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SBA Approves Borrowers. Sites Kill Loans.

  • 4 hours ago
  • 36 min read

Nothing in 13 CFR 120.100 mentions dirt. Soil, groundwater, the floodplain line and the planning commission's hearing calendar kill SBA construction loans anyway. They just do it somewhere else in the file: in the cost stack, the interest reserve, the appraisal and the coverage ratio. Here is where to look.


MMCG Invest, September 2026

Two applications land on the same desk in the same week. Same franchise, same operator, same $2,400,000 request, same equity. One closes in ninety days. The other is still open at month eleven, with a Phase II in the file, a detention pond that ate the second building, and an interest reserve that ran dry in July.


Nobody on the credit committee will say the second loan died because of the site. The memo will say cost overrun, or schedule, or coverage. But that is what happened. The borrower was approved. The parcel was not.


We write feasibility studies for SBA 7(a), SBA 504 and USDA lenders across thirty-odd asset classes, and after a few hundred of them a pattern is hard to miss. The Small Business Administration underwrites the applicant, the use of proceeds and the business type. It never underwrites the ground. Eligibility lives in 13 CFR 120.100 and 120.110, and neither section contains the words soil, flood, contamination or zoning (3). Yet site conditions kill more ground-up files than credit does, and they do it through four numbers the SOP cares about very much: total project cost, time to certificate of occupancy, debt service coverage at stabilization, and collateral value.


That is the whole argument of this piece. Site risk is credit risk. It just arrives in disguise.

A word on the rulebook before we start. SOP 50 10 8 has governed since June 1, 2025, in the Technical Updates version issued May 28 of that year (1). SBA published SOP 50 10 8.1 on August 14, 2026 under Information Notice 5000-880695; it applies to applications assigned an SBA loan number on or after October 1, 2026, and files numbered by September 30 stay on version 8 (2). The 8.1 rewrite concentrates on change-of-ownership lending: a 1.25x coverage floor for first-time buyers, a Quality of Earnings report on purchases of $3,000,000 and up, a new Appendix 15 (2). It does not move the environmental, flood, appraisal or construction provisions this article is about, so everything below survives the transition. One caveat: appendix numbers shifted, and every page cite here should be re-checked against the live 8.1 PDF on October 1.



What SBA does not underwrite (and the two places the site sneaks in)

Read the eligibility chapter cold and the site is invisible. An applicant must be an operating for-profit business, must meet size standards, must show that credit is not available elsewhere, and must not be one of the excluded types listed in 120.110 (3). The closest the program comes to a location rule is occupancy: the borrower must occupy 51 percent of an existing building, or 60 percent of new construction, and speculative construction is barred outright (1). A leasehold must run at least as long as the loan where the improvements are substantial (1). None of that turns on what is under the slab.


The site enters the file in two chapters most people skim. Section A, Chapter 5, Paragraph C, pages 92 to 96, carries the insurance rules, including the flood mandate (1). Paragraph E, pages 100 to 108, carries the environmental policies, the escalation ladder and the appendices that go with it (1). Then Section B carries the construction rules: appraisal at completion, staged disbursement, the bonding threshold, equity in before the first draw (1). Between those three places the SOP has a great deal to say about ground it claims not to care about.


Notice the grammar, because it matters. The SOP never says a contaminated parcel is ineligible. It says a loan may not be approved or disbursed on a contaminated or actively remediating property unless the risk has been sufficiently minimized (1). It never says a floodplain parcel is ineligible. It says flood insurance is mandatory when any part of a collateral building sits inside a Special Flood Hazard Area and, in language new to version 8, that if required hazard insurance is not available the loan cannot be approved at all (1). Those are closing gates, not eligibility gates. An eligibility failure ends a file in a day. A closing gate keeps the file alive for months while the borrower spends money trying to get through it. That is why sites are more dangerous than ineligibility. Ineligibility is cheap.


We know of exactly one place where the dirt reaches back into eligibility itself, and it is worth stating because it is a gas-station problem that surprises someone every year. Where a third party holds a right to environmental indemnification that runs with the land, most often a fuel supplier or the oil company that once owned the corner, SBA requires that party to waive it on the SBA Environmental Indemnification Agreement. If the holder will not sign, the deal is not eligible for SBA financing, and no amount of borrower quality fixes it (31). Pull the deed chain before you pull the credit.


Everything else the site does, it does to the four numbers. Take them in the order the ground reveals them.


Ground: the cheapest report in the file changes the biggest number

A geotechnical investigation for a one-to-five-acre commercial pad is not expensive. A Texas testing firm's published schedule, dated 2020, priced two borings to twenty feet at $1,400 and each additional boring at $700; a deep program on a large site runs into the low five figures (18). Four to eight borings is typical for a pad that size, one to three days in the field, then a week or two in the lab (18)(19). The International Building Code requires the investigation before foundation design in any case (12). What is remarkable is how often it gets ordered after the purchase contract, after the pro forma, and after the lender has already read a hard-cost number that assumed a slab.


The report hands back a bearing value and a plasticity index, and those two figures decide the foundation system. IBC Table 1806.2 presumes 1,500 pounds per square foot for clay and 12,000 for crystalline bedrock; most real reports land between 2,000 and 3,000 (12). Below roughly 1,000 psf, shallow foundations are generally off the table (12)(19). And the cost gradient from shallow to deep is steep. Slab-on-grade prices at roughly $4 to $14 per square foot in 2026 aggregator data; deepened footings and stem walls at $6 to $21; a mat foundation at $6 to $12 before reinforcing steel (19). Once the soil forces drilled shafts, the unit changes from square feet to linear feet. The Wisconsin DOT average unit price list dated October 21, 2025 shows 24-inch shafts at about $65 to $71 per linear foot, 30-inch at $136 to $154 and 36-inch at $201 to $210 across the fiscal 2023 and 2024 lettings (15). A small-quantity TxDOT bid tab from January 2024 came in far higher, $431 per foot for 36-inch and $617 for 48-inch, which is what mobilization does to price when there are only a handful of shafts to drill (16). Driven precast piles run roughly $50 to $85 per foot in 2024 trade data and steel H and pipe piles $80 to $125; the Federal Highway Administration's older Central Artery study had precast at $22 to $80 (17)(19).


Put that on a building. A 40,000-square-foot single-story flex shell with a slab at $8 per square foot carries about $320,000 of foundation. Move the same shell onto Blackland Prairie clay with a plasticity index in the thirties, and the structural engineer will give you one of two answers. The first is chemical stabilization: lime-treat the pad and the paving at $2.50 to $5.00 per square yard for a six-inch lift, per 2026 Texas contractor data, which across the pad and three acres of parking is another $50,000 to $75,000 (20). The second is to carry the building on piers through the active zone, say 120 shafts at 25 feet and $150 per foot: $450,000 added, more than doubling the foundation line (15). Over-excavation and select fill sits between the two at roughly $25 to $35 per cubic yard combined on DOT proxy pricing (15)(19). None of those numbers were in the offering memorandum.


Expansive clay is not a Texas curiosity. The American Society of Civil Engineers estimates that a quarter of American homes carry some damage from expansive soils, and that in a typical year those soils cause more financial loss than earthquakes, floods, hurricanes and tornadoes combined (14). The USGS swelling-clay map, still the national reference nearly forty years on, shades the Texas Gulf Coast and Blackland Prairie, the Colorado Front Range, the Great Plains from the Dakotas down through Oklahoma, the Mississippi Valley and the interior California valleys (13). If your footprint includes any of those, the geotech is not diligence. It is the budget.



Water: the floodplain line, the wetland, and the fifth of the site you never get to build on

Three separate water problems live on a parcel, and each one hits a different number.

The floodplain hits the operating statement and, in bad cases, the closing. Under the Flood Disaster Protection Act, flood insurance is mandatory on any federally backed loan where a collateral building sits, in whole or in part, inside a Special Flood Hazard Area as shown on FEMA Form 086-0-32 (7)(6). Coverage must equal the lesser of the loan balance, the insurable value or the NFIP maximum, and the NFIP maximum for a nonresidential building is $500,000 for the structure and $500,000 for contents (5). That cap is the practical problem. Most commercial collateral exceeds it, which pushes the borrower into private or excess flood, and federal rules oblige the lender to accept a qualifying private policy (5)(1). Since Risk Rating 2.0 finished phasing in on April 1, 2023, the zone no longer sets the premium; distance to water, first-floor height, foundation type and replacement cost do, and commercial policies are capped at 25 percent annual increases on the glidepath, with new policies charged full-risk rates from day one (6). A parcel in an A or V zone carries roughly a one-in-four chance of flooding over a thirty-year mortgage (6). And 13 CFR 120.172 asks the applicant, before anything is approved, to show whether the site is in a floodplain or wetland, that the project complies with local land-use plans, and that the construction and use permits will actually issue (3)(8).


Two smaller points that catch lenders. NFIP will not cover a building under construction until the walls and roof are up, so a builder's risk policy has to bridge the gap (6). And 42 U.S.C. 4012a bars federally backed lending on SFHA property in a community that does not participate in the NFIP at all, which is a live issue on cheap rural land (7).


The wetland hits the schedule. Section 404 of the Clean Water Act splits sharply into two paths. A nationwide permit, where the site plan qualifies and a pre-construction notification is filed, cleared in an average of 45 days in the Corps' last published figures; a standard individual permit averaged 264 days (9). That is not a rounding difference. It is the gap between a spring start and a next-year start. In the Fort Worth District, losing more than a tenth of an acre of waters or 300 feet of streambed triggers compensatory mitigation, and mitigation is bought with credits whose prices vary by an order of magnitude: about $16,000 per credit at central Ohio banks, $25,000 near Katy, Texas, $60,000 to $100,000 for coastal Louisiana, and $50,000 to $195,000 in Florida's basin-restricted market (10)(11). The site plan that stays inside a nationwide permit is worth designing for.


The detention pond hits the pro forma, because it is the part of the site you paid for and cannot rent. The old civil-engineering rule of thumb set aside 15 percent of a greenfield parcel for surface detention. We stopped underwriting at 15 percent some time ago. Post-Harvey Houston requires 0.75 acre-feet of detention per acre on commercial sites, 0.85 in the TxDOT Houston District; Maricopa County requires full on-site retention of the two-hour, hundred-year storm; Austin caps impervious cover at 15 percent inside the Barton Springs Zone (21). Our working floor is now 20 percent of gross area, and constrained Sun Belt sites go to 25 or 30. Surface ponds are cheap to dig, under $1.00 per cubic foot in EPA's estimate, while underground systems run $8.50 to $17.00 per cubic foot installed in 2026 pricing, a ten-to-twenty-times premium that only pays when the land recovered is worth more than the vault (22).


Here is what the arithmetic does to a parcel. Take a rectangular commercial lot with depth one and a half times its frontage, a 50-foot front setback and 25 feet on the sides and rear, then subtract detention as a share of gross area.

Parcel

Gross SF

After setbacks

After 15% detention

After 20% detention

After 30% detention

2 acres

87,120

54,700 (63%)

41,700 (48%)

37,300 (43%)

28,600 (33%)

5 acres

217,800

164,400 (75%)

131,700 (60%)

120,800 (55%)

99,100 (45%)

10 acres

435,600

358,500 (82%)

293,200 (67%)

271,400 (62%)

227,800 (52%)

20 acres

871,200

760,600 (87%)

630,000 (72%)

586,400 (67%)

499,300 (57%)

Source: MMCG Invest. Setbacks 50 ft front, 25 ft sides and rear; parcel depth 1.5 times frontage; detention as a share of gross area. Parking, drive aisles and fire lanes come out of what is left.


On a two-acre pad, less than half the land you bought can hold a building or a lane before a single parking space is drawn. That is why the cheapest parcel is so rarely the cheapest site, and why a per-acre land price tells a lender almost nothing until the civil engineer has drawn the pond.



Environmental: the ladder, the committee and the $1,000,000 reliance letter

The environmental chapter is the one place where the SOP prices the site in weeks and money, if you read it that way. Section A, Chapter 5, Paragraph E opens with a warning that noncompliance may cost the lender its guaranty, and then lays out a ladder (1).


The first rung is a NAICS check. The lender makes a good-faith effort to identify the codes for the property's current use and every known prior use, then compares them to the environmentally sensitive list in Appendix 6 (1)(33). A match means a Phase I Environmental Site Assessment at minimum, regardless of loan size. No match, and the loan amount decides: up to $250,000, an Environmental Questionnaire can start the process; above $250,000, the questionnaire plus a Records Search with Risk Assessment (1)(32). From there the file escalates as the findings warrant: a Transaction Screen where the owner or operator will not sign the questionnaire, then a Phase I, then a Phase II with borings and sampling (1)(32). Reports must be dated within a year of the loan number; the Technical Update settled an older ambiguity on that point (32).


Appendix 6 is where asset classes sort themselves. Gas stations under NAICS 447 are on it and carry their own Appendix 7 on top. Dry cleaners with any history of chlorinated or petroleum solvents on site need a Phase I and a Phase II, no discussion. Funeral homes under 8122 are on the list unless there is no embalming or cremation at the property. Car-wash-only facilities get a carve-out and may start with a Transaction Screen (33)(32). A child-occupied building constructed before 1978 adds a lead risk assessment and drinking-water testing, again within a year of the loan number (32).


Every step up the ladder is time. A Phase I is weeks; a Phase II is months, because drilling contractors and laboratories have queues. And the ladder has a landing. Where contamination is found, the lender writes a recommendation covering the nature and extent, the remediation method, cost, status and completion date, who pays, the effect on collateral, and any mitigating factors (1). The tools available are limited and specific: the Appendix 8 Environmental Indemnification Agreement, which must be executed unaltered by a financially capable third party who is neither the applicant nor the operating company; a brownfield or agency-supervised cleanup; or reliance on "other factors" such as environmental insurance, which under version 8 must go to the SBA Environmental Committee for review even on a delegated loan (1)(32). The old option of asking SBA to concur with a lender's decision to stop investigating over the environmental professional's objection is gone; that is now a formal appeal (32).


Then there is the reliance letter, which is the part environmental consultants read most carefully. Every Transaction Screen, Phase I and Phase II must be accompanied by the Appendix 5 letter, under which the environmental professional waives any dollar limit on liability up to $1,000,000 and any time limit, authorizes both the lender and SBA to rely on the report, and certifies errors-and-omissions coverage of at least $1,000,000 per claim (1). Consultants price that letter into the report. It is one of the reasons an SBA Phase I costs more than a bank Phase I, and one of the reasons the cheap quote from a firm that has never issued one is not a bargain.


How often does the ladder find something? EPA counts 371,387 confirmed releases from underground storage tanks nationally, with 203,247 cleanups completed, and puts the average cleanup at $125,000 to $154,000 depending on the data vintage (26). California, which has just forced the closure of roughly 50,000 single-walled tanks, reported in January 2026 that about 30 percent of the tanks closed so far had leaked and that it expects a higher share among the rest (27). One more thing for the file: version 8 removed language that limited environmental review to real estate acquired, refinanced or improved with loan proceeds, but kept a proceeds-based trigger at Section B, Chapter 2, Paragraph C.3.d.vi, so the question of whether every pledged parcel needs review is genuinely unsettled. Ask SBA counsel and write down the answer (1)(32).



The hearing calendar: entitlements, fees, utilities and the interest reserve

The regulatory layer is where the site hits time to CO, and time to CO hits the interest reserve, which is the number that quietly decides whether the equity survives.


Entitlement paths cluster into three speeds. A by-right site plan or design review runs about three to six months. A conditional use permit or variance runs six to twelve. A rezoning or general plan amendment runs one to two years, and a contested one can run longer (61). Those are serial with permitting, not parallel: the hearings for a CUP or rezone typically add three to six months before a building permit application can even be filed (61). Florida enacted a 120-day deemed-approved rule in 2023 for complete permit applications, one of the few statutory shot clocks in the country (61). On the multifamily side, where the best data lives, the NAHB and NMHC's 2022 survey found that regulation accounts for 40.6 percent of development cost, that 93.9 percent of developers must rezone after gaining site control, and that neighborhood opposition, encountered by three quarters of respondents, adds 5.6 percent to cost and 7.4 months to completion (62). A UCLA and CSUN study of Los Angeles approvals found the approval phase alone consumed roughly 37 percent of a nearly four-year project timeline (61).


Then the fees. The last full national impact fee survey was completed in August 2019 across 270 jurisdictions; nothing comparable has been published since, so any 2026 memo citing per-thousand-square-foot nonresidential fees is citing seven-year-old data and should say so (63). What has not aged is the geography: Arizona, California and Florida charge the most, and California's combination of capped local taxes and generous enabling law has made impact fees close to universal there, while in most other states only water and sewer connection charges are ubiquitous (63). Our practice is to pull the fee schedule from the actual jurisdiction on every study and never to carry a survey average into a cost build-up.


Parking minimums are moving the other way, and that matters for land. As of August 2025, more than 3,700 cities in 22 countries had cut or eliminated parking mandates, more than 100 of them citywide; California's AB 2097 has barred minimums within half a mile of major transit since January 1, 2023 (64). Where minimums still bind, retail runs about four spaces per thousand square feet and fitness five to seven, and structured parking costs $30,000 to $40,000 a space, so a binding ratio either buys land or buys a variance (64). Where reform has removed the minimum, a site that was infeasible on paper last year may be feasible now.


Permitted use is asset-specific and worth reading in the code rather than assuming. Fort Worth requires a conditional use permit for an automated car wash within 200 feet of residential; Roseville, California demands at least 100 linear feet of stacking; Pembroke Pines, Florida demands 18 stacking spaces on the entrance side (41). Thousand Oaks bars self-storage within 1,000 feet of the 101 or the 23 freeway (41). Sumter County, South Carolina adopted an ordinance on January 13, 2026 that permits RV and boat storage in its agricultural-conservation and general-commercial districts only as a conditional use, with a 1,000-foot separation between facilities, a four-acre cap, a 50-foot paved drive from the right of way and a six-foot opaque fence (41). Norco, California keeps child care centers 500 feet apart (41). Each condition is a line item, and each hearing is a month.


Utilities are the sleeper. Extension charges are governed by published tariffs and they are not small: East Bay MUD's Schedule G, effective July 1, 2026, sets a $7,419 basic installation charge plus per-foot pricing for district-installed mains; Athens-Clarke County, Georgia charges $1.24 per linear foot of water main for fiscal 2026; NYSEG provides 500 feet of single-phase or 300 feet of three-phase overhead service free and bills the rest to the applicant (24). The acute problem in 2026 is not the tariff but the transformer. Wood Mackenzie's second-quarter 2025 survey put power transformer lead times at an average of 128 weeks; standard distribution units under 10 MVA had improved to eight to sixteen weeks, but one procurement source still cites 40 to 65 weeks for pad-mounts (23). Anything above distribution class means the transformer, not the contractor, sets the schedule. Ask the serving utility for the lead time in writing before the term sheet.


Access closes the loop. On a state highway, the driveway is a permit, and the permit can carry a turn lane. TxDOT's Access Management Manual sizes deceleration lanes from forecast turning movements and requires a traffic impact analysis where spacing standards cannot be met; MassDOT's guidance sets corner clearance at a 50-foot minimum and 75 feet recommended, and a restrictive median can push a busy corner to right-in, right-out (25). A single deceleration lane with drainage runs from $30,000 or so into the low $100,000s once drainage is included, and the design review runs weeks to months (25).


Now convert all of that into the number lenders actually feel. WSJ Prime has been 6.75 percent since the Fed's December 11, 2025 cut (65). Under version 8 the maximum 7(a) variable spread is set by loan size alone: Prime plus 6.5 points up to $50,000, plus 6.0 to $250,000, plus 4.5 to $350,000, and plus 3.0 above that, so a construction loan above $350,000 caps at 9.75 percent today (65)(3). The FDIC's primer sizes an interest reserve as the average outstanding balance times the rate times the term, and a straight-line draw schedule averages about half the commitment outstanding (66). A $2,000,000 loan at 9.75 percent with a twelve-month build therefore needs roughly $97,500 of reserve. Let the planning commission add six months, and the reserve needs $146,250. The hearing calendar just cost the borrower $48,750, and if the reserve was sized to the base case, the shortfall comes out of working capital in the exact months the business is supposed to be ramping (66).


The SBA rules around that reserve are asymmetric and worth knowing. On the 504 side, Procedural Notice 5000-872764, effective September 30, 2025, raised the construction contingency from 10 to 15 percent of construction cost, with any residual up to 2 percent of the debenture refundable to the borrower as working capital and anything above that reducing the debenture; it is a 504-only change and runs ahead of 13 CFR 120.882(b), which still reads 10 percent (4)(3). On the 7(a) side there is no codified contingency or interest reserve; the lender structures an interest-only construction period followed by amortization, includes the reserve within eligible proceeds at its discretion, and the SBA terms page allows the real-estate portion a 25-year term plus the period needed to complete construction (1)(65). Either way, version 8 requires an appraisal at completion value, a post-completion statement that the building went up with only minor deviations from the plans, staged draws against verified progress with lien waivers, equity injected before or at disbursement, and a payment-and-performance bond on construction above $350,000 unless waived, a threshold the new SOP lowered from $500,000 (1)(3)(67). We covered the cost build-up and contingency mechanics at length in The Construction Loan Feasibility Study and will not repeat them here. This article is about where the numbers in that build-up come from.



Five asset classes, five site signatures

The four channels are universal. The mix is not. Each asset class we underwrite has a dominant site risk that shows up first and costs most, and a lender who knows the signature can order the right report before the letter of intent instead of after the appraisal.


Gas station: the environmental file is the deal

Gas stations are the only asset class here where SBA mandates a Phase I regardless of loan size; the questionnaire and records search that satisfy other files will not (31)(1). The Phase I must be prepared by an independent environmental professional, must examine records for the property and the adjoining parcels, must document compliance with tank and line testing, must include the results of any Phase II the professional recommends (performed by a PE or PG with at least three years of relevant experience), and where the site is contaminated must carry a description and cost estimate for remediation (31). Then the indemnification trap described earlier: an unwaived third-party indemnification right running with the land makes the loan ineligible, full stop (31).


The money follows the tanks. A clean closure of a three-or-four-tank system with piping and dispensers runs $50,000 to $150,000 in 2026 contractor pricing; discover contamination and the range moves to $125,000 to $300,000 or more; free product and an off-site benzene plume push past $1,000,000 (28). State trust funds are uneven and cannot be assumed: Illinois pays up to $1,500,000 per occurrence, California's fund allows $1,000,000 per claim with a $5,000 to $10,000 deductible, Connecticut caps reimbursement at $1,000,000 with a $10,000 deductible, while Texas' fund covers only tanks registered by December 31, 1995 and Florida's stopped accepting new claims long ago (30). If the file involves a station that has run fifteen years or more on single-wall steel, budget a contamination contingency; California's 30 percent leak rate on closed single-wall tanks is the best benchmark available (27). A replacement system is its own line: a 13,000-gallon fiberglass tank is about $40,000, dispensers $20,000 to $45,000 each, a canopy $50,000 to $120,000, and a full multi-tank build-out with monitoring $250,000 to $475,000 (29). Permits typically take eight to sixteen weeks, tank installation twelve to thirty, testing and weights-and-measures certification another four to eight (29).


Access is the second signature, because stations live on corners. State access manuals set corner clearance and may restrict a busy corner to right-in, right-out; Salt Lake City requires 36 feet of stacking between the curb cut and the nearest pump and requires that every queued car fit on site; Elk Grove, California limits fueling stations to two driveways and 35 percent of frontage in curb cuts (25)(41). A site that cannot queue cars off the public street will not get its permit, and a site that loses its median cut loses a third of its trade area.


Our gas station work: Gas Station Feasibility Study, Gas Station Site Selection, engagements in California, Georgia, Kansas, Arizona and Missouri on our Engagement Portfolio, and the U.S. Oil Infrastructure Map.


Car wash: the lightest SBA file and the heaviest local one

SBA treats a car-wash-only facility gently. Appendix 6 lists automotive repair and maintenance under 8111 but carves out car-wash-only sites, which may begin with a Transaction Screen rather than a Phase I; add fuel, servicing or a dry-cleaning history and the Phase I mandate returns (33)(32). The federal file, in other words, is rarely the problem. The city is.


Water first. The International Carwash Association's 2018 metered study put an exterior conveyor tunnel at an average of 30 gallons of fresh water per vehicle, with about a fifth lost to evaporation and carryout and never reaching the sewer; Arizona DEQ's figures are 43.8 gallons per vehicle for a conveyor and 72.5 for an in-bay automatic (34)(35). Reclaim systems recover 60 to 85 percent, and the association's WaterSavers program certifies washes at 40 fresh gallons or fewer (34). The utility then prices that flow twice: through a pretreatment permit and interceptor sizing (Austin Water requires a sand-oil interceptor starting at 20 gallons per minute for a single bay plus 12 per additional bay, with a twelve-minute retention time and a sample port) and through capacity or impact fees tied to metered demand (36). San Marcos, Texas has required recycling on every new automatic wash since 2015 and caps use at 55 gallons per vehicle (37). Wichita Falls has closed washes two days a week under stage-five drought; Brownsville in April 2024 barred new washes within five miles of each other; Edinburg followed with its own restriction, citing historic lows on the Rio Grande (38).


Then the moratoriums, which are the fastest-moving site risk in this list. Birmingham, Alabama adopted a 180-day pause on March 5, 2024, extended it repeatedly, passed a fresh 120-day version on January 14, 2025 and extended that in June (39). Warren, Michigan, the state's third-largest city, approved an eight-month moratorium on new gas stations and car washes in May 2026; Roseville, Michigan extended its own the same month; Hemet, California simply discontinued new car washes across its commercial and manufacturing zones in 2024 (39). Mission, Texas approved a 180-day moratorium on March 24, 2026 and promptly collided with HB 2559, effective September 1, 2025, which limits municipal development moratoriums and requires two hearings thirty days apart (39)(40). Perrysburg, Ohio lifted its ban early (39). An enacted moratorium is not a pricing issue. It is a deferral or a decline, however good the operator.


Where washes are allowed, the conditions are specific. Fort Worth requires a CUP within 200 feet of residential and a 25-foot front setback; Ada County, Idaho wants 100 feet from any residential district; Pembroke Pines bans powered hand tools outside the enclosure unless the lot is 500 feet from homes, bars tunnel openings facing residential and requires 18 stacking spaces; Coral Springs makes the applicant pay for an acoustical study; Independence, Missouri wants ten stack spaces per bay (41). Every one of those conditions is either land or a hearing, and on a two-acre corner it is usually both.


Our car wash work: Car Wash Feasibility Study, Car Wash Site Selection, and engagements in Florida, South Carolina, Maryland and Georgia with total project costs from $3,800,000 to $10,300,000 on the Engagement Portfolio.


RV and boat storage: a land play wearing a building's clothes

Storage for boats and RVs is the purest site play in SBA lending, and that is the collateral problem. Improvements on an open lot, meaning grading, paving, fencing, lighting and security, run $5 to $15 per square foot, with no vertical value at all; under a canopy the steel is only about a quarter of a $32-per-square-foot turnkey budget; a fully enclosed metal building runs $50 to $65 turnkey (42). Buildable coverage lands at 35 to 40 percent of each acre, so 60 to 65 percent of the land acquired is aisles, setbacks and drainage that generate no rent (42). The value of the finished facility is therefore mostly the value of the land it sits on.


SBA's collateral policy then does what it does to land. As SBA counsel summarize the discounting carried into version 8, improved real estate is taken at about 85 percent of value, unimproved real estate at about 50, and going-concern intangibles at zero, and the appraiser must be a certified general with recent special-use experience (43). Appraisers classify RV storage as a limited-market, special-purpose property, which drives the valuation toward the cost approach, and when the improvements are minimal the cost approach collapses toward land value (44). In a forced sale a canopy yard is a fenced field. Size the loan to land plus hard improvements, not to stabilized enterprise value, and treat an enclosed-building format as the one design choice that materially improves recovery (42)(43).


The second signature is water, because the cheapest big parcels are in the floodplain. Operators describe storing on floodplain land where the county allowed gravel and a fence but no elevation change, and where the lender then required flood coverage on everything; an SFHA carries about a one-in-four chance of flooding across a thirty-year loan, floodplain development permits explicitly reach storage yards, and federal law bars the loan entirely in a non-participating community (7)(6). Surfacing rules follow: Broward and Palm Beach counties require paved surfaces rather than gravel, and Maricopa County requires a dust-control permit for disturbing a tenth of an acre and dust control on any unpaved area used to park or store vehicles (46). Fire code is the third: 20-foot access lanes within 150 feet of every building, hydrants within 400 feet, turnarounds on dead ends over 150 feet, and a 75,000-pound design load on the access surface (45). Zoning is the fourth: industrial districts are the most permissive, commercial districts allow it with conditions, and residential prohibits it; Riverside, California wants a commercial storage overlay plus a CUP, and typical setbacks run 25 to 50 feet on the road with 50-to-100-foot buffers against homes (42)(41). We have two Central Texas storage files open as this is written, and on both the detention pond and the fire lane decided the unit count before the market study did.



Hotel: the site is insurable, or it is not a site

Select-service hotels are less soil-sensitive than the three assets above and far more insurance-sensitive, and version 8 made that a closing rule: if required hazard insurance is unavailable, the loan cannot be approved (1). On the coast that is not hypothetical. Admitted carriers routinely exclude named windstorm and surge on coastal hotel programs, pushing owners into wind-only excess and surplus markets with percentage deductibles of 1 to 10 percent of insured value that trigger the moment the National Hurricane Center names the storm; nineteen states plus the District of Columbia now permit hurricane or named-storm deductibles, and Florida and Louisiana lean on their state residual insurers where the private market has left (50). A coastal hotel with strong projected cash flow can still fail at closing because no carrier will write the wind. Get the quote bound before commitment, not before disbursement.


The physical site drivers are conventional but binding. Hotels average 1.24 parking spaces per room nationally and the number has been falling with the shift to limited-service, but the code governs: San Diego requires a space per room in its beach impact area, Salt Lake City one per two rooms (47)(48). Traffic impact studies typically trigger around 100 new peak-hour trips or 750 daily; Harford County, Maryland requires a full study above 249 trips a day (49). Height limits in the commercial districts we sampled push a hotel over 75 feet into a use permit (41). And a four-story wood-frame hotel puts real load on the ground: IBC Table 1806.2 governs, sites under roughly 1,000 psf need deep foundations, and rammed aggregate piers at 4,000 to 6,000 psf are the usual middle-cost answer (12)(19).


The brand sets the parcel. Home2 Suites was launched on a prototype that fits on a little under two acres, four stories, 108 keys, 56,668 gross square feet, and recent builds have landed on 2.24 acres with 83 stalls; Tru by Hilton runs four stories and 80 to 120 keys; Holiday Inn Express moved to its Formula Blue 2.2 prototype in December 2023, raising the key count from 93 to 104 on the same site size, with new builds typically on 1.4 to 3 acres (51). The oft-quoted 2.5-acre minimum belongs to the full-service Holiday Inn H4 prototype, not to Express, and should not be carried into an Express pro forma (51). Franchisors publish the footprint but keep the visibility and access standards in the brand manual; ask for the manual.


Absorption is the number lenders get wrong. STR's data on new-construction hotels show occupancy starting around 58 percent in month one and reaching a 100 percent RevPAR index at about month 17, with Miami reaching index by month seven and New York not until month 35; the Cornell and ISHC work on 3,699 hotels supports a roughly three-year build to mature operation, a difference in definition rather than a contradiction (52)(53). The 1.15x coverage floor for standard 7(a) loans above $350,000 is tested on projected cash flow, and a new hotel runs below 1.0x for most of its first year; the interest reserve and working capital have to bridge to the month coverage clears the floor, tested monthly, because a fixed payment lands the same in a January trough as in a July peak (31)(1).


Assisted living: the license, the occupancy classification and the census curve


Assisted living adds a fourth clock the other assets do not have: the state. Certificate-of-need programs exist in roughly 35 to 38 states plus the District, depending on who is counting and when; many of them apply to nursing beds and exempt assisted living, several run moratoria on specific bed types, and the answer changes by state and by year (54). Florida repealed most of its CON in 2019 but kept it for nursing homes; Montana kept only nursing homes in 2021 (54). Licensure runs on its own calendar after the certificate of occupancy, and it adds months that have nothing to do with construction (55). Verify the state's position in writing before sizing the timeline, and carry licensure as a separate line on the schedule.


The building code then draws a line at seventeen. Group R-4 covers six to sixteen residents; the seventeenth resident pushes the building to Group I-1 if residents can evacuate themselves or I-2 if they cannot (56). All R and I occupancies are sprinklered, but R-4 may use the lighter NFPA 13R standard while I-2 requires NFPA 13 throughout, 96-inch corridors and one-hour corridor ratings for defend-in-place egress (56). That is a cost cliff, not a gradient, and the design that tips a community past sixteen residents pays it in full. Add the generator: Florida rule 59A-36.025 requires an alternate power source that holds ambient temperature at or below 81 degrees for at least 96 hours after loss of primary power, sized at 20 net square feet per resident at 80 percent of licensed capacity, and other Gulf and Atlantic states have followed (57). A large single-story footprint spreads its load, but on soft soils it spreads it over more of them, and the same IBC investigation rules apply (12).


Zoning is residential and conditional. Virginia deems a facility of eight or fewer a single-family use by statute; above that the community goes to a hearing (58). Sugar Land, Texas caps density at 25 beds per acre with buffers and screening; Baltimore County ties parking to beds at one per three; a California memory care project needed an irrevocable annexation agreement just to get sewer (58). High water use mak

es sewer capacity the utility to check first.


Then the census curve, which is the DSCR problem in its purest form. New assisted living and memory care communities take 18 to 30 months to reach stabilized census, memory care at the long end; operators quoted in 2023 were targeting 88 percent over twelve to eighteen months and leasing 19 of 32 memory care units on an eighteen-month plan (59). The sector tailwind is real: NIC MAP reported first-quarter 2026 senior housing occupancy at 89.5 percent, the nineteenth consecutive quarterly gain, on record-low inventory growth of 0.4 percent (60). But the tailwind does not change the first year. A new community runs below 1.0x coverage through fill-up, the SBA floor is 1.15x on projected cash flow, and a projection that clears the floor only in the base case is a warning rather than a conclusion (31)(1).


Our senior living work: Assisted Living Feasibility Study, Senior Living Feasibility Study, Assisted Living and Memory Care: Revenue Durability and Project Feasibility, and the Phoenix memory care and 96-unit assisted living and memory care engagements on the Engagement Portfolio.



What to require in the feasibility study

A lender cannot re-engineer the site. A lender can refuse to size the loan until the study has. Here is what we put in ours, in the order the questions get cheaper to answer.

Before the letter of intent, at a cost of days:

  • A USGS swelling-clay screen, a FEMA FIRM pull and a National Wetlands Inventory check on the parcel, with the SFHA status stated in one sentence.

  • The NAICS position on the Appendix 6 ladder for the current use and every known prior use, so the environmental scope is known before it is quoted.

  • The entitlement path classified as by-right, conditional use or rezoning, with the jurisdiction's own hearing calendar converted to months.

  • The utility's transformer lead time and line-extension tariff in writing, and the state DOT's access classification for the frontage.

During diligence, at a cost of weeks:

  • The geotechnical report, ordered before the hard-cost number is written, with the bearing value, plasticity index and recommended foundation system carried into the cost build-up as their own lines.

  • The environmental report at the rung the ladder requires, with the Appendix 5 reliance letter attached and dated within a year of the expected loan number.

  • Insurance quotes bound, not indicated, for hazard, wind and flood, with the NFIP cap and any excess layer shown against replacement cost.

  • The civil engineer's detention volume and the buildable-area table above, run at 20 percent detention, with parking and fire lanes drawn.

At commitment:

  • The cost build-up on Marshall & Swift with site work, foundations, utilities, access improvements, impact fees and mitigation credits itemized, and contingency at 15 percent for 504 files.

  • The interest reserve sized to the longest-lead item on the schedule, which in 2026 is often the transformer or the hearing rather than the contractor, with the delay case shown.

  • DSCR modeled monthly through the ramp, not annually at stabilization, with the month coverage first clears 1.15x identified.

  • Collateral split into land and improvements at SBA's discounts, so the committee sees what the guaranty actually rests on.


Our methodology and the bankable study format are described at Methodology and Bankable Feasibility Study. The two SBA pieces that precede this one, The SBA Feasibility Study Requirement That Does Not Exist and SBA Will Not Decline Your Loan for Collateral, cover the requirement and the guaranty questions this article leaves alone. The Seismic Risk Map and our note on Building in FEMA Flood Zones cover two of the screens above in more depth.


The borrower was never the problem

The borrower in our opening was never the problem, and the credit memo never said otherwise. The site was the problem, and the memo could not say so because the SOP does not give it the vocabulary. It has words for cost overruns, coverage shortfalls and schedule slips. It does not have a word for clay.


That is the lender's job, and the feasibility consultant's. Order the geotech before the offer. Read the code, not the broker's summary. Get the wind quote bound. Draw the pond before the parking. Size the reserve to the hearing. SBA will approve the borrower. It is up to the rest of us to make sure the site does not take the loan back.


Frequently asked questions

Does SBA require a geotechnical or soil report for a construction loan? Not by name. SOP 50 10 8 requires an appraisal at completion value, staged disbursement against verified progress and a post-completion statement that the building matches the plans; the International Building Code requires a geotechnical investigation before foundation design; and a lender-grade feasibility study should not carry a hard-cost number without one. In practice the report is required by the building department and by prudence, not by the SOP.


Does SBA require an environmental report on every real estate loan? Every loan secured by commercial real estate goes through the environmental ladder in Section A, Chapter 5, Paragraph E. What starts the ladder depends on the NAICS match and the loan size: a Phase I for environmentally sensitive uses regardless of amount, an Environmental Questionnaire for non-sensitive uses up to $250,000, and a questionnaire plus a Records Search with Risk Assessment above that. The scope question for parcels not acquired or improved with loan proceeds is unsettled in version 8; confirm with SBA counsel.


Can SBA finance a property in a FEMA flood zone? Yes. A Special Flood Hazard Area location triggers mandatory flood insurance at the lesser of loan balance, insurable value or the NFIP maximum ($500,000 building and $500,000 contents for nonresidential), usually with a private or excess layer above the cap. What SBA will not do is approve a loan where required insurance is unavailable, or lend on SFHA property in a community that does not participate in the NFIP.


Can a contaminated site get an SBA loan? Sometimes. The SOP bars approval or disbursement on a contaminated or actively remediating property until the risk is sufficiently minimized, and it lists the tools: a third-party Appendix 8 indemnification, an agency-supervised cleanup, or other factors such as environmental insurance reviewed by the SBA Environmental Committee. Each path adds months. A gas station where a third party will not waive its environmental indemnification right is the one case that is ineligible outright.


How much does a six-month entitlement delay cost an SBA construction borrower? At today's 9.75 percent cap on 7(a) loans above $350,000, and using the FDIC convention of half the commitment outstanding on average, a $2,000,000 construction loan needs roughly $97,500 of interest reserve for a twelve-month build and $146,250 for eighteen. The delay costs about $48,750, and it comes out of working capital if the reserve was sized to the base case.


What changed for site risk in SOP 50 10 8 and 8.1? Version 8, effective June 1, 2025, added the rule that a loan cannot be approved if required hazard insurance is unavailable, raised the RSRA threshold to $250,000, formalized Environmental Committee review of "other factors," lowered the automatic bond-waiver threshold to $350,000 and set 7(a) rate caps by loan size only. Procedural Notice 5000-872764 raised the 504 contingency to 15 percent on September 30, 2025. Version 8.1, effective for loan numbers issued on or after October 1, 2026, rewrites acquisition underwriting and leaves the site provisions in place; appendix numbers moved, so cites should be re-verified.


Which asset class carries the most site risk? Gas stations for environmental, car washes for local regulation and water, RV and boat storage for collateral, hotels for insurance and absorption, assisted living for licensing, life-safety classification and fill-up. Every one of them can be underwritten. None of them can be underwritten from the purchase price.


September 2, 2026 by Michal Mohelsky, principal of MMCG Invest, LLC, a national SBA and USDA feasibility study consultancy




Michal Mohelsky, J.D. | Principal | mmcginvest.com 

Phone: (628) 225-1125




Disclaimer: This report is provided for informational purposes only and does not constitute investment, legal, or tax advice. Data presented herein is derived from proprietary MMCG databases and third-party sources believed to be reliable; however, MMCG Invest makes no representation as to the accuracy or completeness of such information. Figures from third-party industry databases have been independently verified and, where appropriate, adjusted to reflect MMCG's proprietary analytical methodology. Statutory and regulatory references are provided for context and must be verified with counsel before reliance. Past performance is not indicative of future results.


Sources

(1) U.S. Small Business Administration, SOP 50 10 8, Lender and Development Company Loan Programs, effective June 1, 2025; Technical Updates version issued May 28, 2025 under Information Notice 5000-868665. Section A, Chapter 5, Paragraphs C and E; Section B; Appendices 5, 6, 7 and 8. (2) U.S. Small Business Administration, Information Notice 5000-880695, Issuance of SOP 50 10 8.1, published August 14, 2026, effective October 1, 2026; as reported by NAGGL and Coleman Report. (3) 13 CFR Part 120, including Sections 120.100, 120.110, 120.172, 120.174, 120.200, 120.214 and 120.882. (4) U.S. Small Business Administration, Procedural Notice 5000-872764, 504 loan program construction contingency, effective September 30, 2025. (5) Congressional Research Service, National Flood Insurance Program coverage limits (IF10988) and program overview (R45999). (6) FEMA, Standard Flood Hazard Determination Form (FEMA Form 086-0-32); Risk Rating 2.0 implementation schedule and premium glidepath (floodsmart.gov); NFIP treatment of buildings under construction. (7) Flood Disaster Protection Act of 1973, 42 U.S.C. 4012a. (8) Executive Order 11988, Floodplain Management, and Executive Order 11990, Protection of Wetlands. (9) U.S. Army Corps of Engineers, Reissuance and Modification of Nationwide Permits, final rule, Federal Register, December 27, 2021; 33 CFR Part 330. (10) U.S. Army Corps of Engineers, Fort Worth District, compensatory mitigation thresholds, as summarized by Halff Associates; USACE and EPA Compensatory Mitigation Rule, 2008. (11) Mitigation credit pricing: EASI Mitigation Credit Price Report, January 2024 edition; Mitigation Banking Group, Florida credit listings; Fenstermaker, Louisiana credit pricing; Kenyon College compilation of Midwest and Texas bank pricing; USACE RIBITS. (12) International Code Council, International Building Code 2024, Section 1803 (geotechnical investigations) and Table 1806.2 (presumptive load-bearing values). (13) U.S. Geological Survey, Swelling Clays Map of the Conterminous United States, Miscellaneous Investigations Series Map I-1940 (Olive, Chleborad, Frahme, Shlocker, Schneider and Schuster, 1989). (14) American Society of Civil Engineers, estimate of expansive-soil damage, as reported by geology.com. (15) Wisconsin Department of Transportation, Average Unit Price List, fiscal years 2023 to 2025, dated October 21, 2025. (16) Texas Department of Transportation, Fort Bend County bid tabulation, letting of January 9, 2024. (17) Federal Highway Administration, Central Artery/Tunnel pile cost study, FHWA-HRT-05-159. (18) Geotech Engineering and Testing (Texas), published boring fee schedule, 2020; Minnesota Rules 2890.3300, maximum reimbursable boring costs, published December 12, 2025. 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(27) California State Water Resources Control Board, press release on single-walled underground storage tank closures, January 14, 2026. (28) USTContractors.com, Underground Storage Tank Removal Cost in 2026; UST Compliance Deadlines by State. (29) CommTank, gas station fuel tank and construction cost guides; StartupCostGuide, Cost to Start a Gas Station, 2025 (citing NACS); USTContractors.com, New Mexico tank installation pricing. (30) Illinois Underground Storage Tank Fund; California UST Cleanup Fund; Connecticut General Assembly, OLR Report 2010-R-0066; ASTSWMO, State Fund Survey list, March 2012; Texas Commission on Environmental Quality, Petroleum Storage Tank Remediation Fund; Florida Senate, SB 5701 (2026) analysis. (31) Starfield & Smith, Best Practices: SBA Gas Station Loans, June 26, 2024; Best Practices: SOP 50 10 8 Update, New 7(a) Small Loan Underwriting Requirements, January 2026; Best Practices: Flood Insurance Requirements, February 2020. (32) Partner Engineering and Science, SBA Environmental Policy Update: Navigating SOP 50 10 8, 2025; SBA environmental flowchart for SOP 50 10 8 with Technical Updates, April 2025. (33) A3 Environmental, NAICS Codes for Environmentally Sensitive Industries (summary of SBA Appendix 6). (34) International Carwash Association, Water Use, Evaporation and Carryout in Professional Car Washes, 2018; WaterSavers program criteria. (35) Arizona Department of Environmental Quality, vehicle wash water use figures. (36) Austin Water, Car Wash Sand/Oil Interceptor Sizing and Design Criteria. (37) City of San Marcos, Texas, Code of Ordinances Section 14-121 (2015). (38) National Drought Mitigation Center, Drought Impact Reporter, September 24, 2024 (Brownsville and Edinburg, Texas); Professional Carwashing and Detailing, Wichita Falls drought restrictions. 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(43) Ward and Smith, Best Practices When Liquidating Real Estate Secured SBA Loans (SBA collateral discount summary carried into SOP 50 10 8). (44) Appraisal Institute, The Appraisal of Real Estate, special-purpose and limited-market property definitions. (45) International Code Council, International Fire Code 2018, Chapter 5, Fire Service Features, and Appendix D. (46) Maricopa County Air Quality Department, dust control rules for vacant lots and unpaved areas; 40 CFR 52.128; Broward and Palm Beach County surfacing requirements as summarized by RecNation. (47) CoStar and STR, hotel parking ratios by class. (48) San Diego Municipal Code, Chapter 14 (March 2026 edition); Salt Lake City parking calculator. (49) Morgan County, Georgia, Article 16, Traffic Impact Analysis; Knox County, Tennessee, Transportation Impact Analysis Guidelines, 2020; Harford County, Maryland, Traffic Impact Analysis Guidelines, Fourth Edition, February 2024. (50) National Association of Insurance Commissioners, hurricane and named-storm deductibles, June 2025; Insurance Information Institute; Iconn Insurance Solutions, coastal hospitality wind coverage; Atesa Risk Advisors, Florida SBA loan closing insurance requirements, 2026. (51) Hilton, Home2 Suites brand launch (CoStar and Hospitality Net, 2011) and Home2 brand brochure, 2019; Florida YIMBY, 2026 (Loxahatchee Home2); Hilton Newsroom, Tru by Hilton milestone, 2024; Hotel Business, Holiday Inn Express Formula Blue 2.2 prototype, December 2023, and IHG prototype commentary; IHG Development, Holiday Inn Express pipeline as of June 30, 2026. (52) STR, Hotel Data Conference presentation on new-construction ramp-up, as reported by CoStar and Hotel News Now, September 12, 2019. (53) International Society of Hospitality Consultants and Cornell University, Hotel Occupancy: Is the Three-Year Stabilization Assumption Justified?; Hospitality Net, Operational Budgeting for Hotel Openings, 2023. (54) National Conference of State Legislatures, Certificate of Need State Laws; National Academy for State Health Policy, 50-state CON scan, updated December 12, 2025; Institute for Justice, The State of Certificate of Need Laws Around the Country. (55) American Health Care Association and National Center for Assisted Living, Assisted Living State Regulatory Review, 2025. (56) International Building Code, Sections 308, 310, 903.2.6 and 903.2.8, as explained by the National Fire Sprinkler Association (2025) and DataDrivenAEC (2024). (57) Florida Administrative Code Rule 59A-36.025, Emergency Environmental Control for Assisted Living Facilities (2018). (58) Code of Virginia Section 15.2-2291; City of Sugar Land, Texas development code; Baltimore County, Maryland, zoning information for small assisted living facilities; Los Angeles Municipal Code Section 12.21; San Bernardino LAFCO, CEQAnet filing (memory care sewer annexation). (59) Senior Housing News, Accelerating Move-Ins Drive Memory Care Optimism, May 5, 2023. (60) National Investment Center for Seniors Housing and Care (NIC MAP), senior housing occupancy releases for the third quarter of 2025 and the first quarter of 2026 (April 23, 2026). (61) Shovels, land entitlement analysis; Barnes Walker, entitlement process glossary; Terrapin Construction Group, Florida permit timelines; Gabriel and Kung, Development Approval Timelines, Approval Uncertainty, and New Housing Supply (UCLA Ziman Center and CSUN). (62) National Association of Home Builders and National Multifamily Housing Council, Regulation: 40.6 Percent of the Cost of Multifamily Development (Emrath and Sugrue Walter), June 9, 2022. (63) Duncan Associates, National Impact Fee Survey: 2019 (Clancy Mullen, August 18, 2019); Duncan Associates, 2008 and 2012 surveys. (64) NAIOP, Eliminating Parking Mandates to Tackle the Housing Crisis, Fall 2025 (citing the Parking Reform Network Mandates Map); California AB 2097 (2022); California HCD technical assistance, April 2026; MMCG Invest, Gym and Fitness Feasibility Study (parking ratios). (65) HSH.com, Wall Street Journal Prime Rate history, September 2, 2026; U.S. Small Business Administration, 7(a) loan terms, conditions and eligibility; Federal Register, 7(a) alternative base rate notice. (66) Federal Deposit Insurance Corporation, A Primer on the Use of Interest Reserves; interest-reserve sizing conventions as described by FNRP, PropertyMetrics and Tactica RES. (67) Interagency Appraisal and Evaluation Guidelines, December 2010 (as-is, as-completed and as-stabilized values).

 
 
 

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