June 26, 2020: MULTIFAMILY Submission Due Date Extensions

Today HUD posted the following notice on the Multifamily Housing – Highlights and Announcements page:

Global Extension for All Submissions Due Before September 30th

The Office of Housing has issued approval for an extension of all financial statements due before September 30, 2020.
Any submission with a due date before September 30th will now be due on September 30th.
This extension applies to both audited and unaudited submission types.

To Further clarify, here is a list of the Multifamily FYEs with due dates before September 30, 2020.

Updated April 30, 2020 [Added information below regarding Residual Receipts]

Multifamily

FASSUB (Multifamily) has just now approved an additional extension of the filing deadline. The revised due date is June 30th. This will cover all submissions (owner-certified, owner-certified greater than $750K, OMB audits with 9 month due dates, etc.) that were due April 30th (originally March 30th) and May 31st. The announcement is posted on the FASSUB announcements page within the REAC system.

Global Extension Til June 30th: REAC  is extending due dates on all submissions that are due April 30th [originally 3/30] and May 31st. the new due dates for these submissions will be June 30th. This applies to all submissions due within this time frame.

Residual Receipts

Q: With the REAC deadline being extended, is the deadline to submit surplus cash into a residual receipts account also extended?

A. All of AHACPA’s communications with HUD indicate that the extension DOES NOT apply to residual receipts requirements.

Public Housing (PHA)

The latest information was posted in this Q&A document dated 4/22.  It states:

HUD is extending the reporting due date of PHAs unaudited submission to the REAC as required by 24 CFR 5.801(c) and 24 CFR 5.801(d)(1) for PHAs with a fiscal year end FYE) of December 31, 2019. The new due date for these PHAs unaudited submission is now August 31, 2020. For PHAs with a FYE of March 31, 2020, the new due date is November 30, 2020. The information below provides the extended due date for the unaudited submission by fiscal year.

FYE	Due Date	Extended Due Date
12/31/2019	02/29/2020	08/31/2020
03/31/2020	05/31/2020	11/30/2020

This extension does not require individual PHAs to seek HUD approval for the extension.

FHA Lender Submissions

We contacted the FHA-Lender Recertification Branch.  They have indicated they will not issue another blanket extension.

March 23, 2019

Last week HUD announced a blanket 30-day extension for the filing of all REAC financial statements. That extension is automatic and does not require any action by the project. However, REAC has clarified that the extension DOES NOT EXTEND THE 60-day RESIDUAL RECEIPTS deposit requirement.
 
Rural Development – Contacts with Rural Development indicate that they DO NOT intend to issue a blanket 30-day extension of the filing deadline. They had previously instructed state offices to consider granting extensions due to the timing of the issuance of their 2019 audit guidance. They consider that COVID-19 related extensions would fit within the same guidance. PLEASE NOTE – Clients must request such extensions by contacting state RD officials.
 
Single Audit Extension – Later last week OMB issued memo M-20-17 which among other things, granted an automatic 6-month extension of the deadline for filing audited financial statements. This extension applies to all Uniform Guidance requirements for audited financial statements due through June 30, 2020.
 
FHA Lender Submissions – Conversations with LEAP management indicate that they have granted an automatic 30-day extension for all LEAP filings. These extensions were automatically placed in the lender’s LEAP recertification screen. Evidence of such extension can be found by each client by simply accessing the LEAP recertification page. Just note the new due date.
 
Ginnie Mae, Fannie Mae and Freddie Mac Filings – Detailed searches of the related web pages of these entities DID NOT reveal any evidence of a Covid-19 related extension. Emails to those entities requesting information about possible extension have not been responded to. If any response is forthcoming we will let you know.