HUD Outlines Revisions to the Multifamily Accelerated Processing Guide

HUD announced a series of clarifications that are effective immediately and will be reflected in a revised Multifamily Accelerated Processing (MAP) Guide. They focus on equal pay-in, bridge loans, identity of interest, subordinate debt, vacancy rates, and developer fees.

HUD will underwrite the fixed minimum pay-in schedule summarized below for all LIHTC transactions, including both pilots and non-pilots. The approach aims to ensure consistency both internally between HUD offices and externally with tax credit investors and other industry professionals. The new standard will be more flexible because the generally pari passu structure will not be precisely proportional to advanced FHA insured loan funds.

Benchmarks for Equity Installments

Minimum Equity Installment (Percent of Total Equity)

Cumulative Equity       Paid In

On or before initial closing



At 65% construction completion



At stabilization



At delivery of IRS Form 8609 or within one year of the date of delivery of the form to investors




Equity investors will be allowed to substitute bridge loan proceeds for all or part of the payments until the date of the final deadline when the bridge loan must be repaid in full. Any of all of the LIHTC equity paid according to the schedule above can be funded out of partners’ cash, tax credit syndication proceeds, or a temporary bridge loan. If the equity is funded by a bridge loan, the borrower may be the project sponsor or an upper tier entity. The term of the promissory note evidencing a bridge loan may extend to one year following the date of the delivery of the 8609 forms to investors.

To respond to the greater presence of direct investors in the market, FHA has increased the number of transactions in which the MAP lender holds up to a 100% ownership in the LIHTC limited partner from 5 to up to 10 transactions per calendar year. This exception is available to certain supervised or publicly held MAP Lenders. FHA allows any MAP lender to carry a 25% or smaller interest in the tax credit equity on any number of projects.

With the revised MAP Guide, debt including seller financing on LIHTC deals may represent up to 100% of total project costs and be secured by the project so long as the subordinate debt provider agrees to HUD’s standard form of subordination agreement and standstill. Subordinate debt must remain subject to the following conditions:

Payments only from surplus cash, if available;

Payments for all secondary debt combined not to exceed 75% of surplus cash;

Documentation with a promissory note; and

Subject to automatic re-subordination in any refinancing of the first mortgage.

New minimum underwritten vacancy and collection loss rates, which will distinguish between classes of multifamily housing, aim to better align FHA practice with the broader multifamily lending market. Underwriting will continue to be at the greater of the minimums below and actual levels.

Minimum Vacancy and Collection Loss Rate

Property  Type


*HUD-assisted property with HAP contract on 90% or more of the units; or

*In-place rehab with greater than 90% occupancy and greater than 90% of the units set aside as LIHTC units, with attainable tax credit rents at least 10% below market (i.e. a discount to market).


*80% of the units are set aside as LIHTC units, with attainable tax credit rents at a 10% discount to market.


*LIHTC without a 10% discount to market; or 20% or more of the units are Market Rate.


FHA will now underwrite any developer fees up to 15% of Total Development Costs that comply with IRS regulations for the LIHTC program and the prevailing Qualified Allocation Plan (QAP) for any project that is not claiming Builder’s and Sponsor’s Profit and Risk Allowance (BSPRA) or Sponsor’s Profit and Risk Allowance (SPRA).  Projects eligible for BSPRA and SPRA can opt for those costs or a Developer fee.  The Developer Fee now may also be treated as a mortgageable cost.  Waivers of the MAP Guide will be required to implement these changes for individual transactions until the change is published in the MAP Guide later this month.*


QAP Updates Across the Nation


Alaska Housing Finance Corporation will host Energy Efficiency NOW: An Energy Performance Conference for Commercial and Public Buildings on March 4-5 in Anchorage, AK. Registration closed on Wednesday, February 25.


Arkansas Development Finance Authority (ADFA) Board of Directors approved funding for three applications to receive $500,000 from the Arkansas Housing Trust Fund Pilot Program.

Riverview Hope Campus, Phase I – $250,000

Little Rock Owner-Occupied Rehabilitation Program – $230,000

HOPE Continuum Revolving Deposit Fund – $20,000

The Arkansas Housing Trust Fund (AHTF) Pilot Program was created by the State Legislature in 2009 and funded by the Legislature in 2013 with $500,000 in General Improvement Funds.   The goal of the AHTF is to provide Arkansas communities a flexible source of funds to address affordable housing needs supporting persons at or below 80% of the area median income.


Michigan State Housing Development Authority released a Notification of Funding Round for April 1, 2015 and a memo regarding LIHTC Program Updates & Credit Availability. They are available on the 2015 Funding Round Information page of the MSHDA web site.

MSHDA updated the LIHTC Program Application, Addendum I, Addendum III and Scoring Summary for the April 1, 2015 Funding Round.  Updated forms can be found on the Combined Application page of the MSHDA web site:


Minnesota Housing Finance Agency will accept comments on the proposed changes to the distribution of low income housing tax credits to suballocators in the Twin Cities Metropolitan Area and Greater Minnesota until 4:30 p.m. on Friday, March 27.

MHFA released a draft of the 2017 Housing Tax Credit Allocation Plan. The plan is open for public comment. MHFA will hold a public hearing on Thursday, March 19 at 1:30pm.


Montana Housing Partnership and the Mountain Plains NAHRO will jointly host the Annual Conference, Bridging the Gap, Building Housing Partnerships, on June 8-11 at the Best Western GranTree Hotel and Conference Center. Pre-conference events will begin on June 8 with a session about planning and funding for housing in your community. A pre-conference networking session will be held the evening of June 8.

Officially the conference starts on June 9 and you will find local, regional and national leaders providing information about important issues facing our industry.  There will be sessions during the conference covering topics on Multifamily development, housing choice vouchers, public housing, community revitalization and development, single family loans, and professional development. A three-day NAHRO certification training in Housing Choice Voucher Eligibility: Income and Rent Calculation will be available to attend.


Virginia Housing Development Authority made the following changes to its 2015 LIHTC Application.

Corrected page 20 so that the state basis boost is not eligible for tax-exempt bond developments.

Corrected the equation to allow the state basis boost for rehab developments that meet the requirements.

Corrected the calculation of points for 7b on the score sheet to reflect the sliding scale for developments with less than 100 units.

The lines requesting the recording date and title of the purchase or right of first refusal documentation from the reservation application on page 24 have been deleted. This information will be requested with the Allocation Application in November.

Click here for more information.

Budget conferees in Virginia released a budget that includes $8 million for the Housing Trust Fund. In order to be enacted, the State House and Senate must vote on the budget and it must be signed into law by the Governor.*


Mortgage Rates Reverse Course and Move Lower

Mortgage rates unwound last week's increase, with the benchmark 30-year fixed mortgage rate pulling back to 3.90 percent, according to's weekly national survey. The 30-year fixed mortgage has an average of 0.29 discount and origination points.

The average 15-year fixed mortgage dropped to 3.15 percent while the larger jumbo 30-year fixed mortgage settled at 4.07 percent. Adjustable rate mortgages were down also, with the 5-year ARM falling to 3.22 percent and the 7-year ARM sinking to 3.44 percent.         

Mortgage rates moved lower this week after indications that maybe the Federal Reserve isn't going to raise interest rates as soon as markets had thought. The minutes from the Federal Open Market Committee's January meeting showed a hesitancy to raise interest rates on the part of Fed members. The concern was that, despite recent signs of improvement in the job market and overall economy, raising interest rates too soon could douse the recovery. Since mortgage rates, and long-term bond yields, move in anticipation of Fed interest rate moves, any change in the outlook for Fed action can have a pronounced effect on mortgage rates. Mortgage rates are closely related to yields on long-term government bonds.

One year ago, the average 30-year fixed mortgage rate was 4.48 percent. At that time, a $200,000 loan would have carried a monthly payment of $1,011.00. With the average rate now at 3.90 percent, the monthly payment for the same size loan would be $943.34, a savings of $67 per month for anyone refinancing now.  


30-year fixed: 3.90% -- down from 3.96% last week (avg. points: 0.30)
15-year fixed: 3.15% -- down from 3.21% last week (avg. points: 0.18)
5/1 ARM: 3.22% -- down from 3.31% last week (avg. points: 0.20)

Bankrate's national weekly mortgage survey is conducted each Wednesday from data provided by the top 10 banks and thrifts in the top 10 markets.

For a full analysis of this week's move in mortgage rates, go to

The survey is complemented by Bankrate's weekly Rate Trend Index, in which a panel of mortgage experts predicts which way the rates are headed over the next seven days. Two-thirds of the panelists, 67 percent, expect mortgage rates to continue falling. One-in-four forecast that mortgage rates will remain more or less unchanged, while just 8 percent predict that mortgage rates will rise.**


HCN Announces $2.2 Billion Q1 Investment Pipeline

Just days after Health Care REIT (NYSE: HCN) reported a record year of earnings during a call with industry analysts, the real estate investment trust announced that it anticipates completing approximately $2.2 billion of investments in the first quarter of 2015.

In comparison, the company completed $3.7 billion of new investments during the entirety of 2014.

HCN’s first-quarter investments will be comprised of approximately $1.1 billion of seniors housing operating investments, $664 million of triple-net investments and $460 million of loan investments, of which the majority is with Genesis Healthcare (NYSE: GEN).

In last Friday’s earnings call, HCN Chief Investment Officer Scott Brinker noted that most of the REIT’s growth, at least in the post-acute space, would be attributable to its partnership with Genesis. 

In keeping with this strategy to grow through established partners, approximately 81% of HCN’s investments are expected to involve existing portfolio partners including Belmont Village Senior Living, Benchmark Senior Living, Brandywine Senior Living, Cascade Living Group, Genesis Healthcare, Merrill Gardens, HCN’s Canadian partner Revera and HCN’s U.K. partners Avery Healthcare and Signature Senior Lifestyle.

It’s worth noting that HCN did pick up a number of new partners through its deal with Mainstreet, including Ensign and Trilogy, and that it “expect[s] to be growth partners going forward,” Brinker said during the company’s fourth-quarter earnings call. 

Of its first-quarter investments, HCN expects 52% to be located in the United States, 30% in the United Kingdom and 18% in Canada.

The aggregate anticipated investment amount includes approximately $156 million of secured debt that HCN expects to assume at an average annual interest rate of 3.9%. ***



Events (2015)

  • Gill Group plans to attend Bank of Advance’s Annual Meeting March 19th – 22nd in Norfork, AR.
  • Cash Gill plans to attend the Missouri Real Estate Appraisers Commission Quarterly Commission Meeting March 17th – 19th in Jefferson City, MO.
  • Gill Group plans to attend the Maco Companies’ Annual Meeting March 12th – 15th in Biloxi, MS.
  • Gill Group plans to attend the Council for Affordable Rural Housing’s Quarterly Board Meeting March 4th – 5th in Washington, DC.
  • Gill Group attended Mississippi’s Annual Affordable Housing Conference February 23rd – 25th in Natchez, MS.
  • Gill Group attended NH&RA’s Annual Meeting February 18th – 20th in Key Largo, FL.
  • Gill Group attended CARH’s Midyear Meeting January 27th – 29th in St. Pete Beach, FL.
    • Cash Gill spoke on a panel Wednesday, January 28th entitled Preservation Challenges and Opportunities

Events (2014)

  • Gill Group attended 40+ meetings and conferences throughout the United States in 2014.

GROWTH (2014 - Highlights):

  • Gill Group began the process of working with owners of affordable housing to develop a web-based program that will work hand-in-hand with our services. It will give the users of our appraisals, market studies, capital needs assessments and many other services easy access and real time usage.
  • Gill Group added 2 offices with appraisers, market analysts, engineers and architects.
    • Within the offices are 11 architects, one MAI appraiser, one general certified appraiser, four market analysts and 12 additional support staff. 

Events (2013)

  • Gill Group attended 22 conferences and meetings throughout the United States in 2013

GROWTH (2013 - Highlights):

  • Gill Group expanded our cutting-edge market analysis software and added our own in-house developed needs assessment software for CNAs, PNAs, PCNAs, PCAs, RPCAs, and every other acronym for this type of service.  
  • Gill Group added 4 offices with appraisers, market analysts, engineers and architects.
    • Within the offices are three architects, one MAI appraiser, two general certified appraisers, five market analysts and 10 additional support staff. 
  • Gill Group expanded the footprint of its subsidiary, National Title & Escrow, to cover the entire United States with a local presence.

Events (2012)

  • Gill Group attended 20 conferences and meetings throughout the United States in 2012

GROWTH (2012 - Highlights):

  • Gill Group developed cutting-edge market analysis software that will allow us to do preliminary analysis that is subject-specific in any market in the United States within minutes.  
  • Gill Group added 11 offices with appraisers, market analysts, engineers and architects.
    • The offices now employ an additional 34 people.
  • Gill Group expanded coverage of its subsidiary, National Title & Escrow, to cover the entire United States.
  • Gill Group expanded coverage of its subsidiary, Gill Insurance Group, to cover the entire United States.

  Gill Group has published the following:

  • New York Real Estate Journal - How can low-income housing facilities translate into high profits?
  • New York Real Estate Journal - Up, up and away: Home mortgage interest rates and gasoline prices continue ascending.
  • Tax Credit Advisor - Boston MSA Market Snapshot
  • Tax Credit Advisor - Seattle MSA Market Snapshot
  • Northeast Industrial Development Resource Guide - What Appraisers Know About Investing.
  • Affordable Housing Finance – Urban and Rural Market Studies.
  • Tax Credit Advisor – LIHTC Appraisals 101

Cash Gill, MAI has had the opportunity to speak on the following topics:

  • (Indianapolis, IN) National Council of Affordable Housing Market Analysts - Maximize Your Market: Understanding the Methodology Behind Market Studies.
  • (Reno, NV) Nevada Council of Affordable and Rural Housing - Don't Get Caught in the Red. New Guidelines for Audits and Inspections.
  • (Washington, DC) The Institute for Professional and Executive Development - Nonrecourse HUD Deals - So You Closed Your Nonrecourse HUD Deal. Now What? And Is It Really Nonrecourse?
  • (Arlington, VA) Council for Affordable and Rural Housing - Property Valuation: The Correct Way to Value Properties.
  • (New Orleans, LA) National Council of Affordable Housing Market Analysts - Affordable Housing Site Analysis
  • (Las Vegas, NV) Nevada Council of Affordable and Rural Housing - Auditing and Accounting Guidelines for Section 42 Low Income Housing Tax Credits.
  • (Washington, DC) Council for Affordable and Rural Housing - Rural Development Appraisals and Market Studies
  • (Miami, FL) Council for Affordable and Rural Housing - The Equity Market - Impact on Rural Housing
  • (Washington, DC) Council for Affordable and Rural Housing - How to Foster Affordable Green and Rural Housing Needs Assessments
  • (Indianapolis, IN) Affordable Housing Association of Indiana - Market Analysis – Best Ways Use Market Studies to Ensure Application Points
  • (Portland, ME) Enterprise Buyer/Seller Conference for RRH 515 Properties – Valuing the Product. What Is My Development Worth?
  • (Washington, DC) National Housing and Rehabilitation Association – Financing and Underwriting Special Needs Housing.
  • (Atlanta, GA) National Council of State Housing Agencies – Comprehensive Market Analysis.
  • (Chicago, IL) AHF Live – Strategies for Rural Deals.
  • (Dallas, TX) Crittenden Multifamily – Financing Special Use Properties.
  • (Washington, DC) Council for Affordable Rural Housing – Rural Housing Preservation
  • (Denver, CO) National Council of State Housing Agencies – Rural Housing Strategies
  • (Denver, CO) National Council of State Housing Agencies – Y15: Preservation and Disposition Seminar
  • (San Antonio, TX) Rural Rental Housing Association – LIHTC Legislative Update
  • (Key Largo, FL) Council for Affordable Rural Housing – How National Appraisal Practices Impact USDA Assisted Properties
  • (San Francisco, CA) National Council of State Housing Agencies – Changes and Challenges in Rural Housing Development
  • (Chicago, IL) AHF Live – Preservation of Older LIHTC Deals
  • (Franklin, TN) Regional Affordable Housing and RAD Training – Valuation, Feasibility and Capital Needs Assessments
  • (Columbus, OH) Council for Rural Housing & Development of Ohio – Rural Housing Market Research
  •  (South Bend, IN) Great Lakes Capital Fund’s University of Affordable Housing – Valuation Risks Using Financing for RAD Deals
  • (Chicago, IL) National Council of State Housing Agencies – Rural Development Opportunities
  • (Orlando, FL) National Association of Housing and Redevelopment Officials – Affordable Housing Appraisals, Market Studies, Rent Comparability Studies and Rent Reasonableness Studies
  • (Alexandria, LA) Regional Affordable Housing and RAD Training – Valuation, Feasibility and Capital Needs Assessments
  • (Ft. Lauderdale, FL) Southeastern Affordable Housing Management Association (SAHMA) – Rent Comparability Studies 101
  • (Indianapolis, IN) Midwest Buyer/Seller Conference – CNAs and Appraisals
  • (Chicago, IL) AHF Live – Acquisition Challenges and Opportunities
  • (St. Pete Beach, FL) CARH – Preservation Challenges and Opportunities





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