MMSD Rules, Chapter 17, and states that a facility is a significant industrial user if categorical pretreatment standards apply, if discharges have the potential to violate a local limit, or if the facility will discharge 25,000 gallons per day or more of process wastewater. Before discharging, such a facility must obtain a permit and provide a Baseline Report. Three things follow for a study. The sewer line in the operating budget is a strength charge, not a per-gallon charge, so a wet process tenant is not priced off a residential rate. The permit is a pre-opening milestone with its own approvals, sampling locations and DNR sign-off where pretreatment is installed. And the district is a separate taxing body sitting over the municipal and county levies rather than inside them.

Wisconsin's personal property exemption, and the fixture test that decides what stays taxable. The Wisconsin Department of Revenue publishes its answers on the personal property exemption created by 2023 Wisconsin Act 12, effective January 1, 2024. The exemption applies starting with the January 1, 2024, assessment, and exempt personal property will not have a 2024 assessment or 2024 property tax bill. Act 12 created sec. 70.111(28), Wis. Stats., and the exemption applies to personal property as defined in sec. 70.04, Wis. Stats., and to steam and other vessels, furniture, and equipment. It does not reach real property, nor buildings, improvements and fixtures on leased land assessed as real property under sec. 70.17(3), Wis. Stats., nor utility property subject to state taxation. Act 12 also amended sec. 70.17(1), Wis. Stats. and removed the option of assessing improvements on leased land as personal property. Whether a given article is exempt turns on a three-factor test drawn from state court cases: actual physical annexation to the real estate, application or adaptation to the use or purpose to which the realty is devoted, and intention on the part of the person creating the annexation to make the item a permanent part of the realty. For an equipment-heavy project this is the line that decides how much of the fit-out sits in the property tax line of the operating budget, and a tenant's leasehold improvements can fall on either side of it.

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

In fiscal year 2025 the Milwaukee metro recorded 378 7(a) approvals for $185,508,500 and 39 504 approvals for $41,014,000, filed largely through the WISCONSIN DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were The Huntington National Bank (48 loans); U.S. Bank, National Association (33 loans); Northeast Bank (26 loans); Newtek Bank, National Association (21 loans); Waukesha State Bank (20 loans); Wisconsin Women's Business Initiative Corporation (19 loans); Old National Bank (16 loans); Associated Bank National Association (15 loans). The most active 504 Certified Development Companies were WBD, Inc. (33 loans, $36,316,000); Racine County Economic Development Corporation (5 loans, $2,411,000); SomerCor 504, Inc. (1 loan, $2,287,000).

SBA 7(a) and 504 lending in the Milwaukee 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 motels33$70,698,900cohort under 3016$31,897,000cohort under 30
Car washes19$16,088,200cohort under 306$6,579,000cohort under 30
Self-storage21$37,816,400cohort under 3010$12,610,000cohort under 30
RV parks and campgroundsunder 5under 5
Assisted living and continuing care53$57,420,0003.2%15$13,850,000cohort under 30
Gas stations and convenience stores142$112,156,9007.3%21$13,135,000cohort under 30
Restaurants, full and limited service379$147,746,10011.5%46$27,253,000cohort under 30
Fitness and recreational sports centers98$25,558,90012.3%9$7,500,000cohort under 30
Marinasunder 5under 5
Child day care services100$40,438,3004.9%9$9,977,000cohort under 30
The ten asset classes in this table846$508,305,7008.7%133$123,052,0000.0%

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.

What one published market report says about Milwaukee

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 Milwaukee Industrial Q2 2026, reports a vacancy rate of 4.0%, an asking rent of $5.64 per square foot. The report is Cushman and Wakefield, MarketBeat Milwaukee 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's most recent retail MarketBeat for this market is from the first quarter of 2025, so the current industrial report is used instead. 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 Milwaukee region

USDA Business and Industry and Community Facilities credit runs on a statutory geography, not on a county line or a metro name. 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. What can remain is outer ground in the four member counties, beyond the urbanized area that runs with the built-up centre, and the test turns on the subject address and the urbanized-area boundary around it rather than on the name of the municipality. MMCG therefore verifies eligibility at the address on the USDA Rural Development eligibility map at intake, before any work on the study begins. 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 Milwaukee 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. Wisconsin Department of Revenue
  5. Wisconsin Department of Revenue, Sales and Use Tax home (the look-up tool the department points to for a particular sale)
  6. Wisconsin Department of Natural Resources
  7. Wisconsin DNR, City of Waukesha Diversion (the approval, its conditions and the annual reports)
  8. Milwaukee Metropolitan Sewerage District
  9. Milwaukee Metropolitan Sewerage District, About Us (service area, the twenty-nine communities and the commission's taxing authority)
  10. Wisconsin Department of Revenue
  11. Cushman and Wakefield, MarketBeat Milwaukee Industrial Q2 2026
  12. 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 Milwaukee Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/milwaukee-feasibility-market-2026

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