Inside a Feasibility Study Engagement: From Engagement Letter to Lender Delivery

Where the study actually sits

For the regulation itself, section by section, see our 7 CFR Part 5001 Handbook.

Most of the confusion about feasibility study timing comes from treating the report as something the agency asks for. Neither SBA nor USDA works that way.

On an SBA file the study is a third party report the lender orders during underwriting, in the same window as the appraisal, the environmental site assessment and, on an acquisition, the business valuation. It is written before the credit memorandum, because the credit memorandum draws on it, and the credit memorandum is written before the request goes to E-Tran and before the loan number issues. Nothing in SOP 50 10 8 places the study anywhere in that sequence, because nothing in SOP 50 10 8 requires the study at all. The placement is a function of what the credit memorandum needs, not of a rule.

On a USDA file the placement is codified. Under 7 CFR 5001.303 the lender must submit a complete application, and the feasibility study is one of its components. For Business and Industry, section 5001.306 requires a study prepared by an independent qualified consultant acceptable to the Agency for guaranteed loans greater than $1,000,000 to a new business, and permits the Agency to require one for loans of $1,000,000 or less where the lender's analysis or other borrower information is not sufficient to determine the technical feasibility or economic viability of the project. For Community Facilities, section 5001.304 requires a financial feasibility report prepared by a qualified firm or individual acceptable to the Agency.

The difference matters because of what USDA does with an incomplete package. Where an application is incomplete the Agency notifies the lender in writing of the items necessary to address it, and completes its evaluation only upon receipt of a complete application. Lenders are encouraged to submit in a single package. There is one carve-out for sequencing: the Agency may accept the environmental information and initiate and complete its environmental reviews in advance of receiving a complete application. The feasibility study gets no such window. It arrives with everything else or the clock does not start.

The three sequences, side by side

SBA 7(a). The lender screens eligibility and collects the intake package, which includes the borrower information form, personal financial statements from every owner of 20 per cent or more, tax transcript verification through Form 4506-C, a business debt schedule, current financial statements, and fee disclosure on Form 159 where a packager or agent is paid. Third party reports are ordered next, on the third party firms' own schedules, which is the main reason real estate and acquisition files run longer than working capital files. The credit memorandum follows, documenting the credit elsewhere test, repayment ability, collateral and equity injection. The guaranty request then goes through E-Tran. A delegated lender approves under its own authority and the loan number attaches to its request; a non delegated package is reviewed by the Loan Guaranty Processing Center. Closing conditions, documents and disbursement follow the loan number.

SBA 504. The CDC assembles the application on Form 1244, performs the credit analysis, prepares the eligibility documentation on Form 2450 and submits to the Sacramento Loan Processing Center, which reviews all 504 applications and contacts the CDC by email where an officer needs additional information, documentation or explanation. The centre evaluates and issues guarantee commitments and issues the authorisation. Before debenture closing, a CDC without ALP or PCLP status must submit its finding of no unremedied substantial adverse change to the centre and obtain approval, under 13 CFR 120.892(c). All CDCs submit Form 2101 with each debenture closing package. Running in parallel on its own track, the senior lender underwrites and closes its own first mortgage, frequently providing interim financing for the whole project during construction that the debenture proceeds later take out. The study sits with the CDC's application assembly and credit analysis, before the authorisation issues.

USDA OneRD. The lender files through its Agency contact and may first request a preliminary eligibility review under section 5001.302, which is encouraged but not required. The Agency's response to that review is written informal comments that are solely advisory in nature and do not obligate the Agency, which makes it a useful scoping instrument and a poor substitute for approval. The complete application under 5001.303 then follows, containing the Agency application form, the lender's credit evaluation conforming to section 5001.202, environmental information, the financial statement package, disclosure of any relationship with an Agency employee, and the lender's loan classification and credit risk rating. Programme specific requirements sit at 5001.304 for Community Facilities and 5001.306 for Business and Industry, the latter carrying additional content thresholds and triggering Department of Labor concurrence for loans over $1,000,000 that increase direct employment by more than 50 employees. Applications are considered in the order they are received.

The clock nobody publishes

Neither agency publishes a processing time standard from complete application to commitment. That is worth stating plainly, because a great deal of circulating advice implies otherwise, and the figures in circulation are secondary, mutually inconsistent, and traceable to commercial sources rather than to either agency.

What does exist is a set of deadlines, and every one of them runs against the lender rather than the agency. Under USDA's rules the lender and borrower must complete, sign and return the conditional commitment within 60 days. The conditional commitment is effective for one year, and the lender must request an extension at least 30 days before it expires. Under SBA's rules the appraisal must be dated within 12 months of the application for guaranty and the environmental report must be dated within one year of the loan number issuing. Those are the dates that actually govern a project timetable.

The contrast that makes the point sits elsewhere in USDA. For guaranteed farm loans, 7 CFR 762.130(a) commits the agency to a clock: complete applications from standard eligible lenders are approved or rejected, with written notice, no later than 30 calendar days after receipt, and complete applications from certified and preferred lenders no later than 14 calendar days after receipt, with a preferred lender's application automatically approved subject to funding if the 14 day window is missed. The department knows how to write an agency deadline. OneRD does not contain one.

Two mechanisms make the absence of a published clock more consequential than it looks. The first is USDA's completeness rule, under which evaluation resumes only when the missing items arrive. The second is the modification rule carried in the Business and Industry application checklist: after a complete application has been accepted, any modification is treated as a new application, which resets the submission date of record. A study delivered late is a delayed application. A study substantially revised after acceptance can be something worse.

What has to be in hand before day one

A study cannot begin before the project it describes has been defined, and the definition comes from documents the borrower controls. Building the list from the agency checklists rather than from custom, the following are what a preparer needs on the table:

Site and project definition. Site control documents, a survey where one exists, the site plan and building plans, the construction budget, and the general contractor's bid. On SBA construction files the general contractor, the project architect or a construction management firm are the recognised sources of the post completion confirmation that construction matched the plans, which is a separate function from the feasibility study but draws on the same documents.

Operating definition. Franchise or management agreements, licences, and for healthcare a certificate of need where federal or state law requires one. Where a franchise is involved, SBA has reinstated its franchise directory, and the listing status of the system is a threshold question rather than a detail.

Financial history and forecast. USDA sets this out precisely at section 5001.303: a current balance sheet and year to date income statements for the borrower and any guarantor dated within 90 days of submission of the complete application; historical balance sheets, income statements and cash flow statements for the lesser of the last three fiscal years or all years of operation; and projected balance sheets, income statements and cash flow statements, or a financial model, running from the current statements through a minimum of two years of the project performing at full operational capacity or stable operations. The requirement that matters most to the preparer is the last clause: projections must be supported by a list of assumptions showing the basis for them. A study's job is to test those assumptions, so a projection arriving without them is an unfinished input.

Regulatory and utility position. Environmental information under section 5001.207 and 7 CFR part 1970 on USDA files, zoning and permit status, and utility availability confirmations. USDA warns that starting development activities before the environmental process is complete may jeopardise its ability to guarantee the loan, which makes premature site work a documented eligibility risk as well as a sequencing error.

Programme specific forms. On USDA multifamily and residential care projects of five or more units, including nursing homes and assisted living centres, Form HUD-935.2A applies, and intergovernmental consultation comments are required under 2 CFR part 415. A business plan is required unless it is contained in the feasibility study or the credit evaluation, which is worth confirming at scoping so the same document is not commissioned twice.

Scope: who decides what the study contains

This is where the two programmes diverge most sharply, and where an engagement goes wrong before any analysis begins.

USDA prescribes the contents. Appendix A to subpart D of 7 CFR part 5001 sets out the five components a feasibility study must address: economic, market, technical, financial and management feasibility. The financial component enumerates a list of factors, the last of which is sensitivity analysis. The regulation names it and stops there. It does not define the method, name the variables, specify direction or magnitude, or set a coverage threshold to be tested against. There is no codified break even requirement and no worst case language. A note for anyone trying to read the appendix online: it was published as scanned images rather than as text, which is why searching the electronic code returns nothing. The text identical companion for the energy programme, at appendix D to subpart B of 7 CFR part 4280, is machine readable and can be used to read the same list.

Two USDA content rules sit outside the appendix and are easy to miss. Section 5001.304 requires the financial feasibility report to take into account any interest rate adjustment that may be instituted under the terms of the promissory note, and requires projections for assisted living, skilled nursing and similar residential facilities to be based on no more than 90 per cent occupancy. The second is a hard cap on the revenue line, not a suggestion, and a study that stabilises a care facility at 95 per cent has failed a codified test rather than an underwriting preference.

USDA also decides scope case by case. The Business and Industry material states that the scope of the study will be determined by the Agency and is dependent on the complexity of the project and the borrower, and repeatedly urges lenders to make contact as early in application development as possible. Read together with the preliminary eligibility review at section 5001.302, that is as close as the rules come to an instruction: pin the scope with the Agency in writing before commissioning the work, and treat the advisory comments for what they are, useful direction that binds nobody.

SBA prescribes nothing. There is no content template, no component list, no sensitivity requirement and no coverage test written into the feasibility provision, because there is no feasibility provision beyond the permissive clause at 13 CFR 120.160(b). What fills the gap is the coverage arithmetic the file has to satisfy anyway, and the lender's own scope letter. On an SBA engagement the scope conversation is with the lender or the CDC, and it should end in writing before the analysis starts.

Nor is there a standard elsewhere to fall back on. Outside rental housing, no professional body publishes a binding standard for the format or content of a commercial feasibility study. The nearest analogues govern something else: the accountancy attestation standards on prospective financial information govern an accountant's examination of the numbers rather than the market narrative behind them, and appraisal standards govern appraisal. For hotels, self storage, car washes, RV parks, industrial and the rest of the special purpose universe, the content standard is whatever the engagement letter says it is.

The data underneath, and what the last year did to it

Demand analysis in a lender grade study rests on federal statistical series, and anyone scoping work in late 2026 needs to know the state of those series, because the last twelve months have been the most disrupted in decades.

The current vintages. The American Community Survey one year estimates for 2024 were released on 11 September 2025, covering geographies of 65,000 people or more. The five year estimates for 2019 to 2023, which reach down to block group level, were released on 12 December 2024. County Business Patterns for 2023 was released on 26 June 2025. The Quarterly Census of Employment and Wages for the first quarter of 2025 was released on 9 September 2025. Occupational Employment and Wage Statistics for May 2024 were released on 2 April 2025. Population estimates are on the Vintage 2024 series. The economic census is on its 2022 cycle. Final annual building permit estimates for 2024 were released on 1 May 2025.

The shutdown. The federal government shut down for 43 days, from 1 October to 12 November 2025, and the effects are permanent in one place and merely disruptive in others. The household survey for the October 2025 reference period could not be collected and, as the statistical agency stated, cannot be retroactively collected. There is no October 2025 unemployment rate and there never will be. State level unemployment data for that month is likewise unavailable, and several state releases slipped by weeks. Bureau of Economic Analysis county level gross domestic product and personal income for 2024 were pushed to 5 February 2026, and state personal consumption expenditure and personal income for 2024 to 19 February 2026. The advance third quarter 2025 output estimate was cancelled outright. Consumer expenditure collection lapsed for October and November and resumed on 5 December 2025.

The methodology breaks. Vintage 2024 population estimates changed the net international migration methodology, and the change is large enough to distort any comparison across vintages: net international migration was 69.5 per cent higher for the year to June 2022 and 101.7 per cent higher for the year to June 2023 than the previous vintage had it, with net international migration of 2.8 million accounting for 84 per cent of the nation's 3.3 million population increase between 2023 and 2024. Business formation statistics were restated to the 2022 industry classification in November 2025. The building permits survey changed its imputation methodology with the release of 26 February 2025. Nonemployer statistics carry methodological changes that break comparability with earlier years.

The uncertainty ahead. The release date for the 2025 one year survey estimates is undetermined while the statistical agency assesses a departmental disclosure avoidance order, and new federal race and ethnicity standards are working through the survey programme with first products several years out.

None of this stops a study being written. It changes how it must be written. Every series carries its vintage and its release date on the page. Any use of 2025 or 2026 labour or income data carries a note on what the shutdown did to it. Population estimates from different vintages are not spliced, and neither are business series on different industry classifications, without saying so. Where small area stability matters, the five year survey is the right instrument, with its reference period stated so nobody mistakes 2019 to 2023 data for current conditions.

On the supply side the split between free and paid is sharp and worth being honest about in the report. Individual permits, licences and parcel records are public and verifiable one at a time from municipal permit portals, state licensing registries for care facilities and licensed uses, and county assessor and recorder systems. The federal building permits survey covers residential construction only, drawn from roughly 19,900 permit issuing places, and captures more than 99 per cent of privately owned residential buildings constructed, but it is an aggregate rather than a project list and it says nothing about commercial pipeline. Comprehensive, deduplicated, forward looking pipeline data by asset class is a subscription product. A study should verify competition from the public record first and be explicit about which supply findings rest on public records and which on licensed data.

Sequencing against the other reports

The third party reports in a credit file expire on different clocks, and the feasibility study, which expires on none, is usually the one that should be commissioned first.

The appraisal. On SBA files it must be a USPAP compliant appraisal report dated within 12 months of the application for guaranty, naming the lender as client or intended user. Where the business transferred within the 36 months before application, a new appraisal is required, together with either a review by a separate appraiser or a site visit by senior lender staff. On USDA files, under section 5001.203, appraisals must not be more than one year old, though the Agency may request a more recent one to reflect current market conditions, and the lender must submit an appraisal review report before the guaranteed loan closes. If the appraisal is not complete when the application is filed, the lender submits an estimated value that must be supported by an acceptable appraisal before the loan note guarantee issues.

The environmental report. The Phase I standard sets its own shelf life. A report remains viable if completed no more than 180 days before acquisition, extending to one year where five components are updated, those being the interviews, the search for recorded environmental cleanup liens, the review of government records, the site reconnaissance and the environmental professional's declaration, with the clock running from the date the first of them was completed. SBA adds its own overlay, requiring the environmental report to be dated within one year of the SBA loan number issuing. Note which end that measures from. Timing the environmental work to the submission date rather than to the expected loan number date is a common and expensive error.

The business valuation. Required from a qualified source where the financed amount less appraised real estate and equipment exceeds $250,000 or where buyer and seller are closely related, requested by and prepared for the lender, and never one prepared for the applicant or seller. From 1 October 2026 the lender self valuation tier disappears for changes of ownership, and a quality of earnings report ordered by the lender is required at a business purchase price of $3,000,000 or more. Neither edition sets a maximum age for the valuation itself. The SBA acquisition report stack planner lists the reports a given acquisition file carries and prices them.

The feasibility study. No age limit under either agency. That is not a licence to use old work. The federal position on what makes a report stale is stated most clearly in the interagency appraisal guidance, which holds that validity is not simply a question of the age of the report but requires consideration of the condition of the property, changes in the market and the nature of the transaction, and that where there has been an obvious and material change in market conditions the existing report is no longer valid. Applied to a feasibility study, the test is whether the market has moved, not whether the cover date is inside a window. Where the market data underneath is more than a year old, refresh the demand and comparable set analysis rather than leave a reviewer to decide what stale means.

The practical order that falls out of this: commission the study first where repayment rests on projections, since USDA folds it into the complete application and SBA's credit memorandum depends on it. Time the appraisal to the expected application date. Time the environmental work to the expected loan number date. Order the valuation when the purchase price is fixed.

Delivery, and what happens next

The study goes to the lender, and on USDA files onward to the Agency as part of the complete application. Three mechanics decide how smoothly that goes.

Completeness. Where USDA finds the application incomplete it notifies the lender in writing of the items necessary, and evaluation waits for them. This is a curable position rather than a denial, and it is the ordinary path for a study missing one of the five components. Reviewers work against the component list, so an unaddressed component is the most predictable reason a study comes back.

Modification. After a complete application has been accepted, substantive modification is treated as a new application with a new submission date of record. That is the argument for getting scope right at the front rather than expanding the work after submission.

Appeal. Section 5001.5 provides that borrowers, lenders and holders may have appeal or review rights, that decisions adverse to the participant are appealable, and that appeals are handled by the National Appeals Division under 7 CFR part 11, with the lender and borrower jointly executing a written request where the decision affects the borrower. Whether the rejection of a single third party report, standing alone, is an appealable adverse decision rather than a curable completeness item is not addressed in the published guidance. A denial of the guarantee plainly is.

On SBA 504 files the equivalent mechanic is quieter: the processing centre contacts the CDC by email where an officer needs more information, documentation or explanation, which means the practical measure of a well built package is how few of those emails it generates.

Running the engagement to a timetable

Nine points of discipline, all of them derived from rules rather than from custom:

Fix the scope in writing before commissioning. On USDA files, use the preliminary eligibility review and early Agency contact to define the components, and remember the response is advisory. On SBA files, get the lender's or CDC's scope letter.

Deliver the study with or before the credit evaluation, not after it. On USDA files it is a component of the complete application. On SBA files the credit memorandum depends on it.

Collect the borrower package before day one. Site control, budget and bid, plans, franchise or management agreements, licences, historical statements, and projections with the supporting assumption list. A projection without assumptions is not yet an input.

Watch the 90 day financial statement rule. USDA requires the borrower and guarantor interim statements to be dated within 90 days of submission of the complete application, which means a study that takes months to complete can outlive the financials it was built alongside.

Build the appraisal to the application date and the environmental report to the loan number date, not both to the same date.

Treat the 90 per cent occupancy cap for care facilities as a hard input, and address the interest rate adjustment on the note where USDA's Community Facilities rules apply.

Include a sensitivity analysis on USDA files whatever the study's own template says, because it is a named factor, and state the method, since the rule does not.

Date stamp every dataset with its vintage and release, and disclose the 2025 data disruptions wherever labour or income series from that period carry weight.

Do not modify a submitted application casually. The resubmission rule can cost more time than the change is worth.

None of this is exotic. It is the difference between a study that clears review and one that generates three rounds of correspondence, and on a file where the conditional commitment runs for a year and has to be signed and returned within 60 days, correspondence is the expensive part.

What a reviewer is instructed to check once the report lands, and the defects that follow, is set out in feasibility study deficiency letters.

To check whether a specific loan needs a study, which other reports the file carries and how each section should be prepared, use the Feasibility Study Methodology Navigator.

Frequently asked questions

When in the loan process should the feasibility study be commissioned? Before the credit analysis, not after it. On a USDA guaranteed loan the study is a component of the complete application under 7 CFR 5001.303, so the application is not complete without it. On an SBA loan the credit memorandum draws on it, and the credit memorandum precedes submission and the loan number. Commissioning the study after the credit analysis is written inverts the order the work is for.

How long does a feasibility study take? There is no published figure from either agency, and the day counts in circulation come from commercial sources and disagree with one another. The honest answer is that duration depends on how complete the borrower package is on day one, how many primary sources the market analysis has to reach, and how tightly the scope was defined. What is fixed are the deadlines around the study: 60 days to sign and return a USDA conditional commitment, one year of commitment life, 12 months of appraisal currency and one year of environmental currency.

Does the study expire? No rule says so. Neither SBA nor USDA sets a maximum age for a feasibility study, unlike the 12 month appraisal rule and the one year environmental rule. The relevant federal test is the one in the interagency appraisal guidance: validity is not simply a question of age, and a material change in market conditions invalidates an otherwise recent report. In practice, refresh the demand and comparable set analysis when the underlying market data passes a year.

What does the borrower have to provide before work starts? Site control, plans and site plan, the construction budget and contractor bid, franchise or management agreements, any licences or certificate of need, three years of historical financial statements or all years of operation if shorter, current interim statements, and projections supported by a list of assumptions showing the basis for them. USDA names most of this in section 5001.303 and its application checklists.

Who decides what the study has to contain? On USDA files the regulation does, through the five components in appendix A to subpart D of part 5001, with the Agency setting the depth according to the complexity of the project. On SBA files nobody does, because SBA prescribes no content for a feasibility study, which is why the lender's scope letter is the operative document.

Does USDA require a sensitivity analysis? Yes, in the sense that sensitivity analysis is a named factor in the financial component of the codified study contents. No, in the sense that the rule does not define it, name variables, set magnitudes or specify a coverage threshold. The practical response is to run it against the variables that actually move the coverage ratio for the asset class and to state the method used, since the rule leaves it open.

What happens if the study is rejected? Usually nothing dramatic. USDA treats an incomplete application as curable and notifies the lender in writing of what is needed. The complication is the modification rule: once a complete application has been accepted, substantive modification is treated as a new application with a new submission date of record. Formal appeal rights exist under section 5001.5 and run to the National Appeals Division, though those are aimed at adverse decisions such as a denial of the guarantee.

Can the borrower commission the study, or does the lender have to? Both agencies allow the borrower to commission it, and in practice most studies are borrower commissioned. SBA imposes no engagement rule for feasibility studies at all, though it does require the appraisal and the business valuation to be ordered by and prepared for the lender. USDA requires only that the consultant be independent, qualified and acceptable to the Agency. What decides whether the lender can rely on the report is whether it is named as an intended user, which is a matter for the engagement letter rather than the invoice.

Sources

1. 13 CFR 120.160(b), Loan conditions
2. 13 CFR 120.892(c), CDC finding of no unremedied substantial adverse change
3. SBA SOP 50 10 8, Lender and Development Company Loan Programs, effective 1 June 2025
4. SBA Information Notice 5000-866746, Issuance of SOP 50 10 8, 21 April 2025
5. SBA Information Notice 5000-868665, Issuance of SOP 50 10 8 with Technical Updates, effective 29 May 2025
6. SBA Information Notice 5000-880695, Issuance of SOP 50 10 8.1, 14 August 2026, effective 1 October 2026
7. SBA Notice 5000-19007, Appraisal Requirements, 26 March 2019
8. SBA Form 1919, Borrower Information Form, effective 19 March 2025
9. SBA Form 413, Personal Financial Statement; SBA Form 159, Fee Disclosure and Compensation Agreement
10. SBA Form 1244, Application for Section 504 Loan; SBA Form 2450, 504 Eligibility Checklist; SBA Form 2101, CDC Certification
11. SBA, Sacramento Loan Processing Center, programme page
12. SBA, Loan Guaranty Processing Center, programme page
13. 7 CFR 5001.202, Lender's credit evaluation
14. 7 CFR 5001.203, Appraisals
15. 7 CFR 5001.207, Environmental requirements, and 7 CFR Part 1970
16. 7 CFR 5001.301 and 5001.302, Beginning the application and preliminary eligibility review
17. 7 CFR 5001.303, Applications for loan guarantee
18. 7 CFR 5001.304, Specific application requirements for Community Facilities projects
19. 7 CFR 5001.306, Specific application requirements for Business and Industry projects
20. Appendix A to Subpart D of 7 CFR Part 5001, Feasibility Study Components, 85 FR 42518, 14 July 2020
21. Appendix D to Subpart B of 7 CFR Part 4280, Feasibility Study Components, 86 FR 22304, 27 April 2021
22. 7 CFR 5001.5, Appeal and review rights, and 7 CFR Part 11, National Appeals Division
23. 7 CFR 762.130(a), Farm Service Agency guaranteed loan processing deadlines
24. 2 CFR Part 415, intergovernmental consultation
25. USDA Rural Development, Business and Industry complete application checklist
26. USDA Rural Development, Community Facilities complete application checklist
27. Federal Register, 85 FR 42518, 14 July 2020, and 89 FR 79720, 30 September 2024, OneRD rulemaking
28. Interagency Appraisal and Evaluation Guidelines, 75 FR 77450, 10 December 2010
29. ASTM E1527-21, Standard Practice for Environmental Site Assessments, and the EPA All Appropriate Inquiries rule effective 13 February 2023
30. HUD Multifamily Accelerated Processing Guide, Handbook 4430.G, Chapter 7
31. Form HUD-935.2A, Affirmative Fair Housing Marketing Plan
32. AICPA AT-C Section 305, Prospective Financial Information
33. Uniform Standards of Professional Appraisal Practice, 2024 edition
34. US Census Bureau, 2024 American Community Survey 1-year estimates, released 11 September 2025
35. US Census Bureau, 2019-2023 American Community Survey 5-year estimates, released 12 December 2024
36. US Census Bureau, American Community Survey updates page, 2025 release status
37. US Census Bureau, County Business Patterns 2023, released 26 June 2025
38. US Census Bureau, Vintage 2024 Population Estimates and net international migration methodology announcement, 19 December 2024
39. US Census Bureau, Building Permits Survey methodology and 2024 annual estimates, released 1 May 2025
40. US Census Bureau, Business Formation Statistics, November 2025 release and 2022 NAICS restatement
41. US Bureau of Labor Statistics, Quarterly Census of Employment and Wages, first quarter 2025, released 9 September 2025
42. US Bureau of Labor Statistics, Occupational Employment and Wage Statistics, May 2024, released 2 April 2025
43. US Bureau of Labor Statistics, statement on the October 2025 household survey reference period
44. US Bureau of Labor Statistics, 2025 federal government shutdown impact on the Consumer Price Index and Consumer Expenditure Surveys
45. US Bureau of Economic Analysis, post-shutdown release schedule updates, county and state series for 2024