Will There be a Blanket Extension to the Submission Deadline?

“Is there going to be a deadline extension?” It’s a question we are asked frequently this time of year.

We do not expect a blanket extension. We have received information from our contacts at HUD Multifamily and FHA/LEAP that there will not be an extension to the submission deadline.

Although there may not be a blanket extension, we have been assured that HUD Multifamily will entertain extensions on an individual entity basis. These requests must be processed through the applicable HUD online system. If granted, the approval will extend the deadline by 30 days. At the end of those 30 days, if you need additional time, you will need to re-request the extension.

Any new information we receive regarding extensions will be posted on our website and Twitter.

If AHACPA performs your electronic submission we can assist you with the extension request. Scroll to the bottom of this notice for more information.


** According to Scott Loveday at HUD, it is unlikely that there will be a blanket extension to the filing deadline. Extensions, if necessary, must be requested on a project-by-project basis online through REAC. If a blanket extension is granted, we will send an email blast and post the notice on our website (https://ahacpa.org), and Twitter (@AHACPA). **

The following answers frequent questions received regarding automatic HUD deadline extensions, individual extension requests, and HUD’s “grace period”.


This is the guidance on the submission deadline as found in Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements


V. Overdue Financial Statements

The overdue tracking module of FASS-MF is updated nightly. If an AFS is not received by the 10th day of the month following the AFS due date, an e-mail letter is automatically sent to the owner’s Secure System coordinator on the 11th day. This message informs the owner the AFS is overdue and that a noncompliance flag has been entered into APPS. It also advises the owner if the AFS is not received within the next 30 days (grace period), HUD will refer the owner to the DEC. If the owner does not submit the AFS within the 30-day grace period, the owner is referred to the DEC and a letter is sent to the owner announcing the referral.

12/31/2021 Year End Due Dates:

  • 90-Day deadline: 03/31/2022
  • Late notice sent: 04/11/2022
  • End of grace period: 05/11/2022

* Non-profit entities must file either an audited or unaudited submission by the 90-day deadline. If an unaudited submission is filed, and an audit is required, the audited submission is due 9 months after year end.


MULTIFAMILY EXTENSIONS:

In connection with COVID-19, HUD has indicated to us, and our experience confirms, that they are being more lenient in approving extension requests. Some examples of successful COVID-related extension requests can be downloaded here.

IF AHACPA processes your electronic submission we can assist you in your extension request(s). For extension requests please provide the following:

  • Project Name and Tax ID Number
  • Short explanation of why the extension is needed. Make sure to include something about COVID-19
  • Contact name, phone number, and email address. There are no rules on who this must be. It should be someone that is familiar with the extension being requested. I have never known HUD to actually reach out to this person.
  • Type of Submission:
    • NP – Less than $750K – Owner Certified
    • NP – Greater than or equal to $750K – Owner Certified
    • NP – Greater than or equal to $750K – Audited
    • Profit Motivated – Less than $500K – owner certified
    • Profit Motivated – Greater than $500K – Audited

Once our team received the information we will process the extension request. It will take HUD 24-48 hours to review and give their answer. We will send you the response once it is posted.

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