What an SBA Credit Committee Needs: Feasibility Studies for 504 and 7(a) Loans

A feasibility study does not become bankable because it is long. It becomes bankable because it answers the one question the loan structure forces the lender to ask, and that question is not the same under an SBA 504 loan as it is under a 7(a). The two programs sit side by side in the same Standard Operating Procedure, draw on the same pool of small-business borrowers, and are often arranged by the same banker on the same deal. They are nonetheless built to carry risk in opposite ways. A study engineered for one will not satisfy the other, and a generic market overview satisfies neither.

This is not a stylistic preference. It follows from how each program allocates collateral, prices its debt, requires equity, and recovers loss when a borrower fails. Once those mechanics are laid out plainly, the analytical obligations of the feasibility study fall out of them almost deterministically. What follows is a working map of that translation, from loan architecture to the contents of the model, written for the people who commission, review, and rely on these studies.

1.  Two programs, two repayment questions

Start with the structures themselves, because everything downstream depends on them. The 7(a) program is the agency's general-purpose instrument. A single lender advances the loan, the SBA guarantees a portion of it, and the proceeds can fund almost any legitimate business purpose: working capital, equipment, leasehold improvements, the purchase of a business, debt refinancing, and real estate. Most 7(a) loans cap at $5 million, the guarantee runs up to 85 percent on loans of $150,000 or less and up to 75 percent above that, and the maturity reaches 25 years where real estate or long-lived equipment is involved.⁽¹⁾Critically, the rate is usually variable. The lender sets a spread over a base rate, most commonly Prime, and the borrower's payment moves when the base rate moves.⁽²⁾

The 504 program is narrower by design and stranger in shape. It finances only major fixed assets with a useful life of at least ten years, owner-occupied commercial real estate and heavy equipment, and it cannot touch goodwill, inventory, or working capital.⁽³⁾ It is delivered through two lenders and a debenture. A conventional bank takes a first mortgage for roughly 50 percent of project cost, a Certified Development Company advances a second-lien debenture backed by the SBA for up to 40 percent, and the borrower injects the remaining 10 percent. The debenture carries a fixed rate, set once at the debenture sale and never reset, fully amortizing with no balloon, and is non-recourse on the SBA portion.⁽⁴⁾

These are not two flavors of the same loan. They are two different risk machines. The 7(a) lender holds a single, mostly unsecured-by-real-estate position whose payment floats; the 504 stack splits the deal into a well-collateralized bank first mortgage, a thin and locked government second, and a slug of borrower equity. The feasibility question each one poses is therefore distinct. For 7(a), the question is whether the operating business can carry a payment that can rise, across the full life of one loan. For 504, the question is whether the operating business can carry a fixed, owner-occupied real-estate cost while the bank's separate first-mortgage tranche remains refinanceable. Same building, same borrower, different question.

As of July 4, 2026, this distinction becomes more practically urgent rather than less. The SBA has decoupled the two programs, so a single borrower may now carry a fully drawn $5 million 7(a) and a full 504 on the same acquisition, up to $10 million of SBA-backed financing on one deal.⁽⁵⁾ The clean structure is a 7(a) for the operating company and a 504 for the real estate, closing together, sequenced so the 7(a) is approved first since a 504 balance counts against 7(a) capacity but not the reverse. That means the modern special-purpose deal increasingly runs on both programs at once, and the feasibility study must answer both repayment questions in a single document without conflating them.

Exhibit 1.  How loan structure dictates the feasibility question

Structural feature	SBA 7(a)	SBA 504
Lender / lien	Single lender; partial SBA guarantee	Bank first lien (50%) + CDC/SBA debenture second lien (40%)
Rate	Usually variable, Prime-indexed; payment floats	Debenture fixed for full term; bank tranche priced separately
Eligible uses	Working capital, goodwill, equipment, real estate, refinance	Fixed assets only (10-yr useful life); owner-occupied real estate, heavy equipment
Equity floor	10% (startups & changes of ownership)	10%; 15% special-purpose or startup; 20% if both
The study must prove	Operating cash flow carries a payment that can RISE, across the whole loan	Operations carry a FIXED real-estate cost; bank tranche stays refinanceable

Source: MMCG analysis of SBA SOP 50 10 8 and 13 CFR Part 120. Equity ladder per SOP 50 10 8 and CDC guidance.

2.  Lien geometry: why the same default costs different money

The clearest evidence that the two programs demand different analysis is what happens when a borrower fails. The numbers are not close. Across normal economic conditions, the 504 program's net charge-off rate has averaged roughly 0.8 to 1.5 percent, materially below the 7(a) program's comparable 2 to 4 percent.⁽⁶⁾ The gap is structural, not incidental. A 504 loan is anchored to real estate that retains value and can be recovered; it carries a hard equity floor; and it tends to finance more established operators. A 7(a) loan, by contrast, frequently funds intangible value and working capital, where recovery after default is thin.

Read that gap back into the feasibility study and the implication is immediate. On a 504, the real estate provides a genuine collateral backstop, so the analysis can lean partly on the durability of property value and the resilience of an established operation. On a 7(a), there is far less to recover, which means the cash-flow projection itself has to carry almost the entire weight of the credit. The lien geometry is the reason the same analytical error is more dangerous in a 7(a) study than in a 504 study: when the projection is wrong on a 7(a), there is no real estate to fall back on.

This also disciplines how a study should treat collateral coverage, a point sharpened by the 2025 rules. Under the current SOP, collateral is required on all loans above $50,000, a tenfold reduction from the prior $500,000 threshold, and lenders must lien available business assets and the personal real estate of any 20 percent owner where the loan is not fully secured.⁽⁷⁾ A serious 7(a) study now evaluates liquidation value alongside going-concern income, because both feed the lender's loss-given-default. The 504 study weights it differently: the first-mortgage position stops at roughly 50 percent loan-to-value, which is precisely why the bank feels protected and why the analytical burden shifts toward operating durability rather than collateral sufficiency.

Exhibit 2.  Program loss experience and what it implies for analytical emphasis

Measure	SBA 7(a)	SBA 504
Net charge-off rate, normal conditions	~2% to 4%	~0.8% to 1.5%
Primary recovery source	Business assets; personal guarantee	Owner-occupied real estate
Where the study must concentrate	Defensibility of the cash-flow projection (thin recovery)	Value durability + operating resilience (real recovery)

Source: SBA loan program performance data and SBA Office of Inspector General reporting; figures are charge-off measures in normal conditions, not single-year default or guaranty-purchase rates. Pull current-year figures from SBA program tables before relying on point values.

3.  Rate and amortization: building the right stress test

If lien geometry sets where the analysis concentrates, rate structure sets how the analysis must be stressed. Here the programs diverge most visibly. A 7(a) loan is usually variable. With Prime at 6.75 percent in mid-2026, well-qualified borrowers price near 9.0 to 9.5 percent all-in, but the rate floats and can climb toward its cap as Prime moves.⁽²⁾ The 504 debenture is the opposite: a fixed rate, recently in the low-to-mid 6 percent range once servicing fees are included, locked for a 20- or 25-year term.⁽⁸⁾

Stress testing is not an MMCG embellishment; it is recognized lending practice. Prudent underwriters shock the rate by 100 to 200 basis points to confirm coverage holds, a discipline that matters most precisely for floating-rate loans.⁽⁹⁾ The magnitude is not trivial. A loan underwritten to a comfortable-looking 1.15 times coverage can fall below 1.0 times under a standard 200-basis-point rate shock.⁽⁹⁾ Because the 7(a) payment genuinely floats, a feasibility study that reports only a static, day-one coverage ratio has not actually answered the 7(a) repayment question. It has answered an easier one.

The 504 case requires a different stress entirely, and this is where most generic studies go wrong. The 40 percent debenture is fixed, so a rate shock does not touch it. But the structure hides a second risk: the bank's 50 percent first mortgage is frequently written on a 10-year term against a 20- or 25-year amortization, which means it balloons and must be refinanced while the debenture continues untouched.⁽¹⁰⁾ The relevant 504 stress is therefore a refinance stress on the bank tranche, set at plausible future rates, layered on top of revenue and expense sensitivities applied to the operating business. The debenture is immune; the bank balloon is the exposure. A study that runs a rate shock across the whole 504 stack misunderstands the instrument, and a study that runs no refinance stress at all has missed the only rate risk the structure actually carries.

Exhibit 3.  Program-specific stress design for the same special-purpose deal

Stress dimension	SBA 7(a) (variable)	SBA 504 (fixed debenture + bank balloon)
Interest-rate shock	Apply +100 to +200 bps across the whole loan; payment rises	Not applicable to the fixed debenture
Refinance risk	Single loan; no balloon if fully amortized	Stress the bank first-mortgage balloon at future rates
Revenue & expense	Revenue decline 5%–15%; expense escalation 10%–20%	Same operating sensitivities on the occupying business
Binding exposure	Rising payment over the full term	Refinanceability of the bank tranche at balloon

Source: MMCG methodology, consistent with prudent commercial-real-estate underwriting practice (interest-rate and vacancy stress testing). Rate-shock conventions per industry underwriting guidance.

4.  Owner-occupancy: the cash flow has no rent roll

The 504 program is reserved for owner-occupied property. The operating business must occupy at least 51 percent of an existing building, or 60 percent of new construction, with the balance available to lease.⁽¹¹⁾ This single rule rewrites the feasibility model. A 504 study cannot be underwritten as an income-property leasing play, because the program does not finance a leasing play. The repayment source is the operating business itself, and the analysis must model that business, not a market rent roll.

The regulatory engine behind this is the Eligible Passive Company structure that most owner-occupied deals use. A passive entity holds the real estate and leases it to the operating company, but the rules are strict and they are interpreted strictly: the passive entity must lease 100 percent of the property to the operating company, the lease must be subordinated to the SBA's lien with an assignment of rents, its term must equal or exceed the loan term, and, decisively, the rent cannot exceed the amount needed to cover loan payments, taxes, insurance, and reasonable maintenance.⁽¹²⁾

Sit with that last constraint, because it is the whole point. The rent in a 504 deal is sized to debt service. There is no leasing spread to underwrite, no market upside between contract rent and operating cost, nothing for the analyst to capitalize. The entire repayment case collapses onto a single question: can the operating company generate the cash flow to make the payment? A study that presents a market rent roll, a stabilized net operating income built from comparable lease rates, or a capitalized value premised on third-party tenancy is answering a question the program does not ask. The SOP itself is the reason. For owner-occupied 504 deals, the feasibility study is an operating-business analysis wearing a real-estate label.

5.  The going-concern appraisal, and the line the study must not cross

Where a feasibility study is most consistently expected under the SOP is the special-purpose property, the asset whose value depends on a specific business use and which cannot easily be repurposed. A precise word is warranted here, because a great deal of marketing content overstates the rule. The codified feasibility hook is discretionary; the SOP does not impose a blanket feasibility mandate on every loan. What it does impose, for special-purpose property, is a particular appraisal regime, and in practice that regime makes an independent viability study the expected companion.

For special-purpose property, the lender must obtain an independent appraisal by a Certified General Real Property Appraiser who has completed no fewer than four going-concern appraisals of equivalent special-use property within the last 36 months.⁽¹³⁾ That appraisal must allocate separate values to land, building, equipment, and intangible assets, and it must comply with USPAP as a full Appraisal Report rather than a restricted one.⁽¹³⁾ The going-concern appraisal and the feasibility study are complementary instruments that must be internally consistent. The appraiser opines on value; the feasibility consultant tests whether the operation that produces that value is achievable. An appraisal premised on a stabilized cash flow that the feasibility study finds unattainable is a red flag the credit committee should catch.

This is also the line a feasibility consultant must not cross, and stating it plainly protects everyone. The going-concern appraisal is the appraiser's instrument; it requires the Certified General credential and the documented special-use experience. MMCG's deliverable is the independent feasibility study, the viability analysis on which the appraisal and the credit decision both lean. Keeping those two instruments distinct is not a technicality. Conflating them is one of the ways studies get returned, and one of the ways lenders run afoul of the SOP.

6.  Coverage that clears the floor, on a projected basis

Every thread so far converges on a single number the model has to produce: the debt service coverage ratio, constructed and stressed to the program. A precision point first, because the field is loose about it. The SOP codifies two coverage floors. For 7(a) Small Loans at or below $350,000, the borrower's coverage must be at least 1.10 to 1, on a historical or projected basis; for Standard 7(a) loans above that threshold, the codified minimum is 1.15 to 1.⁽¹⁴⁾ The 504 program sets no single mandated ratio, and lenders apply prudent judgment, commonly around 1.15 to 1.20 times, while conventional, life-company, and CMBS lenders typically demand more still, up to 1.40 times and higher for hospitality.

The pivotal phrase is “historical or projected.” For the asset classes that actually require feasibility studies, special-purpose property, startups, new construction, and changes of business concept, there is no adequate operating history. The projected coverage is therefore the binding figure, and the feasibility study is the evidence base for that projection. This is the crux of the entire subject: the study does not merely inform the coverage ratio; for these deals, it is the coverage ratio's support. When a credit committee tests a projected 1.10 or 1.15, it is testing the feasibility study, whether or not the memo says so.

The 2026 rule changes sharpen this point rather than soften it. Effective March 1, 2026, the SBA sunset the credit-scoring gate that had screened 7(a) Small Loans, directing lenders back to traditional commercial credit analysis built on coverage and cash flow.⁽¹⁵⁾ The screening test moved from an automated score to genuine, projection-based repayment analysis, which is the feasibility study's native territory. The regulatory tide is running toward the independent study, not away from it, and the studies that get accepted are the ones that build coverage the way the program will test it: floating-rate-stressed for 7(a), refinance-stressed and operations-anchored for 504, and projected, not assumed, for any deal without a history.

Exhibit 4.  Coverage standards across capital sources, for orientation

Capital source / loan type	Typical DSCR	Codified floor?
SBA 7(a) Small Loan (≤ $350,000)	1.10x	Yes (1.10x)
SBA 7(a) Standard (> $350,000)	1.15x	Yes (1.15x)
SBA 504 (project / global)	~1.15x to 1.20x	No (convention)
Conventional CRE (banks)	1.25x–1.35x	Market
Hospitality (conventional)	1.40x–1.60x	Market
CMBS / conduit	1.20x–1.25x	Market

Source: MMCG compilation of SBA SOP 50 10 8 (codified 1.10x for 7(a) Small Loans and 1.15x for Standard 7(a)), CDC underwriting practice, and prevailing commercial-real-estate and CMBS underwriting norms. SBA figures are codified floors; the 504 and non-SBA figures reflect typical practice, not mandates.

7.  The value conclusion is the binding constraint

There is a final mechanism that makes the feasibility study consequential in dollars rather than in narrative, and it operates in both programs through the appraisal. The loan is capped to value, and value is precisely what an over-optimistic projection inflates and a disciplined study protects.

On the 504 side the arithmetic is explicit. When the appraised value comes in below 95 percent of project cost, the borrower's required equity rises by the shortfall and that increment is subtracted from the SBA portion. A 10 percent deal with an appraisal at 92 percent of cost becomes a 13 percent equity requirement and a 50 / 37 / 13 structure.⁽¹⁶⁾ On the 7(a) side the parallel is just as hard: for a change of ownership, the loan amount used to acquire the business cannot exceed the business's appraised value, and any gap between price and value must be filled by buyer equity or seller standby.⁽¹⁷⁾

Put the two together and the thesis resolves into a single sentence. Under both programs, the independent value-and-viability conclusion is the binding constraint on loan size and the trigger for additional equity. The feasibility study that defends an achievable stabilized cash flow protects the appraised value, which protects the capital structure, which determines what every party actually contributes to the deal. That is the transmission mechanism, expressed not in adjectives but in the equity each party must write. It is also why a study that flatters the projection does not help the borrower: it simply moves the shortfall from the analyst's spreadsheet to the borrower's checkbook at closing, or sinks the deal at credit committee.

8.  Reading the market correctly, asset class by asset class

None of the above licenses borrowed optimism about the underlying market, and 2026 is a year that punishes borrowed optimism. The macro base rate is sobering on its own: across all sectors, roughly one in five new businesses closes within a year and about half are gone within five, per federal business-dynamics data.⁽¹⁸⁾ But the base rate is necessary context, not an answer, and the most important analytical move in a special-purpose study is to resist the obvious narrative.

Consider the resilience paradox. General business-survival data ranks accommodation and food services as comparatively resilient at the one-year mark. Yet in SBA loan performance, the same category is among the worst, charging off at 23 to 28 percent on a lifetime basis.⁽¹⁹⁾ The two facts are not in conflict; they measure different things. Survival data counts all establishments, most of them lightly leveraged. Charge-off data measures leveraged-loan loss. A restaurant with no debt can limp along; a restaurant carrying a multi-million-dollar SBA loan on a purpose-built building cannot. The charge-off rate captures the interaction of thin margins with heavy fixed debt service on an illiquid single-purpose asset, and that interaction is exactly what the feasibility study exists to assess. The question is never whether the business type survives in the abstract. It is whether this cash flow carries this debt on this asset under this program's structure.

The 2026 market data reinforces the need for asset-specific discipline. Hotels are forecast to grow RevPAR by less than one percent, after a 2025 that recorded the first non-recessionary RevPAR decline in the industry's history.⁽²⁰⁾ Self-storage street rates are running modestly below the prior year; car-wash volumes are softening even as transaction multiples stay elevated; RV-park occupancy is broadly flat with booking windows compressing. The conspicuous exception is senior housing, where occupancy reached 89.5 percent in early 2026, a nineteenth consecutive quarterly gain, on the lowest construction pipeline since 2012.⁽²¹⁾ A feasibility study that applies a single growth assumption across these asset classes is not doing analysis. The senior-housing deal can defend an assertive stabilization curve; the hotel and car-wash deals cannot, and a credit committee that sees the same optimism applied to all three should distrust all three.

Exhibit 5.  Special-purpose asset signals entering 2026, and the modeling implication

Asset class	2025–26 signal	Modeling implication
Hotels	RevPAR forecast < 1%; 2025 saw first non-recessionary decline	Conservative ramp; coverage well above the SBA floor
Self-storage	Street rates modestly below prior year; cap rates ~5.75%–6.15%	Lease-up sensitivity; resilient at lower occupancy
Car wash (express)	Volumes softening; ~$7–$9 average ticket; 24–36 mo. stabilization	Model car count × realistic ticket; capital-structure risk
Gas / c-store	Inside sales up; fuel margins > 40¢/gal; foodservice 38.9% of gross profit	Weight inside-sales gross profit, not fuel volume
RV parks	Occupancy broadly flat; booking windows compressing	Seasonality floors; demand-segment realism
Senior housing	89.5% occupancy; 19 quarters of gains; lowest pipeline since 2012	Supply scarcity supports an assertive stabilization curve

Source: MMCG database synthesis of CBRE, CoStar / Tourism Economics, NACS, NIC MAP, and industry sources, 2025–2026. Hotel figures are forecasts; verify current values before publication. Asset signals are directional, not guarantees.

9.  What a bankable study does, and what gets one returned

The argument of this paper can be compressed into a working standard. A bankable study is engineered to the program. It identifies which program, or which combination, is financing the deal; it builds and stresses coverage the way that program will test it; it models the operating business rather than an inapplicable rent roll where owner-occupancy governs; it keeps the feasibility instrument distinct from the going-concern appraisal; and it defends a value-consistent, achievable stabilized cash flow on which the loan size ultimately rests.

The failure modes are the mirror image, and they are the reasons studies come back from credit committees and secondary reviews. A generic market overview with no program-specific construction. A single static coverage ratio with no rate shock on a floating-rate 7(a), or no refinance stress on a 504 bank balloon. A market rent roll imported into an owner-occupied 504 deal. A projection untethered from the appraised value that caps the loan. And the optimism error that recurs across asset classes: a growth assumption lifted from a headline and applied to a special-purpose property whose loan-leveraged failure economics tell a harder story. The empirical case for getting this right is not abstract. A decade of SBA Inspector General reviews ties early defaults repeatedly to deficiencies in repayment ability, equity injection, and business valuation, the precise items a program-specific feasibility study is built to address.⁽²²⁾

The discipline, in the end, is simple to state and demanding to execute. Engineer the study to the loan. The 504 and the 7(a) ask different questions because they carry risk in different ways, and the study that answers the wrong question is not merely incomplete. It is the document that lets a deal pass when it should not, or fail when it should not. The feasibility study is the place where loan structure becomes analytical obligation, and reading that translation correctly is the difference between a study a lender can rely on and one it cannot.

June 23, 2026, by Michal Mohelsky, J.D. Principal of MMCG Invest, LLC, feasibility study company serving feasibility studies for assisted living facilities.

Reach out to discuss how our methodology supports your lending decision.

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

Contact: michal@mmcginvest.com

Phone: (628) 225-1125

Disclaimer: This report is provided for informational purposes only and does not constitute investment 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. Past performance is not indicative of future results.

Sources

(1)  U.S. Small Business Administration, “Terms, Conditions, and Eligibility,” 7(a) Loan Program (maximum loan amount, guaranty percentages, maturity).

(2)  U.S. Small Business Administration, SOP 50 10 8, Section B, Chapter 1, and Procedural Notice 5000-875051, “7(a) Alternative Base Rate Options,” effective March 1, 2026; current Wall Street Journal Prime Rate, mid-2026.

(3)  13 CFR § 120.120, “Eligible Uses of Proceeds”; SBA 504 program materials on fixed-asset limitation (useful life of at least ten years).

(4)  U.S. Small Business Administration, 504 Loan Program structure (50/40/10); CDC debenture pricing and fully amortizing, non-recourse terms; NADCO debenture pricing.

(5)  U.S. Small Business Administration, Policy Notice 5000-879058, decoupling of the 7(a) and 504 loan programs, effective July 4, 2026.

(6)  SBA loan program performance data and SBA Office of Inspector General reporting; program net charge-off comparisons under normal economic conditions (charge-off measures, not single-year default or guaranty-purchase rates).

(7)  U.S. Small Business Administration, SOP 50 10 8 (effective June 1, 2025), collateral requirements for loans above $50,000 and personal real-estate lien rules for 20 percent owners.

(8)  SBA 504 debenture effective-rate data, early-to-mid 2026 (CDC/SBA debenture coupon plus servicing and guaranty fees), based on monthly debenture sales tied to Treasury yields.

(9)  Commercial-real-estate underwriting practice on interest-rate stress testing (100–200 basis-point shocks), with particular relevance to floating-rate loans; worked rate-shock examples in lender underwriting guidance.

(10)  SBA 504 first-mortgage practice: bank first mortgage frequently written on a 10-year term against a 20- or 25-year amortization, producing a balloon while the CDC debenture continues at its fixed rate.

(11)  U.S. Small Business Administration, SOP 50 10 8, occupancy and leasing requirements; owner-occupancy of 51 percent (existing) and 60 percent (new construction).

(12)  U.S. Small Business Administration, SOP 50 10 8, Eligible Passive Company / Operating Company rules (13 CFR § 120.111): 100 percent lease to the operating company, subordination and assignment of rents, lease-term matching, and rent limited to debt service plus carrying costs.

(13)  U.S. Small Business Administration, SOP 50 10 8, special-purpose property appraisal requirements: independent Certified General Real Property Appraiser, four going-concern appraisals of equivalent special-use property within 36 months, component value allocation, and USPAP Appraisal Report.

(14)  U.S. Small Business Administration, SOP 50 10 8, Section B, Chapter 1, 7(a) underwriting; codified minimum debt service coverage of 1.10:1 for 7(a) Small Loans (at or below $350,000) and 1.15:1 for Standard 7(a) loans above $350,000, on a historical or projected basis.

(15)  U.S. Small Business Administration, Procedural Notice 5000-876777 and related guidance, sunset of the SBSS score for 7(a) Small Loan screening, effective March 1, 2026, and return to traditional commercial credit analysis.

(16)  SBA 504 equity-adjustment rule where appraised value falls below 95 percent of project cost; CDC borrower-equity guidance.

(17)  U.S. Small Business Administration, SOP 50 10 8, cap of 7(a) change-of-ownership loan proceeds to the business’s appraised value; treatment of price-to-value gaps via buyer equity or seller standby.

(18)  U.S. Bureau of Labor Statistics, Business Employment Dynamics, and U.S. Census Bureau, Business Dynamics Statistics: first-year and five-year business survival rates by sector.

(19)  PeerSense database analysis of SBA loan charge-off rates by NAICS sector (lifetime charge-off measures); accommodation and food services among the highest.

(20)  CoStar / Tourism Economics and CBRE U.S. hotel forecasts, 2026 (RevPAR projections and 2025 realized RevPAR decline). Figures are forecasts; confirm current values before publication.

(21)  NIC MAP Vision senior-housing occupancy data, Q1 2026 (occupancy level, consecutive quarterly gains, and construction-pipeline measures).

(22)  U.S. Small Business Administration, Office of Inspector General, High-Risk 7(a) Loan Review Program and related reports tying early defaults to repayment-ability, equity-injection, and business-valuation deficiencies.