AGM Update 8.6.2020: HUD Multifamily Finance during COVID-19
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HUD recently published answers to several new questions and answers, expanding and revising their guidance during the COVID-19 emergency.
We recommend Borrowers read all of HUD’s guidance and remain in frequent contact with their Lenders. AGM’s website features links to HUD’s COVID-19 related publications for your convenience. Highlights from the new Q&A’s include:
HUD addressed several issues for Owners and Agents including tenant testing for COVID-19, a tenant’s positive test results, house rules to require face coverings, and tenant income calculations.
Clarification that eviction prohibitions apply to the entire time a mortgage is under forbearance, including any extensions.
Audited Financial reporting deadlines have been extended from June 30, 2020 to September 30.
Income Certification procedures during the COVID-19 emergency for tenants with HUD assistance were revised and clarified in several Q&A’s; electronic signatures from applicants are acceptable.
With certain conditions, HUD has relaxed the inspection requirements for Lenders and CNA needs assessors until the earlier of September 30, 2020 or when the COVID-19 national emergency is lifted. Certain minimum unit sampling and additional due diligence is required. This includes the RAD program.
HUD’s Asset Management is permitted to accept electronic signatures on all subsidy administration documents. For real estate transactions, the HUD closing attorney will have to advise if electronic signatures are acceptable in the recording offices of the local jurisdiction. Documents not being recorded may be signed electronically (also see Notice H 20-4).
