July is right around the corner and we wanted to remind everyone of the HUD deadlines for closing RAD conversions by year end:
|Required Action||Deadline to close by
November 30, 2018
|Deadline to close by
December 31, 2018
|Upload all required Financing Plan
|June 15||July 13|
|Receive a HUD-executed RCC**||August 17||September 14|
|Submit complete closing package**||September 1||October 1|
|All RAD documents approved and ready for HUD signatures**||November 15||December 13|
* Note: FHA applications should be submitted at roughly the same time as the Financing Plan documents. PHAs should coordinate with their FHA lender to stay on track.
** Note: An RCC that has already been extended up to or beyond 6 months past the date of issuance will have a lower priority for closing during CY2018.
These deadlines don’t always align with standard low income housing tax credit closings and can sneak up quickly. Keep the following tips in mind to manage a successful year end conversion:
- Know the RAD checklists (PBV and PBRA) and what transaction documents must be submitted to HUD.
- Work out any title and survey issues before HUD submission.
- Establish a detailed RAD timeline and engage with financing partners as soon as possible on the timeline.
- Share the HUD-required ownership and control provisions that must be included in transaction documents with financing partners prior to the circulation of draft documents.
- Share the HUD sample RAD Subordination Agreement with lenders as soon as possible.
- If necessary, consider prioritizing circulation and review of transaction documents that must be submitted to HUD.
- Account for the time between receiving final HUD approval and HUD signing and mailing documents – this can take over a week.
- Aim to make an initial submission to HUD within 2 weeks of RCC issuance (if not sooner). A submission beyond 2 months of RCC issuance will have the transaction placed in “Delayed Submission” status.
- Make HUD aware of any targeted and hard closing deadlines.
Cheers to a smooth year end!