| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
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| #14899 | Closed | public | Multifamily | _General Support |
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Hi, I’ve got a client that refinanced a project that previously had conventional financing (non-HUD) with HUD debt in late 2019. With the HUD debt, they now obviously have an audit requirement, and their reporting period is from the date of closing on 12/20/19 through 12/31/20 (stub period deferral granted last year). As for the REAC submission, does HUD want to see the true activity from the closing date, which would include obtaining the proceeds of the HUD loan, paying off the old debt, other distributions at closing, etc., or does HUD just want to see the activity immediately following the HUD loan closing through 12/31/20 (exclusive of activity on the closing statement)? Thank you |
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Chad, in each of these cases that start of reporting should be what happens after the refi. So, in other words, they do not want to see the entire financing transactions. Just after the closing. I have seen people include all of the financing and HUD does not seem to care. It’s a little uneven how it is approached. Here is the guidance. F. Refinance – Replacing a Conventional Mortgage with a FHA Insured MortgageThe “Date Owner Assumed Financial Responsibility (FASS)” is the initial/final endorsement date of the new FHA mortgage. This is true unless the new loan is a new construction or substantial rehabilitation loan (e.g. 221(d)(4), 221(d)(3), 232), which requires a cost-certification. If a cost certification is required, the “Date Owner Assumed Financial Responsibility (FASS)” is the day after cost certification cut-off (see section VI.A. – New Projects). The FASS date should not be confused with the “Date Ownership Assumed.” The “Date Ownership Assumed “ is the date the deed was recorded. Les Sparks AHACPA (801) 547-0809 |