Can an interest rate reduction loan modification (“IRR”) only be done by the lender that currently holds a note?
If another lender intends to purchase the rights to the note and become mortgagee of record, there must be, at a minimum, consent of the current mortgagee of record in the submission package. The Mortgagee Record Change form is required to be submitted in situations where you have a transfer of mortgagee. -- Dec-16
If the MIP rate has increased since a loan closed, would an IRR trigger an increase in the MIP rate?
IRRs do not trigger a change in the MIP rate. After receiving the modified note through the portal as, “Interest Rate Reduction-Final,” ORCF will forward the amended note to the Multifamily Insurance Branch (MFIOB) to provide a new amortization schedule for the remaining term of the loan which will change the MIP amount in subsequent years. -- Apr-21
Are PCNAs required for IRR applications?
PCNAs are required if a PCNA or comparable reserve analysis (e.g., as found in a 232NC application) has not been submitted to HUD in the previous 10 years. This PCNA requirement is an IRR program requirement, and the existing regulatory agreement has no bearing on whether a PCNA must be submitted. -- Dec-16
If a PCNA is required, can the PCNA be submitted after the IRR application to allow the borrower to rate-lock as soon as possible?
Yes. In order to start the IRR review as soon as possible, the PCNA can be submitted within 90 days of the submission. A special condition will require the borrower and lender to certify that the PCNA will be submitted within that timeframe. -- Dec-16
Will the IRR review team process other applications (e.g., Change of Participants (CHOP)) as part of the IRR review process?
No. The review team only processes IRRs to complete them as efficiently as possible. If other project actions are required that may impact your ability to complete the IRR, contact your assigned HUD account executive as early as possible before submitting your IRR. -- Dec-19
If exhibits in the IRR checklist are unavailable or difficult to obtain, can we submit the IRR application without them?
As a general rule, no. ORCF may give you permission to submit the application without the exhibits under extraordinary circumstances, but there will be a special condition governing those circumstances. In certain situations, ORCF will refuse to close the IRR if the exhibits are not provided before closing. -- Dec-16