FHA’s “6-Month Window” for Condo Recertification
This week I received a call from a property manager who was concerned that the 6-month window for recertification with FHA was quickly approaching. The condominium’s FHA approval expired on 3/21/14 and the manager and association were concerned that they would have to get recertified by 9/21/14 or else risk losing their approval.
The manager called me to see if I could expedite the process as he felt that he and the association would not be able to get it done as quickly as a professional service.
I told him that we would be happy to handle the recertification process for him and his client. I went on to say that in the interest of full disclosure, there is no 6-month window for FHA recertifications at present. A full submission package would need to be supplied to FHA as if it had never been approved.
Initially in 2011, when HUD released the Condominium Project Approval and Processing Guide, it named a “Recertification Period”. During this time, approved condominiums could apply for FHA recertification. The Recertification Period stretched from 6 months prior to the expiration of the approval to 6 months following the expiration.
If an approved condominium submitted a recertification package to HUD during this time period, only new and updated information would need to be provided. So-called “permanent documents” would not need to be re-supplied, which would reduce the required paperwork for recertification.
“Permanent documents” typically include the condominium’s legal governing documents, building plans, plat maps, site plans and flood maps. Obviously, if any of these are modified or amended, the new documents must be supplied as part of the recertification package.
If a package is submitted after this 6-month window closed, the condominium would have to go through the full approval process and all required documents for approval would need to be re-supplied. This would also include the “permanent documents”.
It was HUD’s intention to store submission packages electronically so that the permanent documents would not have to be re-supplied and re-reviewed every two years. Unfortunately, at the time, HUD did not have the capability to store the documents electronically.
Because of this, current recertification packages must include everything that a full submission package would include. Thus, there is no 6-month window. I would expect that HUD will be implementing this procedure in the near future and those that are being approved and recertified now will be able to take advantage of the streamlined process in two years.
I told the property manager, there is no cause for concern with the 9/21/14 deadline for recertification. It simply doesn’t exist. I could hear the relief in his voice over the phone.