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The St. Louis 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

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

St. Louis 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 city that is also a county, with no county government above it. Article VI section 31 of the Missouri Constitution recognises the city of St. Louis, as now existing, both as a city and as a county. This is not trivia: it means the taxing, permitting and assessment stack for a site inside the city has one fewer layer than a site in St. Louis County a mile away, that the two are governed by different bodies with different rates and different review calendars, and that any comparison of a city site to a county site is a comparison across jurisdictions rather than within one. A study that treats St. Louis County as the county containing the City of St. Louis has the geography wrong and will carry the wrong tax and permitting assumptions all the way through.

An earnings tax that must be re-approved by the voters every five years. Missouri law provides that after December 31, 2011 no city, including any constitutional charter city, shall impose or levy an earnings tax, except that a constitutional charter city that imposed one on November 2, 2010 may continue it if it puts to its voters the question whether to continue the tax for a period of five years and a majority voting on the question approve it; if no election is held, or if the voters fail to approve continuation, the city is no longer authorised to impose the tax except to reduce it as the statute provides, and the summary of the law states that in that case it is phased out over a period of ten years. Underwriting practice follows: a ten-year projection for a city site cannot simply hold the earnings tax constant, nor assume it away, and the honest treatment states the renewal cycle and models the operator's exposure both ways rather than silently picking one.

The New Madrid seismic zone. The U.S. Geological Survey records that in the winter of 1811 and 1812 the New Madrid seismic zone generated a sequence of earthquakes including three estimated between magnitude 7 and 8, which destroyed settlements along the Mississippi River and caused minor structural damage as far away as Cincinnati and St. Louis. The relevant point for a feasibility study is that this is an inland metro where seismic design, and the insurance question behind it, are live rather than nominal. A construction budget copied from a comparable project in a low-hazard inland market will understate structural cost, and a property insurance assumption carried over from such a market will understate premium and deductible structure. A defensible file states the seismic assumption explicitly and names its source rather than leaving it to a national template.

Three jurisdictional layers in one metro: the city, the Missouri counties, and Illinois. The two Missouri instruments above do not apply uniformly even within Missouri: the earnings tax is levied by the City of St. Louis, and the city-county structure is the city's alone. Around it sit ordinary Missouri counties with a county government the city does not have, and the metropolitan statistical area is delineated across Missouri and Illinois, with the member-county list taken from the Census delineation file naming counties in both. A project therefore falls into one of three quite different stacks, and they differ in the number of taxing layers, in whether an earnings tax applies at all, and in which state's assessment and incentive law governs. Establishing which stack the address sits in is the first site-work step here, not a formality, and a study that treats the metro as one jurisdiction will carry the wrong tax line from its first page to its last.

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

In fiscal year 2025 the St. Louis metro recorded 491 7(a) approvals for $264,149,700 and 54 504 approvals for $77,808,000, filed largely through the ST. LOUIS DISTRICT OFFICE. The most active 7(a) lenders in the metro that year, by approval count, were U.S. Bank, National Association (86 loans); Northeast Bank (39 loans); Newtek Bank, National Association (30 loans); Midwest Regional Bank (25 loans); The Huntington National Bank (20 loans); Live Oak Banking Company (17 loans); Readycap Lending, LLC (15 loans); Bank of Springfield (12 loans). The most active 504 Certified Development Companies were St. Charles County Economic Development Council (25 loans, $30,755,000); Rural Missouri, Inc. (12 loans, $28,290,000); Small Business Growth Corporation (9 loans, $7,744,000); SomerCor 504, Inc. (4 loans, $7,452,000); STL Partnership CDC (4 loans, $3,567,000).

SBA 7(a) and 504 lending in the St. Louis 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 motels44$95,874,000cohort under 3024$40,411,000cohort under 30
Car washes19$18,722,500cohort under 3010$3,530,000cohort under 30
Self-storage31$46,963,600cohort under 305$5,602,000cohort under 30
RV parks and campgrounds5$7,753,900no resolved loansunder 5
Assisted living and continuing care10$13,692,500cohort under 30under 5
Gas stations and convenience stores31$30,657,000cohort under 30under 5
Restaurants, full and limited service395$200,670,50014.4%44$26,508,000cohort under 30
Fitness and recreational sports centers143$50,500,5007.9%7$3,623,000cohort under 30
Marinasunder 5under 5
Child day care services86$68,198,7002.7%23$15,961,000cohort under 30
All ten asset classes in this table766$538,258,50010.4%121$103,729,0006.1%

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 St. Louis 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 St. Louis urbanized core is therefore out. What remains in this metro is the outer parts of the member counties in both states, beyond the urbanized area that runs with the city and its inner suburbs. 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

A St. Louis 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 St. Louis 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. Missouri Revisor of Statutes, Missouri Constitution article VI section 31
  5. Missouri Revisor of Statutes, RSMo 92.111 and 92.105
  6. Missouri Revisor of Statutes, RSMo 92.105 (the ten-year phase-out where voters do not continue the earnings tax)
  7. U.S. Geological Survey, Earthquake Hazards Program
  8. 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 St. Louis Feasibility Market: SBA, USDA and Its Structural Variables. MMCG Invest, LLC. https://www.mmcginvest.com/post/st-louis-feasibility-market-2026

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