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Feasibility Study Blog · Program Compliance & Lender Risk

Why a Fully Compliant Feasibility Study Matters

USDA just removed ten lenders from the OneRD Guaranteed Lending Program — a group USDA tied to nearly half of Rural Development’s delinquent loans. Whatever the causes in any one case, it is a reminder of how much rides on the projections a loan is approved against — and on the feasibility study that tests them.

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Why a Fully Compliant Feasibility Study Matters
Watch: a short overview — Why a Fully Compliant Feasibility Study Matters

To a borrower racing toward closing, the feasibility study can feel like one more item on a checklist. To the agency standing behind the guarantee, it is the opposite. Under the U.S. Small Business Administration’s SOP 50 10 and USDA Rural Development’s 7 CFR Part 5001, the feasibility study is a primary underwriting document — the independent test of whether the revenue, the ramp, and the debt-service coverage that justify the loan will hold up after the ribbon is cut. A study that fully satisfies the program’s requirements is what makes the credit defensible years later, when an examiner reopens the file. A study that cuts the corner is a defect baked into the loan from day one.

When the Program Removes the Lender

Program compliance is not an abstraction, and its consequences are now being enforced in public. USDA listed ten lenders as removed from participation in the USDA Rural Development OneRD Guaranteed Lending Program:

Lenders USDA listed as removed from OneRD participation
  • Bank of Montgomery (BOM) Bank
  • Byline Bank
  • Celtic Bank
  • Community Bank & Trust – West Georgia
  • Genisys Credit Union
  • Greater Nevada Credit Union
  • North Avenue Capital
  • Optus Bank
  • U.S. Eagle Federal Credit Union
  • ReadyCap Commercial
USDA said these lenders carried about $620 million in delinquent loans — roughly 47% of Rural Development’s delinquent loan balance.

Removal from participation is a portfolio-management action by the agency, not a verdict on any single deal, borrower, or feasibility study. But the headline figure is the part every sponsor and lender should sit with: a small group of participants accounted for nearly half of a national program’s delinquency. Whatever drove it in any given case, a number that large is a reminder of how concentrated program risk can become — and of why agencies lean so heavily on the document that tests a loan’s projections before it closes.

What Delinquency Has to Do With the Study

A guaranteed loan goes delinquent when the borrower cannot service it — when revenue arrives slower, thinner, or later than the projections promised. Those projections come from the feasibility study. When a study is built to the program — demand anchored to a defined trade area, expense ratios benchmarked to RMA and industry data, a modeled ramp instead of day-one stabilization, and debt-service coverage tested against the real loan structure — the approved loan is sized to a future the borrower can actually reach. When a study is an advocacy document dressed as analysis, it launders an optimistic pro forma through a consultant’s letterhead, and the gap between the projection and the market becomes the lender’s delinquency and the agency’s loss.

That is why agencies treat the study as underwriting, not paperwork. The compliance requirements exist precisely to keep the projection honest — and a loan approved on a study that falls short of them carries the risk that the file will not hold up once the market, rather than the narrative, sets the revenue.

What “Fully Compliant” Actually Means

Full compliance is specific, and it differs by program. For USDA Business & Industry and Community Facilities work, it means addressing the enumerated factors of 7 CFR Part 5001 — economic feasibility, market and technical feasibility, management capacity, and the rest — rather than a generic narrative that gestures at them. For SBA 7(a) and 504, it means the projection-based and special-purpose analysis SOP 50 10 calls for, including global debt-service coverage on the borrower and affiliates. Across both, it means three things a reviewer can verify on sight:

Independence — the determination is not for sale to the party who benefits from a “feasible” finding. Benchmarked assumptions — every material number is derived and sourced, not asserted. Honest risk disclosure — the study names what could go wrong and stress-tests it with sensitivity analysis, instead of presenting a single confident line. A study missing any one of these is not merely thinner; it is non-compliant — and compliance is exactly what gives a lender and an agency confidence that the loan was sized to reality.

The Cost of the Shortcut

The economics are lopsided. A study that skips compliance saves a sponsor a few days and a few thousand dollars. The loan it helps approve can cost a lender and the agency far more when it underperforms. Program standing is not permanent either — the OneRD removals are a reminder that agencies actively manage which lenders participate. Viewed against that downside, a fully compliant feasibility study is not the expensive option; it is cheap insurance.

Wert-Berater prepares feasibility studies to the specific program’s requirements: factor-compliance matrices on USDA work, benchmark-annotated ratio tables, ramp-resolved pro formas, global debt-service coverage and sensitivity testing on SBA and conventional credits, and a plain statement of every material risk. The firm’s fiduciary duty runs to the lender and the agency, never the borrower — because the study’s job is to be right, not to be flattering. That is the discipline that keeps a loan out of the column USDA just published.

Who Signs the Study: The Credentials Behind the Determination

A compliance framework is only as credible as the people who apply it. When an underwriter, a CDC, or an agency reviewer weighs a feasibility determination, the first question after “does it address the regulation?” is “who stands behind it?” Wert-Berater’s answer is a senior-led bench whose experience predates the programs it now serves — more than 4,000 feasibility studies completed since 1998, across all 50 states and internationally, evaluating $40.2 billion in project value — directed and reviewed by the two senior leaders below.

Donald Safranek, MSc — Founder and President, Wert-Berater, Inc.
Donald Safranek, MSc — Founder & President

Institutional underwriting since 1982. Mr. Safranek’s professional foundation was established at Lehman Brothers, where he advanced into the underwriting and management of a $700 million real estate equity investment portfolio — institutional risk modeling, structured equity investments, and disciplined capital deployment. He later held senior asset management and underwriting roles with Hatfield Philips, Inc., a division of Lehman Brothers, leading risk assessment, asset repositioning, and capital strategy across residential, hospitality, commercial, industrial, energy, and infrastructure assets in Europe, the Middle East, the Americas, and the Caribbean.

He holds dual graduate degrees from the London School of Economics — an MSc in Economics and an LLB in Law — and a BA in English Literature and Economics from Rollins College. That four-decade institutional lens is the analytical framework underpinning every Wert-Berater study: more than 4,000 feasibility studies completed for SBA, USDA, EB-5, conventional, and institutional financing decisions, with fiduciary duty running to the lender and agency in every engagement.

Credentials: MSc Economics & LLB Law, London School of Economics · BA, Rollins College · institutional underwriting & asset management since 1982 · 4,000+ feasibility studies directed since 1998.

Bruce E. Jones, MAI — Senior Valuation Advisor, Wert-Berater, Inc.
Bruce E. Jones, MAI — Senior Valuation Advisor

MAI designation held since 1987. Mr. Jones brings nearly four decades of commercial and residential real estate valuation experience, with deep expertise in complex, income-producing, and going-concern assets — exactly the special-purpose properties where SBA SOP 50 10 and USDA reviewers demand the most scrutiny. He is an Accredited Senior Appraiser with the American Society of Appraisers, including the ASA Going Concern specialty, and a Certified General Real Estate Appraiser licensed in multiple states.

Beyond real estate, Mr. Jones holds the BCA and CMEA credentials and brings more than 12 years of experience as a business and machinery & equipment appraiser — so when a project’s value rests on the integrated performance of real estate, an operating business, and tangible assets, each layer is valued by a credentialed specialist rather than assumed. His valuation work has withstood adversarial and highly scrutinized contexts, including litigation support and expert testimony.

Credentials: MAI, Appraisal Institute (since 1987) · ASA, Going Concern specialty · BCA · CMEA · Certified General Real Estate Appraiser (multi-state) · nearly 40 years of valuation experience · business and machinery & equipment appraisal expertise.

That combination — institutional credit discipline on one side, designation-backed valuation depth on the other — is what full compliance looks like in practice: every material number derived by someone qualified to defend it in front of the reviewer who will test it.

Sources & further reading. USDA OneRD Guaranteed Loan Initiative  ·  7 CFR Part 5001 (eCFR)  ·  SBA SOP 50 10 (official). The list of removed lenders and the delinquency figures are as reported from USDA.
Donald Safranek, MSc — President and feasibility study consultant, Wert-Berater, Inc.
Donald Safranek, MSc

President, Wert-Berater, Inc. — independent feasibility study consultants since 1998. More than 4,000 feasibility studies completed across all 50 states and internationally, evaluating $40.2 billion in project value for SBA, USDA, EB-5, conventional, and institutional financing decisions. Fiduciary duty runs to the lender and agency in every engagement.

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