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The Orlando 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

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

Orlando 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.

The lodging tax changes at every county line inside this metro. Florida lets each county levy a local option transient rental tax on accommodations rented for six months or less, and the Department of Revenue publishes the resulting rate county by county on Form DR-15TDT. In this metro the four member counties do not agree. Orange is at 6.0 percent, Osceola at 6.0 percent, Seminole at 5.0 percent and Lake at 4.0 percent, and the Department states that this local tax is in addition to the 6% state sales tax and any applicable discretionary sales surtax. The 200 basis point spread between Orange and Lake is not a rounding difference on a hotel pro forma; it sits on gross room revenue, and it changes the gap between the rate a guest pays and the revenue the operator books. Two of the four counties also carry a statutory qualification the other two do not. The Department names Orange and Osceola among the counties that have imposed the high tourism impact tax after certification, and the statute sets the test for that certification: taxable transient rental sales above $600 million in the previous calendar year, or at least 18 percent of the county's total taxable sales where those sales were a minimum of $200 million. A study that carries one metro-wide lodging tax line is wrong for three of these four counties.

The Wekiva Study Area, a development overlay whose boundary is a survey line and not a county line. The Legislature drew the Wekiva Study Area and then wrote development rules for the land inside it. The two that reach a feasibility budget are stormwater and water supply. The Legislature directed the St. Johns River Water Management District to amend its recharge criteria so that postdevelopment recharge volume conditions within the Wekiva Study Area approximate predevelopment recharge volume conditions, which is a harder standard than ordinary retention and is set on a development-specific basis, and it directed the district to revise the consumptive use permit thresholds in the area to address proposed water withdrawals above 50,000 gallons per day. For the asset classes MMCG studies that is not background. A car wash, a hotel laundry and a restaurant kitchen are the uses that approach a withdrawal threshold, and a recharge standard that must approximate predevelopment conditions decides how much of a site is buildable before the first cost estimate is drawn. The instruction the study carries is narrow, because the area's own definition is narrow: the statute defines the Wekiva Study Area by a metes and bounds description that begins at the northwest corner of Section 6, Township 18 South, Range 28 East in Lake County, so the question is answered by locating the subject parcel against that description, not by naming a county.

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

In fiscal year 2025 the Orlando metro recorded 787 7(a) approvals for $389,735,000 and 95 504 approvals for $96,777,000, filed largely through the NORTH FLORIDA DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were Northeast Bank (103 loans); Newtek Bank, National Association (76 loans); Readycap Lending, LLC (70 loans); TD Bank, National Association (61 loans); The Huntington National Bank (60 loans); JPMorgan Chase Bank, National Association (28 loans); BayFirst National Bank (22 loans); United Midwest Savings Bank National Association (20 loans). The most active 504 Certified Development Companies were Florida Business Development Corporation (48 loans, $45,115,000); Florida First Capital Finance Corporation, Inc. (42 loans, $45,436,000); Sunshine State Economic Development Corporation (5 loans, $6,226,000).

SBA 7(a) and 504 lending in the Orlando 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 motels54$144,548,9002.9%27$69,266,000cohort under 30
Car washes20$45,134,200cohort under 3021$35,162,000cohort under 30
Self-storage8$24,359,400cohort under 30under 5
RV parks and campgroundsunder 5under 5
Assisted living and continuing care34$28,176,200cohort under 305$13,479,000cohort under 30
Gas stations and convenience stores19$14,274,600cohort under 30under 5
Restaurants, full and limited service410$275,950,80012.9%39$39,150,000cohort under 30
Fitness and recreational sports centers109$56,124,60014.3%6$4,582,000cohort under 30
Marinasunder 5under 5
Child day care services142$151,160,0006.2%43$54,951,000cohort under 30
All ten asset classes in this table796$739,728,70010.4%147$220,038,0001.7%

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 the published market reports say about Orlando

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 Orlando Retail Q2 2026, reports Orlando totals of 158,842,092 square feet of inventory at 3.9% overall vacancy and $31.18 average asking rent, and states that average asking rents reached $31.18 per square foot (psf), well above the national average of $26.08 psf, while annual rent growth measured 2.9% YOY, compared with 1.7% nationally. The report is Cushman and Wakefield, MarketBeat Orlando Retail Q2 2026, covering Q2 2026.

Source: CoStar via Cushman and Wakefield; the report's market fundamentals line reads "Source: CoStar" and its economic indicators line reads "Sources: CoStar, Moody’s".

Two qualifications travel with that figure and belong on the page rather than in a footnote. The report prints Source: CoStar under its market fundamentals. The figure is carried here as Cushman and Wakefield's published figure on Cushman and Wakefield's own public page, and the underlying attribution is recorded rather than hidden. 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.

A second published figure covers a different asset class in this metro and is carried on the same terms. Yardi Matrix, Matrix Multifamily Orlando Report, July 2026, states that the average advertised asking rent was $1,767 through May, marking a 0.2 percent increase on a T3 basis that was 10 bps below the U.S. average, and that transactions totaled only $347 million during the first five months of 2026, with an average per-unit price of $174,502. The report is Yardi Matrix, Matrix Multifamily Orlando Report, July 2026, covering July 2026. Yardi Matrix collects its own multifamily data. The figures quoted here are on the publisher's ungated public page; the full report behind it sits behind a sign-up form, so it is not used here. This figure is metro context and nothing more.

USDA eligibility geometry in the Orlando region

USDA Business and Industry and Community Facilities credit runs on a statutory geography, not 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 of more than 50,000 inhabitants and any urbanized area contiguous and adjacent to such a city or town. The Orlando urbanized core is therefore out. What remains in this metro is the outer parts of the member counties, beyond the urbanized area that runs with Orlando, Kissimmee and Sanford. 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.

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 an Orlando 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 Department of Revenue, Form DR-15TDT, Local Option Transient Rental Tax Rates; Florida Department of Revenue, Local Option Taxes; The Florida Senate, s. 125.0104, F.S.
  5. Florida Department of Revenue, Local Option Taxes (high tourism impact tax, counties named)
  6. The Florida Senate, The 2024 Florida Statutes, s. 125.0104 Tourist development tax
  7. The Florida Senate, The 2024 Florida Statutes, ss. 369.316 and 369.318
  8. The Florida Senate, The 2024 Florida Statutes, s. 369.316 (Wekiva Study Area definition)
  9. Cushman and Wakefield, MarketBeat Orlando Retail Q2 2026
  10. Yardi Matrix, Matrix Multifamily Orlando Report, July 2026
  11. 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 Orlando Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/orlando-feasibility-market-2026

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