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USDA’s Role in the Preliminary Review of Loan Applications


usda feasibility study

The United States Department of Agriculture (USDA) plays a pivotal role in fostering economic development in rural areas through its Business and Industry (B&I) Loan Guarantee Program. This program is designed to support rural businesses by providing loan guarantees that reduce the risk for lenders, thereby encouraging investment in rural communities. One of the initial steps in this process is the preliminary eligibility review, an essential but informal assessment that guides potential borrowers and lenders in understanding whether they might qualify for the program. This review, however, is advisory in nature and does not constitute a final decision on eligibility or funding.


Key Considerations for USDA’s Business and Industry Loan Program

When conducting a preliminary review of a loan application, the USDA considers several critical factors. These factors, while not exhaustive, are among the most significant in determining the likelihood of a project’s approval under the B&I Loan Guarantee Program. Here are some of the key considerations:


1. Equity and Capital Requirements

Equity and capital structure are foundational aspects of any business loan, and the USDA has specific requirements in this regard:


  • Equity Requirements for New Businesses: For new businesses seeking a USDA loan guarantee, the borrower must meet certain equity thresholds. Specifically, a minimum of 25% balance sheet equity is required. Alternatively, the business can have a maximum debt-to-equity ratio of 3:1 at the time of loan closing. This means that for every dollar of equity, the business can have no more than three dollars of debt.

  • Equity Investment in Projects: The USDA also mandates that the borrower invest at least 25% of the total eligible project cost through equity or other funds. This investment can include subordinated debt, provided it is subject to a standstill agreement for the life of the loan. This requirement ensures that the borrower has a significant stake in the project’s success, reducing the risk for the USDA and the lender.


The USDA reserves the right to increase these capital or equity requirements if it determines that the loan carries a higher risk. This flexibility allows the USDA to safeguard its interests while supporting rural development.


2. Interim and Permanent Financing

Interim financing is often necessary during the construction and development phase of a project. The USDA acknowledges that borrowers may need to secure interim financing before applying for long-term guaranteed financing. Importantly:


  • Treatment of Interim Financing: The USDA does not consider interim financing as the refinancing of existing lender debt, provided that permanent USDA-guaranteed financing is applied for after the project is completed. This distinction is crucial because it allows borrowers to proceed with project development without violating USDA regulations regarding debt refinancing.


3. Comprehensive Application Requirements

A complete and well-prepared application is crucial for advancing from the preliminary review to formal consideration for a loan guarantee. The USDA requires a detailed submission that includes a variety of documents and evaluations:


  • Credit Evaluation: The application must include a credit evaluation that conforms to USDA guidelines. This evaluation helps the USDA assess the creditworthiness of the borrower and the risk associated with the loan.

  • Environmental Information: Environmental impact is a critical consideration for the USDA. The application must include all necessary environmental information to allow the USDA to conduct its environmental reviews as per the requirements of RD 5001.207(a)(2)(i).

  • Financial Statements: Comprehensive financial statements are essential. These must include current balance sheets, income statements, and cash flow statements prepared according to Generally Accepted Accounting Principles (GAAP) or other acceptable accounting practices. The USDA may also request historical financial data and projected financial statements that extend through at least two years of full operational capacity.

  • Loan Agreement: For applications involving loans of $600,000 or more, a draft loan agreement must be included. This agreement should cover repayment terms, collateral descriptions, guarantor obligations, and other critical financial covenants. It should also outline the frequency of financial reporting and any limitations on the borrower’s activities, such as the purchase of fixed assets or distribution of dividends.


4. Financial Viability and Risk Assessment

The USDA’s role is not only to provide financial support but also to ensure that the projects it supports are financially viable and sustainable:


  • Feasibility Studies: A feasibility study is often required as part of the application process. This study, prepared by a qualified independent third party, assesses the viability of the project. The scope of the study may vary depending on the complexity of the project but typically includes market analysis, financial projections, and risk assessments.

  • Appraisals: Appraisals are required for any real estate collateral used in the loan. The USDA mandates that the fair market value of the collateral, appropriately discounted, must equal or exceed the loan amount. This ensures that the collateral can adequately secure the loan, minimizing the USDA’s risk.

  • Credit Reports: Current credit reports are required for the borrower, any guarantors, and significant stakeholders in the borrower’s business. This helps the USDA evaluate the financial stability and creditworthiness of all parties involved.


5. Environmental and Regulatory Compliance

Compliance with environmental regulations and other legal requirements is non-negotiable:


  • Environmental Assessments: For real estate collateral valued over $100,000, a Phase I Environmental Site Assessment (ESA) is required. This assessment identifies any potential environmental liabilities that could affect the project or the value of the collateral.


6. Ongoing Financial Monitoring and Reporting

Once a loan guarantee is issued, the USDA continues to monitor the financial health of the borrower and the performance of the project:


  • Periodic Financial Reporting: Borrowers are required to submit regular financial reports, including balance sheets, income statements, and cash flow statements. The frequency and type of reporting are typically outlined in the loan agreement and are essential for the USDA to monitor the ongoing viability of the project.

  • Loan Classification and Credit Risk Rating: At the time of application, the lender must provide the USDA with its loan classification and credit risk rating classification scale. This helps the USDA assess the risk associated with the loan and determine appropriate levels of oversight.


Conclusion

These considerations represent just a fraction of the factors that the USDA takes into account when reviewing applications for the Business and Industry Loan Guarantee Program. Each application is unique, and the USDA may request additional information or impose additional requirements based on the specific circumstances of the project and the borrower’s financial situation. The goal is to ensure that the projects supported by USDA guarantees are viable, sustainable, and beneficial to rural communities.


MMCG is a company dedicated to providing comprehensive feasibility studies for USDA loan programs. With a deep understanding of the USDA’s requirements and processes, MMCG helps borrowers prepare strong applications that meet the USDA’s stringent standards, increasing the likelihood of securing the financial support needed to bring their projects to fruition.

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