SBA and USDA Loans for RV Parks and Campgrounds: Eligibility, the Passive-Income Problem with Long-Term Sites, and the Study Both Programs Expect

Sep 3

16 min read

Motorhome and travel trailers parked on grass sites at a campground.

The campground industry's best-performing revenue line in 2025 was the long-term stay. The SBA's eligibility test for RV parks penalizes exactly that line. Here is the rule as written, the USDA version of the same rule, what the 2026 data say about where park revenue is heading, and what a feasibility study has to prove before either program will guarantee the loan.

Something shifted in American campgrounds in 2025, and it was not the number of campers. The count of North American households that camped held at just over 52 million, essentially flat on the year, according to Kampgrounds of America's twelfth annual industry report, released in April 2026. What moved was the shape of the stay. A reservation-level analysis of hundreds of U.S. campgrounds published in May 2026 found that long-term stays of 28 nights or more hit a record in 2025, up 19.1 percent year over year, while short-term stays fell 3.2 percent. The industry took fewer reservations and booked record revenue. At the outdoor hospitality industry's annual conference in November 2025, the brokerage that presented the economic outlook put it in one line: transient business is declining, while seasonal and long-term stays are stable or increasing. For an operator, that is good news. Long-term guests pay in advance, cancel less, and flatten the seasonal curve that has always made campground cash flow hard to underwrite. For an operator who wants a government-guaranteed loan, it is a problem, because the U.S. Small Business Administration decides whether an RV park is a business or a piece of rental real estate by looking at exactly that split. This piece sets out the rule as the SBA writes it, the parallel test USDA applies under its Business and Industry program, what each program costs in 2026, and the feasibility study both expect a park to survive. The market economics themselves are covered in this site's RV park feasibility guide and RV park industry outlook; this is the loan page.

The sentence that decides SBA eligibility

The SBA does not lend to landlords. Its regulation at 13 CFR 120.110(c) bars "passive businesses owned by developers and landlords that do not actively use or occupy the assets acquired or improved with the loan proceeds," and SBA Standard Operating Procedure 50 10 8, effective June 1, 2025, adds that "businesses that are primarily engaged in owning or purchasing real estate and leasing it for any purpose are not eligible." In the same passage the SOP names two neighbors of the RV park that fall on the wrong side of the line: "Apartment buildings and mobile home parks are not eligible." RV parks and campgrounds are carved out, on one condition. The SOP's language is worth reading in full:

"Hotels, motels, recreational vehicle parks, marinas, campgrounds, or similar types of businesses are eligible if more than 50% of the business's revenue for the prior year is derived from transients who stay for 30 days or less at a time and the business complies with all zoning and other legal requirements. If the Applicant is a Start-Up Business, the Applicant's projections must show that more than 50% of the business's revenue will be derived from transients who stay for 30 days or less at a time." Every word in that test does work.

More than 50 percent of revenue, not of sites and not of nights. A park with 40 percent of its pads on annual leases can still fail if those pads produce most of the money, which at $600 to $900 a month against $45 nights they often do. For the prior year, which means an existing park is judged on its trailing twelve months of actual revenue by category, and a park that has been drifting toward seasonal tenants can cross the line between one application and the next. 30 days or less at a time, which is where interpretation begins. A guest who books a 30-day monthly rate is a transient under the letter of the rule; a guest who books for the season is not; a guest who re-registers every 30 days for eleven months is a question for the lender's counsel. One lender's own guidance concedes the point, noting that monthly visitors can count as short-term but that "not all lenders interpret this guideline the same." The SOP then removes the option of splitting the park in two. "A business is either fully eligible or fully ineligible. If a business has a combined model (part of the revenue is from rent and part from membership dues), it is not eligible." A sponsor cannot present the transient loop as the borrower and leave the long-term loop off the application; the SBA looks at the whole business. And the SOP shuts the back door: "An ineligible business cannot obtain an SBA Loan for any purpose, including the purchase or construction of a building for its own use." Two further clauses catch parks that pass the revenue test. A business "that has entered into a management agreement with a third party that gives the management company sole discretion over the business operations" is an ineligible passive business; the owner must keep "meaningful oversight," defined as approving the budget and major spending, controlling the bank accounts, and employing the staff who run the park. And the compliance clause is not decorative. Parks operating long-term residents in a jurisdiction that zones them as campgrounds, not as residential use, have a legal-compliance problem before they have an eligibility problem. Workforce and contractor parks sit at the edge of all this. A park that markets to pipeline crews and traveling nurses but operates as an open-to-the-public campground with a majority of 30-day-or-less stays can qualify. A closed "man camp," where the operator leases units exclusively to one employer on an annual contract, is a landlord with a single tenant, and lenders who specialize in the sector say so plainly.

The second bind: long-term rent does not count toward repayment

Even a park that clears the 50 percent test carries its long-term revenue into the credit memo with a handicap. SBA repayment analysis is built on the operating cash flow of the business, and the SOP is specific about what a lender may not count. For 7(a) loans, projected debt service coverage "may not include anticipated cash flow from rental income from the Project Property." For 504 loans, rental income from the project property "may be included in the global cash flow analysis. However, it must not be included in the repayment ability analysis." Transient site fees are operating revenue of a hospitality business; no lender treats a $55 overnight as rent. The further a park's revenue moves toward annual leases of a pad, with the guest's own unit sitting on it year-round, the more that revenue looks like the rent the SOP excludes, and the more of it a conservative underwriter will carve out of the coverage calculation. The SBA's floor is a debt service coverage ratio "equal to or greater than 1.15 on a historical and/or projected cash flow basis and 1:1 on a global basis," and for a start-up or construction project the projections must reach 1.15 "within 2 years from loan funding or, for construction projects, within 2 years from the end of construction." A park that leans on long-term sites therefore faces a double bind: the long-term revenue can push it past the 50 percent threshold into ineligibility, and even where it stays eligible, a lender may decline to count that revenue toward the 1.15.

Structuring: 7(a), 504, and a list that leaves RV parks off

For parks under $5 million, the 7(a) program is the common route: one loan, real estate on a 25-year term, equipment and working capital folded in, a 10 percent equity injection for a start-up or complete change of ownership, and personal guarantees from every 20 percent owner. For land-heavy projects, the 504 program finances the fixed assets (land, site work, utilities, bathhouses, pads, long-life infrastructure) through a bank first lien and an SBA-backed debenture of up to $5 million, with the borrower contributing 10 percent of project cost. Here the SOP produces a documentable oddity. The 504 program raises the borrower's contribution to 15 percent for a "Limited or Special Purpose Property" and to 20 percent where the project is both special purpose and a new business. The enumerated list includes "Hotels, motels, and other lodging facilities" and "Marinas," the RV park's siblings under the transient test. It does not include RV parks or campgrounds. The list "is not intended to be all-inclusive and SBA may determine that other properties meet the Limited or Special Purpose Property definition," so a certified development company may classify a park as special purpose in its credit memorandum, but the classification is a judgment call rather than an automatic categorization, and a sponsor can argue it. On a $6 million project, the difference between 10 and 20 percent is $600,000 of equity.

The USDA version of the same rule

For a park in a rural area, the USDA Business and Industry Guaranteed Loan program is the other federal route, and it is a larger one. Under 7 CFR Part 5001, B&I guarantees lender loans of up to $25 million, generally, to for-profit and nonprofit businesses, cooperatives, tribes and individuals in "rural areas not in a city or town with a population of more than 50,000 inhabitants." Loan terms may run to 40 years. For loans approved in fiscal year 2026, USDA's annual notice sets the guarantee at 85 percent for applications under $5 million and 80 percent for $5 million and above, with an initial guarantee fee of 3 percent of the guaranteed amount and an annual retention fee of 0.55 percent of the guaranteed outstanding balance. The program's ineligible-project list at 7 CFR 5001.115 excludes some of the RV park's neighbors by name: "golf courses and golf course infrastructure," "racetracks or facilities for the conduct of races," "for-profit zoos or safaris," and "publicly-owned or non-profit amusement parks, water parks, and similar recreational type facilities inherently commercial in nature and primarily used for recreational purposes." Campgrounds are not on the list. What is on the list, at paragraph (g), is the USDA's own version of the passive test: "Properties to be used for primarily commercial rental when the borrower has no control over tenants and services offered." A park that operates its sites, sets its rules, sells its services and turns its guests is a business; a park that rents pads on annual leases and does nothing else is a rental property, and USDA reads it the same way the SBA does. Two more USDA clauses matter to park owners. Owner-occupied housing is ineligible, but "owner-occupied housing, such as bed and breakfasts, and hotels and motels, are only eligible when the pro-rata value of the owner's living quarters, based on square footage, is deducted from the loan proceeds." The manager's residence at the park entrance is financeable only after that deduction. And rental housing is excluded outright, which is the USDA answer to the same question this site addressed in explaining why the SBA will not finance an apartment building. The feasibility study is where B&I becomes stricter than the SBA. Under 7 CFR 5001.306, "for guaranteed loans greater than $1,000,000.00 to a new business, a feasibility study prepared by an independent qualified consultant acceptable to the Agency is required. The scope of the feasibility study will be determined by the Agency and is dependent on the complexity of the project and the borrower." For smaller loans and existing businesses, the Agency "may require" one when the lender's analysis is insufficient. The study must evaluate the five components the regulation names, "economic, market, technical, financial, and management feasibility," and it must be prepared by an independent third party. A ground-up rural park with a $4 million B&I request therefore arrives at the state office with the study already mandatory.

Term (2026)	SBA 7(a)	SBA 504	USDA B&I
Location	Anywhere in the U.S.	Anywhere in the U.S.	Rural area, not in a city or town over 50,000
Eligibility test	More than 50% of revenue from stays of 30 days or less; zoning compliance	Same	Borrower controls tenants and services; no rental housing
Maximum	$5 million gross loan	$5 million debenture (bank first lien on top)	$25 million, generally
Guarantee	Up to 75% of the loan (85% under $150,000)	Debenture is 100% SBA-backed	85% under $5 million; 80% at $5 million and above (FY2026)
Term	Up to 25 years with real estate	10, 20 or 25-year debenture	Up to 40 years
Equity	10% for start-up or change of ownership	10%; 15% special purpose or new business; 20% both	Tangible balance sheet equity per lender and Agency; commonly 10% to 25% in practice
Coverage	1.15x historical or projected; 1:1 global	1:1 per SLPC	Lender credit evaluation; Agency concurrence
Fees	SBA guaranty fee	CDC and SBA fees in debenture	3% initial; 0.55% annual retention
Feasibility study	Discretionary; SLPC may request	Discretionary; SLPC may request	Mandatory above $1 million for a new business

Sources: SBA SOP 50 10 8; 13 CFR 120.910; 7 CFR 5001.115 and 5001.306; USDA RD B&I program page and FY2026 fee notice.

What the 2026 data say about the revenue mix

The eligibility rule would be an academic point if the industry were still a transient business. The 2025 data say it is becoming less of one.

KOA's 2026 report counts more than 52 million camping households and puts campers' local spending at $66 billion, up more than $5 billion on 2024, with average daily spending per person above $200 before accommodation. Glamping units accounted for 29 percent of camping trips, and 31 percent of campers said they planned more nights in 2026 than in 2025. Those are demand numbers, and they are strong. The revenue-mix numbers point the other way for SBA purposes. The RoverPass 2026 report, built on reservation transactions rather than surveys, records long-term stays up 19.1 percent to a record, short-term stays down 3.2 percent, glamping revenue up 43.6 percent, and record-low cancellations. Fewer reservations produced more revenue because each reservation was longer and richer. The NAI outdoor hospitality outlook presented at OHCE 2025 read the same trend from the transaction side of the market: occupancy, RevPAR and ADR have returned to pre-pandemic levels after the 2020 to 2022 surge, 2023 and 2024 brought lower occupancy and income, 2025 is mixed by property, and the stable line is seasonal and long-term. On the pricing side, the Campspot benchmark developed with OHI put the May 2025 average daily site rate at $33.12, up 4 percent on the year, with revenue per available site at $12.98, up 7 percent, and trailing-twelve-month occupancy up 3 percent. Read together: the campground that is easiest to run in 2026 is the one with a heavier long-term book, and the campground that is easiest to finance with an SBA guarantee is the one with a lighter one. A sponsor who follows the market toward seasonal tenants is walking away from the 7(a) program a few percentage points of revenue at a time. That is the underwriting question this site's seasonality and contract-mix model was built to answer, and it is now also an eligibility question.

What it costs to build, and why that pushes parks toward 504 and B&I

Per-site development cost has moved well past the rule of thumb. A 2026 build-cost analysis puts a professionally engineered RV site at $40,000 to $70,000 per pad, with terrain, soils and finish level driving the top of the range, and a competitive mid-sized park at $1.2 million to $2.5 million or more before land. A 2025 campground construction guide puts the site range at $10,000 to $50,000 and up, depending on amenities, with bathhouses, offices and recreation buildings on top. Usable land in secondary markets trades from roughly $3,000 to $25,000 an acre, more in gateway and interstate corridors. At those numbers a 100-site park with a bathhouse, an office and utilities to every pad is a $4 million to $7 million project. The 7(a) program's $5 million ceiling therefore covers the small and mid-sized park but not the resort-format project the market is rewarding, which is why larger ground-up parks end up in a 504 structure (bank first lien plus a $5 million debenture) or, in a rural county, in a B&I guarantee that runs to $25 million. Both of those routes raise the odds of a mandatory or requested feasibility study.

The study both programs expect

The SBA's feasibility language is discretionary: SBA "has the regulatory authority to request a feasibility study when it is needed to further understand the small business type and market conditions at the project location," and the triggers it names are "market saturation by industry type and location; unique market concept; highly specialized Project property; project size disproportionate to size of community it will serve." A 200-site resort in a county of 9,000 people meets the fourth trigger on its face. USDA's language, as noted, is mandatory above $1 million for a new business. For an RV park the study has to do five things that a hotel study does not.

First, it has to prove eligibility, not just viability. The revenue mix by stay length is the SBA's gate and USDA's control-of-tenants test, so the study's projections must show revenue by category (nightly, weekly, 30-day, seasonal, annual) for each stabilized year, and the trailing twelve months by the same categories for an existing park. A study that reports occupancy without the stay-length split has not answered the lender's first question. Second, it has to model seasonality on a trailing-twelve-month basis and show the 1.15 coverage being reached within two years of funding or of construction completion, with the shoulder months carrying the debt. The 2025 data help here: shoulder-season share grew, with November bookings up 18.7 percent in the RoverPass sample. Third, it has to benchmark rate and occupancy against comparable properties, not against national averages. The Campspot figures are a national floor; a destination park near a national park entrance and a highway-corridor overnight park are different businesses with different ADR bands. This site's stabilized occupancy benchmarks lay out the ranges lenders actually apply. Fourth, it has to address demand concentration. Where a park's projections lean on a single construction project or one employer's crews, the lender's question is whether the demand exists in year ten of a 25-year loan; the study has to show the recreational base case with the workforce revenue as upside, not the reverse. Fifth, it has to separate the ancillary businesses. Cabins and glamping units, an RV and boat storage yard, propane, a camp store and a rally field each carry their own rate, occupancy and cost profile, and some of them (storage in particular) are eligible operating businesses under a different NAICS code with a different risk history. Lenders want them broken out. Where the SBA and USDA money has actually gone by state is the subject of the next table, computed from the SBA loan-level files.

Does more than half of the park's revenue, actual or projected, come from stays of 30 days or less at a time? If yes, and the park is in compliance with local zoning for that use, it is SBA-eligible, and the 7(a) program is open to it anywhere in the country with 10 percent down. If no, the SBA is not a lender to this park under either program, and no entity structure or carve-out of the transient loop changes that.

Is the park in a USDA-eligible rural area, and does the owner control the tenants and the services? If yes, B&I offers up to $25 million on terms to 40 years with an 85 or 80 percent guarantee, at a 3 percent initial fee, and it will require an independent feasibility study on any new-business loan above $1 million.

Is the plan to follow the market toward seasonal and annual tenants? Then the financing is conventional or agency, priced as real estate, and the sponsor should decide that before the first application rather than discover it in the credit memo. The transient test is measured on the prior year's revenue; a park can qualify at closing and drift out of the program's logic by year three, which is a conversation to have with the lender, not with the SBA.

The RV park is one of the few asset classes the SBA finances that is also drifting, market-wide, toward the thing the SBA does not finance. That is the underwriting story of 2026 in this sector, and the feasibility study is where it gets resolved one park at a time.

Frequently asked questions

Are RV parks eligible for SBA loans?

Yes, on one condition. SBA SOP 50 10 8 makes RV parks, campgrounds, marinas, hotels and motels eligible "if more than 50% of the business's revenue for the prior year is derived from transients who stay for 30 days or less at a time" and the business complies with zoning and other legal requirements. A start-up must show the same split in its projections.

Do monthly tenants disqualify a park?

Not automatically. A 30-day stay meets the letter of the test; a seasonal or annual lease does not. The question is whether more than half of total revenue comes from stays of 30 days or less at a time. Lenders read the "at a time" language differently, and the SBA also excludes rental income from the project property from the repayment analysis, so long-term site rent may not count toward the 1.15 coverage even where the park remains eligible.

Can a park finance only its transient section with an SBA loan?

No. The SOP states that a business "is either fully eligible or fully ineligible," and a combined model with part rent and part transient revenue is ineligible as a whole.

Are mobile home parks eligible?

No. The SOP names "apartment buildings and mobile home parks" as ineligible passive businesses.

How does USDA B&I treat RV parks?

As eligible rural businesses where the borrower controls tenants and services. 7 CFR 5001.115 excludes golf courses, racetracks, for-profit zoos and publicly owned or nonprofit amusement parks, and excludes "properties to be used for primarily commercial rental when the borrower has no control over tenants and services offered." For FY2026 the guarantee is 85 percent under $5 million and 80 percent above, with a 3 percent initial fee and terms to 40 years. A new-business loan above $1 million requires an independent feasibility study.

Is an RV park a special purpose property for SBA 504?

Not by name. The SOP's special purpose list includes hotels, motels and marinas but not RV parks or campgrounds. The list is non-exhaustive, so a CDC may classify a park as special purpose, which raises the borrower contribution from 10 percent to 15 or 20 percent, but the classification is a judgment call the sponsor can contest.

Sources:

Kampgrounds of America, Inc., 2026 Camping & Outdoor Hospitality Report, twelfth edition, released April 14, 2026; research by Cairn Consulting Group.
RoverPass, 2026 Outdoor Hospitality Report, reservation-level analysis of 2025 campground transactions, published May 2026.
NAI Outdoor Hospitality Brokers, Economic Forecast presented at the OHI Outdoor Hospitality Conference & Expo, November 2025, as reported by Woodall's Campground Magazine, November 21, 2025.
U.S. Small Business Administration, SOP 50 10 8, Lender and Development Company Loan Programs, effective June 1, 2025: Section A, Chapter 1 (Types of Ineligible Businesses); Section B, Chapter 1 (Credit Standards, 7(a)); Section C, Chapter 1 (504 Eligibility, Limited or Special Purpose Property, CDC Credit Memorandum).
U.S. Small Business Administration, Information Notice 5000-880695, Issuance of SOP 50 10 8.1, August 14, 2026, effective October 1, 2026.
U.S. Small Business Administration, 13 CFR 120.110, "What businesses are ineligible for SBA business loans?", Electronic Code of Federal Regulations.
SBA 504 Blog, guidance articles on RV park and campground construction lending and business-plan projections, March and April 2026.
SBA 504 Blog, "SBA Loans for Monthly & Contractor RV Parks," March 30, 2026.
U.S. Small Business Administration, 13 CFR 120.910, "Borrower contributions," and 13 CFR 120.931, 504 debenture limits, Electronic Code of Federal Regulations.
USDA Rural Development, Business and Industry Guaranteed Loan program page, updated June 25, 2026.
Federal Register, USDA Rural Development, OneRD Annual Notice of Guarantee Fee Rates, Periodic Retention Fee Rates, Loan Guarantee Percentage, March 9, 2026 (fiscal year 2026 terms).
USDA Rural Development, 7 CFR 5001.115, "Ineligible projects: general," Electronic Code of Federal Regulations, as amended September 30, 2024.
USDA Rural Development, 7 CFR 5001.3 (definitions of feasibility study and qualified consultant) and 7 CFR 5001.306 (Business and Industry application requirements), Electronic Code of Federal Regulations.
Campspot and OHI, The Data Dig: Insight on Campsites, May 2025 edition.
RoverPass, "RV Park Build Cost: 2026 Real Numbers," updated June 2026.
Campground Consulting Group, "Campground Construction Costs: A Developer's Complete Guide," May 2025.