Many of you have heard that FHA condo spot approvals are now going away. While this isn’t entirely true, there are some big changes coming and they start February 1st – next Monday!
Here is an attempt to describe the changes and the impact they’re going to have:
Lenders will no longer be doing spot approvals. Instead, there are two options, both based on criteria put forth by the U.S. Department of Housing and Urban Development (HUD):
- DELRAP Approval (Direct Endorsement Lender Review and Approval Process)
- HRAP Approval (HUD Review and Approval Process) and
The big difference is this: for DELRAP, I work with the bank and their builder approval group to get an approval, which takes a couple weeks. For HRAP, it goes to HUD, this can take a month or two…if you’re lucky. And with all the new projects that will now need approval, the HRAP times will most likely increase.
Details:
DELRAP Review Eligibility and Process Requirements Process
- Brokers still have the option of working directly with HUD for an HRAP review for projects requiring a project approval (read: slow approval, harder to get)
OR
- Brokers can work with their bank’s account executive (AE) to get a DELRAP approval through the Builder Project Approval Group (BPAG). Once all required documents are received, BPAG will complete the DELRAP review or, if necessary, forward to HUD for a HRAP review and approval. BPAG will determine DELRAP eligibility based on a few additional bank overlays (underwriting rules) defined below.
Note – If an extension or recertification is requested on a project not originally processed as a DELRAP through BPAG, a full review of the project documents will be required.
BPAG DELRAP project reviews will be completed within about two weeks of a complete submission. Compared to the month-plus timeline for HRAP, which is likely to increase, that is pretty good!
DELRAP Eligibility
The following are ineligible for a DELRAP review and must be sent to HUD for an HRAP review:
- Anything identified on the builder certification, appraisal, or other documentation obtained pertaining to environmental hazards.
- Any unobstructed view of an oil refinery, propane distribution center, large gasoline storage tank(s), etc. Note – projects next to a gas station are eligible for DELRAP.
- Superfunds (dumps or landfills) identified on the EPA Web site that have ongoing maintenance.
- Project is located on wetland or national wetland and insufficient documentation approving the project’s location.
- Historic districts and insufficient documentation approving the project’s location.
- Budget without at least a 10% line item allocation for capital replacement unless a reserve analysis is obtained.
- Fidelity bond coverage not in the name of the association, i.e. Management Company provided fidelity bond coverage.
- Manufactured home projects.
- On a case-by-case basis, any project within a potential noise issue that does not have sufficient mitigating factors.
My take on all of this: FHA condo financing is about to get tougher. If the project is not currently approved by HUD/FHA, it’s going to be difficult to get FHA financing.
Realtors – make sure you know whether a condo is FHA-approved before taking a client using FHA financing out to see it. You don’t want them to form an attachment to a property they can’t buy and set their expectations based on that.
For complete information on this, visit HUD’s press release on the topic.