At first glance, that is an odd pairing, but stay with us, please.
The Suez Canal was prominent in the news last week when a container ship became stuck, blocking the Canal and creating a massive logjam of ships at both ends.
There has been unprecedented demand for HUD’s multifamily mortgage insurance, creating logjams of applications waiting in queues across the five Regional Centers.
Demand has been fueled by historic low interest rates, notwithstanding their recent spike; more favorable loan-to-value, loan-to-cost, and debt service coverage ratios than conventional sources; non-recourse provisions that are a rarity elsewhere in the capital markets; and long-term (up to 40 years), fully amortizing structures.
In addition, there has been an increase in the popularity of the Section 223(f) refinance program since HUD eliminated the three-year rule last March that required a property to be in service for that long before it was eligible. (Special note to healthcare facility owners and operators: a similar waiver to the three-year rule may be in the offing under the LEAN program. Stay tuned for more details.)
HUD has taken several positive steps to address the situation, ensuring transparency and consistency to the application process.
First, they have established a fairly uniform screening protocol for applications before they are placed into the queue. Once an application is screened for deficiencies, a lender has five bidness days to respond; if the response is acceptable, the application is formally placed into the queue.
Second, once the application is in the queue, it is given a targeted date to be assigned to a HUD underwriter. The queue is generally updated weekly, so lenders and borrowers can track the progress of their deal and manage expectations along the way.
Third, HUD has revised loan priorities for assignment in the queue. They now are:
- Low Income Housing Tax Credit (LIHTC) deals for new construction.
- LIHTC deals involving new credits.
- Opportunity Zone transactions with a qualified investment fund.
- Second-stage applications involving new construction.
- Other affordable or broadly affordable transactions.
Applications that do not meet the priorities are assigned on a first-in, first-out basis.
The new priorities took effect on March 18. We have seen immediate benefits as one of our applications became a Priority 4 and moved up to the top of the queue, gaining about three weeks in the schedule.
Please contact us if you have any questions or would like additional information.