POST-AWARD COMPLIANCE CHECKLIST

HUD 221(d)(4) FHA Multifamily Mortgage Insurance: Compliance Requirements

What you must do after you win this award — administered by US Department of Housing and Urban Development · Federal Program.

6
Total requirements
2
Clawback-risk items
6
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to maintain insurance with proper endorsements can trigger loan default and insurance claim denial
  • Labor & Wage: Non-compliance with Davis-Bacon can result in wage restitution requirements, disallowed costs, and sanctions
  • Financial & Cost Eligibility: Unapproved coverage may result in construction prohibition or forced modification at borrower expense
  • Environmental: Failure to test can result in construction stoppage and project non-compliance
  • Reporting: Failure to submit audits may result in loan covenant violation and acceleration of loan
  • Environmental: Failure to obtain radon testing can result in delay of final endorsement and project completion

Reporting

  • HighAnnual

    Borrowers must submit annual financial audits as required under FHA multifamily loan agreements.

    Deadline: As specified in loan agreement; typically within specified timeframe after fiscal year end

    Source: Arbor.com citing FHA multifamily loan requirements; search result index 9-8

Financial & Cost Eligibility

  • Clawback riskOngoing

    Insurance certificates must be provided to HUD and lender naming HUD and lender as additional insureds where applicable.

    Deadline: Maintained throughout construction and permanent loan term; renewal as policies expire

    Source: HUD Loans blog citing 221(d)(4) insurance requirements; search result index 1-1, 1-2

  • HighOne Time

    All insurance policies and coverage amounts must be reviewed and approved by HUD and the lender before binding.

    Deadline: Prior to construction commencement; periodic updates for renewals

    Source: HUD Loans blog citing 221(d)(4) insurance requirements; search result index 1-9

Labor & Wage

  • Clawback risk

    Contractors and subcontractors must submit weekly certified payroll reports evidencing compliance with Davis-Bacon prevailing wage requirements.

    Deadline: Each week during construction, with DOL clearance required upon construction completion

    Source: ADROC Capital citing 221(d)(4) requirements; search result index 3-9

Environmental

  • HighOne Time

    For projects involving substantial rehabilitation of pre-1989 buildings, asbestos test reports are required; for pre-1978 buildings, lead-based paint test reports are required.

    Deadline: Prior to construction completion and final endorsement

    Source: ADROC Capital citing 221(d)(4) requirements; search result index 3-8

  • HighOne Time

    Radon test reports must be obtained for all projects following construction completion regardless of EPA radon zone classification.

    Deadline: Upon construction completion before final endorsement

    Source: ADROC Capital citing 221(d)(4) requirements; search result index 3-2, 3-7

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with US Department of Housing and Urban Development.