Crypto Currency

ID Status Date Public/Private Industry AHACPA Contact
#16065 Closed public FHA Lender Les Sparks
Customer Reply

With the new guidance on unacceptable assets for Lenders, where does HUD stand on crypto currency? Is this an acceptable asset for HUD?

Customer Reply

Any update on this? I have some clients asking about crypto currency.




From: AHACPA Support <[email protected]>
Sent: Tuesday, October 19, 2021 9:20 AM
To: [email protected]
Subject: Received: Crypto Currency

Les Sparks

John, if it is not specifically mentioned as an unacceptable asset, then it is not an unacceptable asset. I see nothing in the Guide to suggest that  is the case. Here is the list.



a. Any asset or portion thereof pledged to secure obligations of another entity or any person. Supervised institutions that provide financial services to incorporated communities are sometimes required by State law to pledge their assets for the benefit of the community or to the government regulator. These pledged assets are acceptable for supervised institutions only.


b. An asset due from an officer or stockholder of the lender or from a related entity, except for


  1. A construction loan receivable, secured by a first mortgage, from a related entity.


  1. A mortgage loan receivable established in the normal course of business in an arm’s length transaction and secured by a first mortgage on the related property.


  1. A receivable from a related party when the affected parties have executed a cross- default agreement4 or corporate guarantee agreement5 with Ginnie Mae.


  1. A receivable from an officer or stockholders of a publicly traded supervised institution that owns less than 5 percent of the shares outstanding or issued.


c. An investment in a related entity in which any officer or stockholder of the lender has a personal interest6 unrelated to that person’s position as an officer or stockholder of the lender.


d. Any intangible asset, including but not limited to goodwill, covenants not to compete, franchise fees, organization costs, value placed on insurance renewals, and value placed on property management contract renewals aside from mortgage servicing rights referenced below.


e. The value of any servicing contract not determined in accordance with Financial Accounting Standards Board Accounting Standards Codification 860-50 – Transfers and Servicing – Servicing Assets and Liabilities or its revisions.


f. Any asset unrelated to the lending business and not readily marketable and for which appraised values are highly subjective. Examples include but are not limited to antiques, artwork, and gemstones.


g. That portion of any marketable security (listed or unlisted) in excess of the lower of cost or market, except for shares of Fannie Mae stock required to be held under a servicing agreement, which must be carried at cost, including unrealized gains on “available for sale” securities.


h. Any amount in excess of the lower of cost or market value of mortgages in foreclosure, construction loans, or property acquired through foreclosure.


i. Any asset, which is principally used7 for the personal enjoyment or benefit of an officer, director, or stockholder and not for normal business purposes. This includes motor vehicles and personal residences.


j. “Other assets” unless the financial statements are accompanied by a schedule covered by the audit opinion or a schedule prepared by the issuer or lender and signed by an officer of the issuer or lender.


k. That portion of contributed property, not otherwise excluded, in excess of the value as of the date of contribution, determined by an independent appraisal. If property is contributed but the related mortgage or debt is not also transferred to the company, the value of the contributed property must be reduced by that obligation.


k. Any asset that is real property, including all land and any buildings attached to it; other than the home office registered with HUD in accordance with Handbook 4000.1, Section I.A.3.c.iii.

l. Any asset designated to offset future expenses. Examples include deferred tax assets and prepaid expenses.



Les Sparks
AHACPA | 459 N 300 W #10 | Kaysville, UT 84037 | Phone: 801-547-0809
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From: AHACPA Support <[email protected]>
Sent: Tuesday, October 26, 2021 2:52 PM
To: [email protected]
Subject: Crypto Currency [Client Reply]

Customer Reply

That was my conclusion but I thought I would check with you. Seems like HUD is scrutinizing the assets more each day.




From: AHACPA Support <[email protected]>
Sent: Tuesday, October 26, 2021 7:05 PM
To: [email protected]
Subject: Reply to: Crypto Currency

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