As 2011 came to a close, HUD was still hard at work as evidenced by the two Housing Notices that were issued on December 29th. Housing Notice 2011-35 provided significant revisions to the thresholds for the HUB and National Loan Committees, and Housing Notice 2011-36 provided revised underwriting guidance for “Large Loans”.
The loan committee thresholds have been relaxed significantly, both in terms of loan amount and number of units. This means that more transactions can be approved by the local field office or the HUB, as fewer transactions will require National approval. This means improved timeframes for all multifamily transactions!
The new HUB and National Loan Committee thresholds are as follows:
Section 221d4/221d3 New Construction and Substantial Rehabilitation (Market Rate)
- No Loan Committee: Under $5 M and less than 75 units
- HUB Loan Committee: $5 M – $25 M or 75 – 250 units
- National Loan Committee: Over $25 M or greater than 250 units
Section 221d4 New Construction and Substantial Rehabilitation (Affordable)/Section 223(f)
- No Loan Committee: Under $20 M and less than 200 units
- HUB Loan Committee: $20 M – $50 M or 200 – 350 units
- National Loan Committee: Over $50 M or greater than 350 units
Section 220/Section 231/Section 221(d)(4) Age-Restricted
- National Loan Committee required regardless of loan size or number of units