Requesting an Extension for a Multifamily Electronic Submission

Click here to download pdf directions on How to Request an Extension for Multifamily Submission

An extension request must be completed online through REAC’s online systems. It has to be requested before the due date. If AHACPA does your electronic submissions, we will request the extension for you. The information needed for an extension request is as follows:

  1. A short explanation of why the request is needed. (See below for Approval and Denial Criteria)
  2. Audit firm’s name
  3. Audit firm’s phone number
  4. Audit engagement date (must be at least 60 days prior to year end).

HUD has issued guidance on the extension process in “Submission and Review Requirements & REMS Critical Data Fields for Annual Financial Statements”. On Page 29 it states:

Extension Request Procedures

The procedures for the submission and review of the requests are:

  1. The owner’s coordinator accesses FASS and enters an explanation as to why they believe an extension is warranted, and enters personal contact information in case REAC needs to discuss the request.
  2. The request is electronically transmitted to REAC via FASSUB.
  3. The REAC analyst assigned to that Hub would act on the request based on the Office of Asset Management’s approval/denial criteria as outlined below.
  4. Once the request is approved or denied, the decision, and an explanation for the decision, is posted in FASSUB and is available for viewing in the submitter’s online Administrative Request Status Box.
  5. If the request is approved, then the due date is automatically changed in the FASS-MF overdue tracking module, thus preventing an overdue letter from being emailed to the owner’s coordinator.

Approval and Denial Criteria – It is extremely unlikely that an extension will be approved

The following criteria will be used in approving and denying extension requests:

  • Approve requests when: circumstances exist that are beyond the owner’s control
  • database problems beyond the control of the Project Manager and the owner prevent the owner from filing (examples include situations in which a former owner’s information was deleted from REMS, or problems with the FASS effective date or expiration date)

Deny requests when:

  • the hard copy audit report was not prepared in time to meet the electronic submission deadline
  • the owner failed to register as a coordinator in secure systems at least 30 days prior to the end of the fiscal year the owner does not have Internet access
  • the owner has overdue submissions from previous years that have not been received
  • the owner fails to engage an auditor at least 60 days prior to the end of the fiscal year

REAC understands that these criteria constitute a Housing policy decision and that the Office of Housing retains the authority to amend, adjust, or suspend these criteria at their discretion.

To request an extension you must log into the REAC system and then click on FASSUB.  Click through the announcements.  You will then be to a screen in which you can select “Extension Request”.  Fill out the following form.  HUD does not notify you of their decision.  You must go back to the REAC system in a day or two.  Click on the “Administrative Requests” link to view HUD’s response.

Click here for some samples of extension requests and their approval/denial from HUD.

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