A feasibility study answers whether a project's market supports it and whether its cash flow services its debt. An Opportunity Zone project must answer three more questions:
- whether its location keeps its status through the closing date;
- whether its schedule fits the compliance clocks;
- whether the deal still works if the tax benefit disappears.
A lender who will rely on the study needs all three answered in writing.
UnionMetric Opportunity Zone feasibility studies combine a lender-grade market and financial study with a compliance annex built on primary sources.
Who commissions them
- Senior lenders and credit officers underwriting construction, acquisition or SBA and USDA loans where an Opportunity Zone fund is in the ownership chain.
- Sponsors and developers raising Opportunity Zone equity who need an independent study that lenders and investors will both accept.
- Fund managers evaluating a pipeline of sites against the 2027 map.
- CDFIs and community lenders combining Opportunity Zone equity with New Markets Tax Credits or other incentives.
What the study covers
Part 1: market and financial feasibility
- Trade area and demand: demographic and employment trends, demand drivers and their concentration, with reliability flags for small-area data.
- Supply: the competitive inventory, pipeline and absorption, counted for the trade area rather than taken from a national average.
- Site and access: visibility, traffic, zoning and utilities, as relevant to the asset class.
- Financial projections:
- ramp-up and stabilization, with assumptions tied to the market evidence;
- operating costs;
- debt service coverage and loan-to-cost at the lender's terms.
- Sensitivity analysis: downside cases on the variables that drive coverage.
Part 2: the Opportunity Zone compliance annex
- Tract status in both maps. The parcel, not the tract name, is tested against the 2018 boundaries (2010 tracts) and the 2027 status (2020 tracts), with status date and source. The annex flags rural status, partial tract overlaps and certification contingencies.
- Regime and timing. Expected acquisition and investment dates, and which rule set applies. For 2018-only tracts, the working-capital plan and the December 31, 2026 funding thresholds. For new 2027 tracts, the January 1, 2027 start date.
- Compliance clocks against the schedule. Substantial improvement (100% of basis, or 50% if rural, within 30 months) and the working-capital plan (up to 31 months), mapped month by month against the construction and draw schedule.
- Fund and business tests. How the structure meets the 90% fund test and the business's 70%, 50%, 40% and 5% tests through construction and stabilization, including triple-net-lease and excluded-business screens.
- Exit beyond year 10. Valuation at the investors' expected hold as well as at loan maturity, reflecting the 10-year exclusion and the 30-year basis cap.
- The no-benefit case. The base case re-run with the Opportunity Zone benefit removed, showing whether the committed equity still funds and the loan still services.
- Program overlay. SBA, USDA, LIHTC, NMTC, historic-credit or C-PACE eligibility where those programs are in the stack, with each program's own tract and entity tests.
- State tax treatment. The effect of investor-state conformity on the equity plan.
The annex states its assumptions about structure and tax treatment explicitly. It is written for a credit file. It is not tax or legal advice, and it identifies the points that require counsel's confirmation.
Asset classes
We cover the asset classes most common in Opportunity Zone and SBA and USDA lending: multifamily and mixed-use, hospitality, self-storage, industrial and flex, retail and quick-service restaurants, fuel and convenience, car washes, RV parks, childcare, medical office, and operating businesses. The UnionMetric case-study library shows the method for each.
How an engagement runs
- Screen. Run the site through the Opportunity Zone site screen and share the readout with us. It identifies the questions the study must answer.
- Scope. We confirm the lender's requirements, the asset class and the stack, and quote a fixed scope.
- Fieldwork and analysis. Trade-area research, competitive inventory, financial model and compliance annex.
- Draft and lender review. The draft goes to the sponsor and, where requested, directly to the lender's credit team.
- Final report. Includes a reliance letter where the engagement terms provide for one.
Why the annex matters now
Between now and the end of 2028, two Opportunity Zone maps are in force, and which one applies depends on dates that many studies do not record. A study that says only that a site "is in an Opportunity Zone" cannot tell a lender whether the investor equity will fund. Why the transition matters →
Frequently asked questions
The Opportunity Zone rules do not require one. Lenders often do, particularly for new construction, start-ups, special-purpose properties and SBA or USDA loans. Where a fund is in the ownership chain, lenders increasingly ask for the compliance points above as well.
No. It documents the facts and timelines a tax adviser and a lender both need, flags the issues, and states its assumptions. Tax conclusions remain with the sponsor's tax counsel.
Where the engagement provides for it, the final report is accompanied by a reliance letter naming the lender.
- the site address;
- the project description and budget;
- the proposed capital stack;
- the expected acquisition and investment dates;
- the lender's requirements, if known.
How we verify this page
- Author
- Robert Mitchell
- Updated
- October 26, 2026