With input from the HUD Issues Committee, NRMLA recommended further changes to Forms HUD-9991 and HUD-9992 and that fees charged by condominium associations for completing these forms be considered a mandatory obligation that can be paid from the loan proceeds, according to comments submitted to the Department of Housing and Urban Development.
“Our members report that condominium associations, and their service providers, charge fees ranging from $150 to $800 for providing the information necessary to complete the forms,” NRMLA says in its comments. “For that reason, we requested clear guidance that the cost to obtain the information to complete Form HUD-9992 or Form HUD-9991 may be passed on to the borrower(s) and considered a mandatory obligation for a Home Equity Conversion Mortgage and permitted to be paid at closing.”
On July 31, 2020, HUD issued a notice that it would be renewing and revising Forms HUD-9991 and HUD-9992 – which are used to determine if a condominium project is eligible for FHA project approval and if a unit in an approved or unapproved condominium project is eligible for FHA-insured financing – and invited public comments.
View the full comment letter by logging into the Comment Letters section of NRMLAonline.org.