SBA Feasibility Study Consultant in Hawaii

Current SBA rules for Hawaii 7(a) and 504 loans

SOP 50 10 8.1

SBA issued SOP 50 10 8.1 through Policy Notice 5000-880695 on Aug. 14, 2026. It took effect Oct. 1, 2026 and governs loans that receive an SBA loan number on or after that date. SBA reissued it with technical updates on Sept. 25, 2026. The SOP consolidates the policy and procedural notices issued since the prior version, including the citizenship and residency requirements. It also moves change-of-ownership guidance into Appendix 15 and adds appendices on debt refinancing, maximum guaranty amounts, loan maturity, interest rates, collateral and application submission. For business acquisitions, SOP 50 10 8.1 tests debt-service coverage on historical cash flow at 1.25x rather than on projections, and requires a lender-ordered quality-of-earnings report on acquisitions of $3 million or more. Because acquisitions are now underwritten on history, an independent feasibility study is most useful for start-ups, expansions, new construction and hotels, where projections are the only evidence of repayment ability.

FY2027 SBA fees

SBA Information Notice 5000-881797 sets 7(a) fees for loans approved from Oct. 1, 2026 through Sept. 30, 2027.

The lender-paid annual service fee is 0.55%. SBA's loan system determines rural status from the project address. Whether a particular neighbor-island site qualifies is therefore decided address by address, not island by island. For 504 loans, Information Notice 5000-881796 waives both the upfront and annual fees in FY2027 for manufacturers, listed food-supply-chain businesses and rural businesses.

100% U.S. citizen or national ownership

Since March 1, 2026, and now carried into SOP 50 10 8.1, SBA requires 100% of all direct and indirect owners of an applicant to be U.S. citizens or U.S. nationals whose principal residence is in the United States, its territories or possessions. Lawful permanent residents may not own any percentage of an SBA borrower. In Hawaii, this has three practical effects:

• American Samoans are U.S. nationals and remain eligible owners.
• Citizens of the Federated States of Micronesia, the Marshall Islands and Palau who live in Hawaii under the Compacts of Free Association are neither U.S. citizens nor U.S. nationals, so under the rule's text they cannot hold equity.
• Businesses partly owned by green-card holders must restructure ownership before applying or use non-SBA financing.

Screening the full ownership chain at intake keeps a deal from failing after third-party reports have been ordered.

Hawaii market conditions by asset class

Visitor demand

DBEDT reports 7,366,097 visitors in January–September 2026 (+1.3%) spending $16.62 billion (+2.8%). Average daily spending was $282 per person, up 10.2%, while average length of stay fell to 8.00 days from 8.68 (DBEDT, Oct. 29, 2026).

Growth now comes from spending per visitor rather than visitor counts. U.S. East arrivals rose 9.3% in January–September 2026 and U.S. West rose 0.3%, while Japan fell 0.4% and Canada fell 5.0%. In September 2026, scheduled seats from Japan were down 16.5% from a year earlier (DBEDT, Oct. 29, 2026). The monthly data are published on DBEDT's monthly visitor statistics page.

Hotels and lodging

Hawaii led the top U.S. markets in January–September 2026 RevPAR, ahead of New York ($272) and San Francisco ($189). Statewide room nights were essentially flat (+0.1%). Midscale and economy RevPAR fell 4.1% statewide in September 2026, and 11.3% on Oʻahu. Hotel studies therefore test limited-service ADR at flat to −5% and favor resort-zoned Maui and Kohala Coast assets. On Dec. 15, 2025, Maui County enacted Bill 9 (Ordinance 5909), which ends transient vacation rental use in A-1 and A-2 apartment districts. The county counted 6,208 such units operating as short-term rentals as of May 29, 2024. Under the ordinance, the last legal guest night is Dec. 31, 2028 in West Maui and Dec. 31, 2030 elsewhere. Lawsuits filed in December 2025 (Malter; Lynam) had produced no injunction as of November 2026. In September 2026, the Lahaina/Kāʻanapali/Kapalua region posted RevPAR of $253 (+19.1%).

Restaurants

Hawaii Business Magazine reported on Sept. 25, 2026 that typical Hawaii restaurant margins fell from 10% to under 2% in Q1 2026, citing the Hawaii Restaurant Association. The association said shipping now costs roughly 80% more than five years earlier and tariffs add up to 15% to product costs. Restaurant 7(a) studies use conservative sales ramps and require strong owner equity.

Childcare

Children under 5 are 5.2% of Hawaii's 1,432,820 residents (July 1, 2025, U.S. Census Bureau QuickFacts), or roughly 74,500 children. Licensed care can serve about one in four Hawaii children under 5, and the workforce shortfall is 25%–30% (Commit to Keiki via KHON2, Feb. 9, 2026). The state has spent or committed $120 million to public preschool classrooms (Civil Beat, September 2026), so private 3–4-year-old programs now compete with free public seats, while infant and toddler care remains undersupplied. Centers are licensed by the Department of Human Services under HAR Title 17.

Senior care

Med-QUEST's 2026 fee-for-service rates for Community Care Foster Family Homes and Expanded ARCHs on Oʻahu, effective Jan. 1, 2026 (Memo QI-2604, Feb. 6, 2026), are:

• Level 1: $30.24/day for SSI members, or $67.33/day for cost-share members.
• Level 2: $71.31/day for SSI members, or $108.40/day for cost-share members.
• Neighbor islands add $5/day.

Residents 65 and older are 22.6% of Hawaii's population (Census QuickFacts, 2025 estimates). New-construction senior care studies are built on private-pay demand, because Medicaid rates at these levels do not support debt service.

Medical office

The Hawaii Physician Workforce Report (December 2025) counts a statewide shortage of 644 FTE physicians, or 833 FTE after geographic adjustment. The shortages are 43% in Hawaii County, 41% in Maui County, 28% in Kauaʻi County and 15% in Honolulu. Neighbor-island medical office demand is structurally strong, and physician recruitment is the key risk tested in the study.

Car washes and self-storage

Express-tunnel car washes in Hawaii are locally owned: CarWash808 Express (Waipiʻo since 2018, Kapolei since 2021), Liquid Aloha and Lex Brodie's Express. Honolulu Board of Water Supply rates rose 8.5% on July 1, 2026, with 8% increases scheduled for July 1, 2027 and July 1, 2028 (adopted November 2023). The city's non-residential wastewater charge is $18.53 per 1,000 gallons from July 2026. Water reclaim is therefore built into Oʻahu car wash economics, and Maui sites carry drought-curtailment risk under county water-shortage stages. Self-storage and other new-construction uses on Oʻahu depend on land basis and permit time: Honolulu commercial building permits issued in 2026 averaged 469 days (Hawaii Public Radio, Sept. 24, 2026).

Hawaii-specific structuring issues

Leasehold land

Much Hawaii commercial property sits on ground leases. SBA lenders obtain the written lease and compare its remaining term, including renewal options only the borrower can exercise, against the loan term. A 25-year real estate loan generally needs 25 years of remaining ground-lease term, so on legacy estate leases the remaining term is often the deciding feasibility question. The study states the remaining term and lessor-consent status on the first page.

C-PACE

Act 183 (SLH 2022) authorized commercial PACE statewide, administered by the Hawaii Green Infrastructure Authority with the counties. HGIA describes C-PACE as a senior, non-accelerating assessment lien. Because that lien sits ahead of mortgage debt, plan C-PACE and SBA real estate financing as alternatives on the same property, not as layers.

Maui disaster debt

By April 2024, SBA had approved more than $300 million in Maui wildfire disaster loans, including $105,784,100 to small businesses (Star-Advertiser, Apr. 9, 2024). The loans carry 30-year terms at 4% for businesses. A Maui 7(a) or 504 study includes that fixed debt service in global debt-service coverage and in the collateral position. An applicant that is delinquent on any federal debt, including an SBA disaster loan, is ineligible for new SBA financing.

Kauaʻi after Hurricane Lowell

Hurricane Lowell passed close to the islands on Sept. 6–8, 2026. In September 2026, Kauaʻi visitor arrivals fell 35.0% and spending fell 44.3% from a year earlier, and Nāwiliwili Harbor was closed Sept. 7–17, 2026 (DBEDT, Oct. 29, 2026). DBEDT reported state-funded business recovery grants of $5,000 and $10,000, administered by the Chamber of Commerce Hawaii for non-agricultural small businesses and nonprofits affected by the storm. Kauaʻi studies haircut 2026–2027 cash flow and document storm-recovery status.

About David Jones, MAI, CCIM

David Jones, MAI, CCIM, signs every study. He has completed more than 4,300 feasibility studies for SBA lenders, CDCs and borrowers. Each Hawaii engagement is quoted as a written fixed fee within one business day, with fees from $4,900 and delivery in 10–15 business days (12–20 for hotels).

Request a fixed-fee proposal