MBA Letter to HUD on Loan Disbursements

2024 Comment Letters Commercial / Multifamily FHA Multifamily Government Lending Government Servicing GSE Multifamily Policy Issue
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The Mortgage Bankers Association (MBA), and the lenders listed below, respectfully submit these comments on HUD’s proposed rule on disbursing multifamily mortgage proceeds. The proposed rule would allow 1% of mortgage proceeds to be drawn before equity is exhausted. We believe this is insufficient and urge HUD to allow mortgage proceeds to be drawn on any construction draw proportional to the amount of debt relative to total cost. Without this change, the costs of multifamily construction lending through the 221(d)(4), 220, 231 and 213 programs (“Construction Loans”) will continue to be negatively impacted.

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