WBK Industry - Federal Regulatory Developments

HUD Re-Extends Interim Procedures for Site Access for Section 232 Mortgage Insurance Applications During the COVID-19 Pandemic

HUD recently issued ML 2020-50, which re-extends interim procedures for site access for Section 232 mortgage insurance applications during the COVID-19 pandemic.  HUD initially issued the procedures in ML 2020-10, on April 10, 2020, and extended them in ML 2020-15, on May 28, 2020. 

Through ML 2020-50, the HUD Office of Residential Care Facilities (ORCF) extends through March 31, 2021, the interim procedures providing guidance for third-party site inspections of Section 232 FHA-insured residential healthcare facilities.  These include procedures for property capital needs assessments, appraisals, and Section 232 Phase I environmental site assessments, asbestos surveys, and radon testing.  In addition, lender underwriter site visits are waived for Section 232 applications submitted no later than March 31, 2021. There are also allowable deviations from the normal procedures related to monthly construction inspections for new construction, substantial rehabilitation, and Section 241(a)s. 

Finally, ORCF noted that due to the pandemic’s effect on market stability, it will not grant waivers for appraisals that are older than the 180 days allowed for refinances and 120 days for new construction, as timed from the effective date of value.