Qualified Opportunity Fund Property used as collateral

[Wells Mangrum]

I have $600,000 of capital gains from the sale of stock. This spring, I plan on purchasing land in a Qualified Opportunity Zone and building a multifamily apartment complex. Construction costs are planned to be $600,000. So my capital gains perfectly matches acquisition and construction costs.

Once the complex is fully built and operating, can I use the property as collateral for a loan to purchase a property not in a Qualified Opportunity Zone? Or is that a violation of the 90% rule?

For example, after construction I want to increase my use of OPM. So I go to the bank asking for a loan of $400,000 using the completely paid off QOZ property as collateral. I then use the $400,000 in a separate LLC as down payment on a $2,000,000 McDonalds in a non-QOZ area. Does that violate the 90% rule?

My gut feeling is yes but I would like to be certain.

Thanks!