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Published byMelvyn Gilbert Modified over 6 years ago
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Midwest Lenders’ Conference July 6, Dan Sullivan, Acting Director Multifamily Production, HUD HQ
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Affordable Housing Incentives
Higher leverage – loan ratios, more aggressive NOI assumptions Priority processing Relaxed technical requirements (e.g. timing of escrow funding) Waivers
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Why is it so complicated?
Multiple sources and types of financing Long term FHA debt versus year Tax Credit structure Statutory requirements – e.g. FHA first loan terms –vs- secondary loan requirements Timing
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What does HUD/FHA want? To be recognized as a reliable and attractive capital source for the debt Affordability – rents Preservation – real estate Consistency / standardization of national program Application of the Golden Rule Administrative efficiency (enforcement, low maintenance servicing)
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Tax Credit Pilot Program & the 2016 MAP Guide
A huge success! Pilot still “on the books” Only exception to 3 year rule waivers (if had permit in place prior to Sept 30, 2014.) New Construction/Sub Rehab version pending
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2016 MAP Guide LIHTC Changes
Incorporates changes from Ted Toon and Ben Metcalf memos from 2014/2015 Allow Equity Bridge Loans to be obligations by FHA Mortgagor Entity (with limits on recourse against project) Relaxed “Pari Passu” funding requirements Relaxed secondary financing restrictions (e.g., recordation, compounding)
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2016 MAP Guide LIHTC Changes/Clarifications
55+ exemption. Only available for existing projects (> 3 years) which do NOT have Project-based Section 8 (or other legacy deep-subsidy) age-restricted definitions. Initial LIHTC Equity Pay-In requirement: 20% of Total Equity. This amount may not be funded by a Bridge Loan. Subsequent Pay-Ins may be funded by an EBL and are based on Net Equity.
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