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HUD Refinance223(f) · 232 · 223(a)(7)

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Diligence

The Stale-Data Checklist: Is Your Term Sheet Current?

Five HUD changes between January 2025 and May 2026 reset the numbers on FHA refinancing. Here is how to tell in two minutes whether the document in front of you predates them.

Reviewed October 13, 2026  ·  All primary sources

FHA program terms moved substantially between January 2025 and May 2026. Most published material — including term sheets from major lenders and the reference sites that rank highest for these searches — has not fully caught up. Undated PDFs are the norm in this industry, which makes a document's vintage hard to establish and easy to misjudge.

Below is a checklist. If a document you are relying on contains anything in the left column, it predates a change and its other figures deserve the same scrutiny.

The five changes

Stale figure → current figure
If it says…CurrentChanged by
223(f) MIP of 1% upfront / 0.60% annual0.25% / 0.25%FR-6522-N-02, Sept. 23, 2025
Green MIP discount of 25 bp availableEliminatedSame notice; Aug. 25, 2025 for 232
Broadly Affordable or Inclusionary-Voucher MIP tiersEliminatedSame notice
223(f) market rate at 85% LTV / 1.176x87% / 1.15xML 2025-03, Jan. 8, 2025
223(f) affordable at 87% / 1.15x90% / 1.11xML 2025-03
Repair threshold of $15,000 per unit (or $15,536)$20,406 base for 2026ML 2026-05, May 20, 2026
Large loan threshold of $120M or $125M$130MIndexed; 2025–2026
“Property must be at least three years old”Superseded — 1.17x for 3 monthsML 20-03, Mar. 2, 2020
232 MIP of 0.25% / 0.25%100 / 65 bp for 232/223(f)232 excluded from the 2025 cut
232 refinance at 85% / 90% LTV80% / 85%Handbook 4232.1, Ch. 3
232 equity take-out “may be available”ProhibitedHandbook 4232.1, §3.13

The two errors that run in opposite directions

There is a symmetry worth noticing. On the multifamily side, the common error is understating borrower benefit — quoting the old MIP and the old leverage, which makes FHA look worse than it is and sometimes steers a borrower to agency debt on bad numbers.

On the healthcare side, the common error is overstating it — applying the multifamily MIP cut to Section 232, publishing 85%/90% leverage instead of 80%/85%, and suggesting cash-out is possible when it is prohibited. That direction is worse, because it produces a transaction that cannot be done after the application fee has been spent.

The most consequential single error in the field is the suggestion that Section 232 permits equity take-out. We have found it on prominent reference pages, and reinforced on at least one lender term sheet that presents debt-seasoning LTV bands as though they were cash-out tiers. A healthcare owner who builds a liquidity plan on that will reach the end of a months-long process with nothing. See Section 232 forbids cash-out.

How to date an undated document

Few lender term sheets carry an “as of” date. Three ways to estimate:

  1. The MIP line. The single most reliable tell. 1%/0.60% on a 223(f) means pre-October 2025. 25/25 on a 232 deal means the author applied the wrong notice.
  2. The DSCR and LTV. 1.176x or 85% means pre-January 2025.
  3. The filename or footer code. Many are versioned rather than dated — a trailing code like 0325 or V022526 often encodes a month and year. It is an inference, not a date, but it is usually the only signal available.

Three questions for any advisor

  • “What is the annual MIP on this program, and which notice sets it?” A current advisor names the rate and can point to the Federal Register notice. If the program is 232 and the answer is 25 basis points, stop.
  • “What DSCR applies if the property got its certificate of occupancy fourteen months ago?” Current answer: 1.17x for three consecutive months on a market-rate deal, with a 50% cash-out holdback. “It has to be three years old” means pre-2020 material.
  • “What is the substantial rehabilitation threshold for this property's market this year?” A current answer starts from $20,406 and applies the high-cost percentage. An answer of $15,000 is a decade old.

A word on our own currency

Everything on this site carries a review date, and every program figure cites the mortgagee letter, Federal Register notice or handbook section that sets it. We re-verify against HUD's numbered mortgagee letter list, the Federal Register and the drafting table on a recurring schedule, and where a provision is a draft rather than operative guidance we say so. Figures stated as current here are current as of the date in the page header — and if you find something on this site that has gone stale, we would like to know.

Primary sources for this article

Figures stated as current are current as of October 13, 2026. HUD revises mortgagee letters and handbooks frequently; where a provision is a draft rather than operative guidance we say so on the page. This is general information, not legal, tax or financial advice, and not a commitment to lend.

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Important disclosures

Affiliation disclosure. HUD Refinance is an information resource. It is not itself a lender, a government agency, or an agent of the U.S. Department of Housing and Urban Development, and it is not affiliated with or endorsed by HUD or the Federal Housing Administration. HUD Refinance is affiliated with a HUD-approved MAP lender, and inquiries submitted through this site may be reviewed by that affiliated lender. We may have a financial interest in transactions that result. That lender is identified by name in our first reply to any inquiry, and no engagement proceeds without full disclosure of the relationship. Readers should weigh the information here accordingly and are free to take any transaction to a lender of their own choosing.

Nothing on this site is a commitment to lend, an offer of credit, a pre-qualification, or an application for mortgage insurance. FHA mortgage insurance is available only through a HUD-approved MAP or LEAN lender, and all terms are subject to lender underwriting and HUD review and approval.

The program terms summarized here are drawn from HUD mortgagee letters, Federal Register notices, the MAP Guide (Handbook 4430.G) and the Section 232 Handbook (4232.1), each cited on the page where it is used. HUD revises these materials frequently, sometimes without notice, and provisions may be superseded between our review dates. Figures stated as current are current as of October 13, 2026. Loan sizing is always the lowest of several statutory and underwriting tests applied to a specific property, and no figure on this site should be read as the amount any particular project can obtain.

This site does not publish interest rates. Pricing on FHA-insured loans is set at rate lock by then-prevailing market conditions and varies by lender, execution and credit.

Nothing here is legal, tax, accounting, investment or financial advice, and no attorney-client or fiduciary relationship is created by using this site or submitting the inquiry form. Consult qualified counsel, your accountant and a HUD-approved lender before acting on any information here. Submitting the form does not create a client relationship and should not be used to transmit confidential or non-public personal information.