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The Phoenix 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 22, 20268 minute read

Summary

Phoenix 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 Phoenix metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the Phoenix 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 Phoenix feasibility study hub. Every figure traces to a primary source named in the Sources list. MMCG's city briefs use primary and FOIA sources and do not carry commercial rent, vacancy or occupancy figures.

The structural variables that reset Phoenix underwriting

Phoenix 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.

Assured Water Supply rule and the June 2023 Phoenix AMA groundwater cutoff. Under Arizona's 1980 Groundwater Management Act, land inside an Active Management Area cannot be platted and sold as a subdivision unless the developer first obtains a certificate of assured water supply proving water is continuously available for at least 100 years (A.R.S. 45-576). In June 2023 the Department of Water Resources determined, from its Phoenix Active Management Area groundwater model, that it will not approve new assured-water-supply determinations relying on groundwater, citing 4.86 million acre-feet of projected 100-year unmet demand. Fringe residential and mixed-use projects now need renewable supplies, making water-portfolio verification a gating underwriting step rather than a formality.

The extreme-heat operating and construction regime. The National Weather Service Phoenix office recorded 55 days at or above 110 degrees in 2023, with July 2023 the hottest month ever measured for the city at a 102.7 degree average, followed by 143 days at or above 100 degrees and 70 days at or above 110 degrees in 2024. This heat load drives year-round cooling demand, raises utility operating expenses in pro formas, compresses outdoor construction schedules, accelerates roof and envelope wear and triggers worker heat-safety rules, so energy costs, capital reserves and contingency assumptions all diverge from a temperate national template.

Advanced semiconductor manufacturing base (federal CHIPS buildout). The U.S. Department of Commerce and NIST awarded TSMC Arizona up to 6.6 billion dollars in direct CHIPS funding to support more than 65 billion dollars of investment in three greenfield leading-edge fabs in Phoenix, generating roughly 6,000 direct manufacturing jobs and more than 20,000 construction jobs; Intel received up to 7.865 billion dollars for projects that include Arizona. For underwriting, this concentrates high-wage, cyclical employment, very large industrial water and power demand and multi-year construction absorption in one metro, supporting industrial, flex and workforce-housing demand while tying part of it to a single volatile sector.

Nation-leading absolute in-migration. Census Bureau Vintage 2022 estimates show Maricopa County remained the largest-gaining county in the nation, adding 56,831 residents from July 2021 to July 2022, a 1.3 percent one-year increase on a base near 4.5 million. Sustained in-migration of this scale drives rooftops, retail and service absorption and infrastructure demand across the metro fringe, but it collides directly with the water constraint, since new subdivisions must now secure non-groundwater supplies. Demand assumptions can lean on this population momentum while stress-testing where growth can physically be served with water and utilities.

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

In fiscal year 2025 the Phoenix metro recorded 1,256 7(a) approvals for $666,814,900 and 181 504 approvals for $236,838,000, filed largely through the ARIZONA DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were Northeast Bank (132 loans); Newtek Bank, National Association (90 loans); The Huntington National Bank (88 loans); Wells Fargo Bank National Association (73 loans); U.S. Bank, National Association (71 loans); JPMorgan Chase Bank, National Association (55 loans); Zions Bank, a division of Zions Bancorporation, N.A. (50 loans); Live Oak Banking Company (49 loans). The most active 504 Certified Development Companies were Mortgage Capital Development Corporation (116 loans, $170,656,000); California Statewide Certified Development Corporation (27 loans, $18,495,000); Arizona Capital Source (17 loans, $24,252,000); CDC Small Business Finance Corp. (17 loans, $20,386,000); AMPAC Tri-State CDC, Inc. (2 loans, $1,380,000); Midwest Business Finance Corporation (1 loan, $1,152,000).

SBA 7(a) and 504 lending in the Phoenix 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 motels92$216,875,8000.0%31$83,889,000cohort under 30
Car washes63$71,805,10013.2%14$12,158,000cohort under 30
Self-storage16$35,999,600cohort under 308$11,094,000cohort under 30
RV parks and campgroundsunder 5under 5
Assisted living and continuing care157$137,149,9004.7%13$8,570,000cohort under 30
Gas stations and convenience stores79$117,503,6001.6%under 5
Restaurants, full and limited service556$302,264,4009.7%87$76,935,000cohort under 30
Fitness and recreational sports centers256$106,233,90010.6%16$18,511,000cohort under 30
Marinasunder 5under 5
Child day care services116$88,887,5000.0%17$12,911,000cohort under 30
All ten asset classes in this table1,337$1,077,795,8007.0%189$227,005,0000.0%

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.

USDA eligibility geometry in the Phoenix region

Under 7 CFR 5001.3, a rural area means any area not in a city or town of more than 50,000 inhabitants and not in the urbanized area contiguous and adjacent to it, per the latest decennial census; the USDA Rural Development eligibility map is the authoritative test. In the Phoenix metro outer counties several small incorporated towns sit far below the threshold and away from the urbanized core, making them plausibly eligible; MMCG verifies eligibility at the subject address at intake.

A note on what this post does not claim

A Phoenix 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 Phoenix study a lender can check.

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. Arizona State Legislature, A.R.S. 45-576 (azleg.gov); Arizona Department of Water Resources (azwater.gov, via Internet Archive)
  5. Arizona Department of Water Resources, Phoenix AMA groundwater supply updates (4.86 maf; Internet Archive copy, 14 September 2026)
  6. National Weather Service (NWS) Phoenix, NOAA
  7. National Weather Service Phoenix, 2024 year in review
  8. U.S. Department of Commerce and National Institute of Standards and Technology (NIST), CHIPS Program
  9. NIST, CHIPS incentives award to Intel
  10. U.S. Census Bureau
  11. USDA Rural Development, 7 CFR 5001.3 (eCFR)
  12. Arizona Joint Legislative Budget Committee (JLBC), 2025 Tax Handbook
Michal Mohelsky, J.D., Principal of MMCG Invest

Cite this

Michal Mohelsky, J.D., FMVA (2026). The Phoenix Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/phoenix-feasibility-market-2026

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