SBA RV and Boat Storage Feasibility Study

An SBA RV and boat storage feasibility study is the document a 7(a) lender or a certified development company relies on when the project is a start-up, a ground-up construction, a special purpose property or an acquisition whose price rests on projections. MMCG Invest prepares these studies for SBA lenders nationwide, aligned with SOP 50 10 8.1, which governs every 7(a) and 504 loan assigned a loan number on or after October 1, 2026. This page sets out how the program treats the asset class, where its rules bite, and what the study must put on the record so that the credit memorandum can rely on it. The RV and boat storage feasibility study page covers the asset class itself; this page covers the program.

RV and boat storage is underwritten under NAICS 531130, Lessors of Miniwarehouses and Self-Storage Units, with a size standard of $34 million in average annual receipts. Self-storage has been an eligible SBA business since SOP 50 10 5(C) took effect on October 1, 2010 and removed mini-warehouses from the named passive businesses. The program treats the operator as primarily engaged in providing storage services rather than in leasing real estate, and that framing carries RV and boat storage with it. The SOP does not name RV storage, canopy storage or boat storage anywhere in its eligibility text; the asset class rides on the self-storage interpretation and on how the business is actually run. That is where eligibility is won or lost. Businesses owned by developers and landlords that do not actively use or occupy the assets financed are not eligible except through an Eligible Passive Company, and businesses primarily engaged in owning real estate and leasing it are not eligible at all. A storage operator that sets rental terms, screens and removes tenants, enforces lien rights and runs the gate, cameras and services is an operating business. A management agreement that gives a third-party manager sole discretion makes the applicant a passive business. The owner must show meaningful oversight: budget approval, control of bank accounts, pricing authority and staff who are the applicant's own employees. A kiosk-run, remotely managed facility is eligible on those facts, and the study documents them rather than relying on the asset class's general acceptance. Occupancy is met by operation. The 51 percent rule for existing buildings and the 60 percent rule for new construction apply to the operating business's use of the property, and a storage operator occupies the whole site as its operating premises. SOP 50 10 8 counts exterior space actively used in the business as rentable property while excluding customer parking areas, so a study for a facility whose entire product is parking stalls states plainly that the stalls are the rented product of the operating business, not customer parking. Where the real estate sits in an Eligible Passive Company, the operating company must lease all of it, the passive company may do nothing but lease to the operator, and the operator guarantees or co-borrows. Under SOP 50 10 8.1 every direct and indirect owner must be a United States citizen or United States national with a principal residence in the United States. Lawful permanent residents may no longer hold any ownership interest in an applicant, operating company or passive company, and a business is ineligible if any owner was an ineligible person within the six months before the loan number was issued. The study carries the ownership chart as an eligibility exhibit.

Under 7(a), a start-up in operation for one year or less and a complete change of ownership require a minimum 10 percent equity injection on total project cost. A seller note counts only on full standby for the life of the loan and for no more than half the requirement. Under 504, the borrower contributes 10 percent in the standard case, 15 percent where the business is new or the property is limited or special purpose, and 20 percent where both apply. The bank holds a first lien of 50 percent and the certified development company's debenture carries the balance, up to $5,000,000 in the standard case and $5,500,000 where the project meets a small manufacturer or energy public policy goal. From October 1, 2025 the job opportunity standard is one job per $95,000 of debenture, or one per $150,000 for small manufacturers and energy projects; a storage facility rarely meets the job count and usually qualifies instead under a public policy goal, which the study identifies. Whether RV and boat storage is a special purpose property is not settled by the SOP's published list, and the study treats it as a finding to be made rather than a rule to be cited. The special purpose examples that certified development companies publish name cold storage where more than half the space is refrigerated, and do not name self-storage or RV storage; some lenders nonetheless market mini-storage at the 15 percent contribution. Open-air lots and canopy rows have obvious alternative uses, such as contractor yards and truck parking, and MMCG's position is that they belong at the standard contribution unless the certified development company or its appraiser documents a special purpose finding. Purpose-built enclosed RV garages and forklift-served dry stack boat barns have limited alternative use and should be underwritten with the 15 or 20 percent case shown alongside the standard case. The study runs both. For fiscal 2027, which began October 1, 2026, the 7(a) upfront guaranty fee is 2 percent on loans up to $150,000, 3 percent from $150,001 to $700,000, and 3.5 percent of the guaranteed portion up to $1,000,000 plus 3.75 percent above that for loans from $700,001 to $5,000,000, with an annual service fee of 0.55 percent of the guaranteed balance. The 504 program charges an upfront guarantee fee of 0.50 percent and an annual fee of 0.203 percent. Borrowers in counties the Census Bureau classifies as at least 30 percent rural pay no 504 fees and no upfront 7(a) fee on loans up to $700,000, a waiver that applies to many lake-country and exurban storage sites and that the study tests for the subject county. The maximum 7(a) loan remains $5,000,000, and SBA's July 2026 coordination notice provides that an outstanding 7(a) balance does not reduce a borrower's 504 capacity when the 7(a) loan is approved first.

The largest change in SOP 50 10 8.1 is Appendix 15, which rewrites the change-of-ownership rules. An initial acquisition must cover its debt service 1.25 times on the seller's last fiscal year or a two-year average, measured on historical or adjusted earnings, with no projections allowed. The 10 percent equity injection on an initial acquisition cannot be reduced or eliminated. A Quality of Earnings report from a lender-commissioned provider is required where the business purchase price is $3,000,000 or more, measured before the equity injection and the seller note and excluding owner-occupied real estate, which means many open-lot acquisitions fall below the threshold while still needing an independent business valuation from a qualified source. The business portion of the loan amortizes over no more than ten years, so the blended term is a weighted average rather than the 25-year real estate term the old 51 percent rule allowed. For an RV and boat storage acquisition this has a direct consequence that MMCG's model studies demonstrate: canopy or expansion capital cannot ride inside the acquisition loan at 90 percent financing, because the canopy income does not exist in the seller's history and the historical cash flow must cover the whole loan. A 330-stall open lot bought at a 9.5 percent capitalization rate on about $192,000 of trailing net operating income supports roughly $1.5 million of debt at 1.25 times coverage, which puts the acquisition equity near 27 percent rather than 10 percent and leaves nothing for canopies. The workable structure is to close the 7(a) on the acquisition sized to history, then finance the canopy phase after closing as an expansion of an existing business under general underwriting. A buyer who has owned a storage business for two full fiscal years and buys another in the same four-digit industry group can instead be classified as a business expansion, with 1.15 times coverage measured on the combined entities and an equity injection the lender may reduce.

SBA's loan-level disclosure is the most persuasive exhibit a storage sponsor can place in front of a credit committee, and MMCG computes it rather than quoting it. On the fully seasoned cohort of loans approved from fiscal 2010 through 2019, which is the only cohort old enough to measure, self-storage loans in NAICS 531130 charged off at 0.51 percent by count, with an adverse resolution rate of 0.92 percent once liquidations and guaranty purchases that did not end in a charge-off are added. The 7(a) program as a whole charged off at 6.44 percent on the same cohort and the 504 program at 1.49 percent. Self-storage is among the safest industries in the entire book, and sits below even the 504 average. Two cautions attach to that figure and the study states both. The data covers all of NAICS 531130, because SBA does not separate RV and boat storage from self-storage, and no public source does. The rate is measured by loan count rather than by dollars, and a dollar-weighted loss rate has not been published. Origination volume is active: 7(a) lenders approved about 120 loans and $183 million to self-storage borrowers in 2025 at an average of roughly $1.5 million, about three times the program-wide average loan, with start-ups taking about half the volume.

The study opens with the determination and the conditions precedent, then documents the eligibility findings: the operating-business facts, the management structure, the occupancy finding for an all-parking product, the ownership chart under the citizenship rule, and the special purpose analysis with the contribution case for each outcome. For an acquisition it reconstructs the seller's historical cash flow on the Appendix 15 basis, states the coverage, and sizes the loan to it. The market sections follow MMCG's standard method: trade area demand built from registered boats, RV-owning households, association covenants and parking ordinances; a competitor census checked against each facility's own rate card with pipeline projects counted as supply; pricing by format and stall length inside the verified band; and a lease-up curve to stabilization of 12 to 24 months, lengthened where the submarket has recent deliveries. The cost estimate in MMCG's standard format carries the 504 fees inside the debenture and runs a steel-price stress on any canopy or enclosed line. The five-year pro forma carries property tax at the certified local rate on stabilized value, insurance at a bound or quoted figure, and the operating expense ratio the format supports, typically 29 to 37 percent. Debt service coverage by year, break-even occupancy at 1.0 and 1.25 times, and a sensitivity table that includes the special purpose case and a 100 basis point rate shock complete the financial analysis. The program compliance section closes with the job opportunity or public policy finding and the fee schedule applied. MMCG's model studies show the method on real parcels: an SBA 504 enclosed and covered facility on Lake Norman at Mooresville, North Carolina, where land above $100,000 per acre and a covered competitor still offering a free first month compress yield on cost to about 8 percent and push the equity to 25 percent; an SBA 7(a) acquisition and canopy expansion in Canyon County, Idaho, where the single-loan structure fails Appendix 15 coverage at 0.47 times and the study restructures it; an add-on parking phase at a self-storage facility in Comal County, Texas, financed under 7(a) without a change of ownership; an SBA 504 ground-up facility at Cibolo in the oversupplied San Antonio market, which the study resizes and conditions on a rezoning; and an SBA 504 dry stack boat barn at Aransas Pass, Texas, as the special purpose property case.

Engagements are led by Michal Mohelsky, J.D., Practicing Affiliate of the Appraisal Institute. Feasibility studies are prepared under USPAP discipline and aligned with SBA SOP 50 10 8.1 for 7(a) and 504 loans. A senior analyst responds to proposal requests within 12 business hours from the firm's San Francisco office at 27 Maiden Lane, Suite 625.