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Mark-to-Market (M2M for Owners)

Owners of properties with expiring Section 8 contracts initiate the Mark to Market (M2M) process when they request a Section 8 contract renewal and select options in accordance with the Section 8 Renewal Policy Guide Book, last published in March 2023, 120 days before Section 8 contract expires. The owner notifies the HUD Multifamily Program Center or Hub of their renewal selection.

Owners with questions about the status of their M2M properties may e-mail us at m2minfo@hud.gov or refer to the status report: the M2M Transactions Report. This quarterly report provides a list of all the properties in the Mark-to-Market portfolio, it's ownership information and the last milestone of the property's program in the program. (Latest Update December 22, 2023: PDF | Excel). For additional questions contact us at m2minfo@hud.gov. | Note: Use Microsoft Edge or Internet Explorer to View/Open the Excel File

Mark-to-Market Process

  1. Recap assigns property to PAE for debt restructuring or rent reduction only ("Lite")

  2. Recap notifies owner of PAE assigned to property

  3. Kick off meeting held with owner and PAE

  4. Owner performs data collection PAE performs due diligence

  5. Tenant meeting held PAE performs underwriting

  6. Tenant meeting held PAE submits restructuring plan to Recap

  7. Recap reviews and approves plan

  8. Owner executes restructuring commitment

  9. Closing

 

Post M2M and DEMO Accounting and Audit Questions
  • General Filing Questions: Owners and accountants with questions related to technical aspects of filing AFS using HUD's FASS should refer to the Real Estate Assessment Center (REAC) website - FASS. That site includes contact information for REAC staff and a toll free number for the FASS Technical Assistance Center.
  • Questions unique to M2M and DEMO properties: In response to questions from owners and accountants of previously restructured properties, Multifamily Housing has issued accounting letters annually to owners, since 2004. Those letters address many of the most common accounting questions raised in relation to properties that have completed the M2M and/or DEMO restructuring process and the most common errors from prior years? filings. Letters have been mailed in hard copy to M2M and DEMO owners' monthly billing addresses, emailed to accountants identified in FASS that have filed M2M and/or DEMO AFSs, and have been emailed to HUD MF, REAC and DEC staff. The letters are available in both PDF and WORD formats:
  • The Excel workbook was developed as a tool to assist users searching for answers to M2M/DEMO accounting questions. It consolidates all Q&As issued from 2004 through 2009 and may be searched and filtered more easily than possible when using the individual Word files. Please refer to the source documents (posted above) for introductory comments which address timing and put individual letters into context. Multifamily Housing staff have annotated in the Excel workbook when an answer changed a prior decision (the source documents above are not modified). We have also annotated questions that are similar, with significant nuances. Look for the phrases "see also" or "superseded" in the answer. Changes in formatting required that some answers be split among two or more cells, so check to be sure you are reviewing the ENTIRE answer (e.g., column C lists the first question from 2005 as #1a and 1b because the entire answer did not fit in one cell).

Owners (or their accountants) may also submit questions related to the M2M aspects of the Annual Financial Statement (AFS) to the M2M Resource Desk.

M2M Resources

To request more information, email us at m2minfo@hud.gov.