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The San Antonio 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

San Antonio 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 San Antonio metro SBA 7(a) and 504 record computed from the FOIA file. It is the companion to the San Antonio 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 San Antonio feasibility study hub. Every figure traces to a primary source named in the Sources list.

The structural variables that reset San Antonio underwriting

San Antonio 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.

CPS Energy, a city-owned combined electric and gas utility. CPS Energy states that it was established in 1860, that it is the nation's largest public power, natural gas and electric company, and that it provides energy to more than 996,000 electric and 399,000 natural gas customers in San Antonio and portions of seven adjoining counties. For a feasibility study the combination is what matters. A single municipally owned counterparty supplies both fuels, so a project that uses gas for cooking, laundry or process heat and electricity for everything else negotiates one connection process and one rate structure rather than two, and both are set by a city-owned enterprise rather than by a state rate case. The metro's energy line is therefore more predictable than a template assumes, and the service-upgrade schedule sits with the same body that reviews the site.

Groundwater under a permit cap administered by the Edwards Aquifer Authority. The Edwards Aquifer Authority states that 2.5 million Texans, including farmers, cities and businesses, share this water source through a carefully maintained permitting system, and that water rights permits help control and track the total amount of water being withdrawn from the aquifer so that over-pumping which could deplete the aquifer or damage dependent springs and rivers is prevented. A project whose viability depends on water volume, and a car wash is the clearest case in MMCG's asset classes, has to establish whether its supply comes from the Edwards Aquifer under that permitting system before the demand model means anything, because the authority's jurisdiction follows the aquifer rather than the metro boundary and several of the metro's outer counties draw on other formations, and a drought-stage restriction is an operating risk that belongs in the sensitivity analysis rather than in a footnote.

A city-owned water utility governed by the city's own board. The San Antonio Water System states that it is governed by a Board of Trustees consisting of San Antonio's mayor and six members appointed by City Council. Taken with the aquifer's permit cap, this gives the metro an unusual water profile: the resource is allocated by a regional authority and delivered by a municipal utility answering to the city government. For a project the practical effect is that the connection, the capacity question and the rate all sit with a body accountable to the same council that approves the site, so timing risk and political risk are correlated here in a way a national template does not model.

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

In fiscal year 2025 the San Antonio metro recorded 502 7(a) approvals for $289,408,900 and 17 504 approvals for $20,057,000, filed largely through the SAN ANTONIO DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were The Huntington National Bank (53 loans); Northeast Bank (53 loans); Newtek Bank, National Association (40 loans); Zions Bank, A Division of (25 loans); Readycap Lending, LLC (24 loans); Live Oak Banking Company (20 loans); JPMorgan Chase Bank, National Association (18 loans); PlainsCapital Bank (18 loans). The most active 504 Certified Development Companies were Capital Certified Development Corporation (9 loans, $12,952,000); LiftFund, Inc. (4 loans, $2,764,000); Mortgage Capital Development Corporation (1 loan, $1,632,000); North Texas Certified Development Corporation (1 loan, $1,066,000); Greater East Texas Certified Development Company (1 loan, $929,000); Texas Certified Development Company, Inc. (1 loan, $714,000).

SBA 7(a) and 504 lending in the San Antonio 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 motels117$290,158,2000.0%30$56,258,000cohort under 30
Car washes22$29,582,300cohort under 3020$21,175,000cohort under 30
Self-storage17$24,779,700cohort under 307$6,807,000cohort under 30
RV parks and campgrounds5$10,466,000cohort under 30under 5
Assisted living and continuing care16$17,128,700cohort under 307$6,480,000no resolved loans
Gas stations and convenience stores65$96,907,5002.9%13$6,532,000cohort under 30
Restaurants, full and limited service281$149,748,80016.1%29$26,569,000cohort under 30
Fitness and recreational sports centers104$40,151,00014.3%5$4,495,000cohort under 30
Marinasunder 5under 5
Child day care services87$97,238,3003.8%23$21,067,000cohort under 30
All ten asset classes in this table714$756,160,5009.6%137$152,355,0006.0%

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 San Antonio 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 San Antonio urbanized core is therefore out. What remains in this metro is the outer parts of the eight member counties, beyond the urbanized area that runs with San Antonio and New Braunfels. 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.

A note on what this post does not claim

A San Antonio 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 San Antonio 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. CPS Energy (City of San Antonio municipally owned utility)
  5. Edwards Aquifer Authority
  6. San Antonio Water System
  7. 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 San Antonio Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/san-antonio-feasibility-market-2026

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