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2.6.4.6 Other Lender Conflicts

HUD Multifamily Accelerated Processing (MAP) Guide, HUD Handbook 4430.G (2020 ed., rev. Mar. 19, 2021) · 2026 edition · updated 2026-10-05 · United States

A. MAP Lenders may occasionally seek to invest in a project financed under MAP by a separate “Underwriting MAP Lender”. If the Borrower has an IOI relationship with a MAP Lender, that “IOI MAP Lender” cannot assist in underwriting, purchasing, or servicing the loan until after Final Endorsement. The arrangement to assign the loan after Final Endorsement is subject to full disclosure before processing begins, including certification and approval by HUD and the adoption of appropriate procedures in each MAP Lenders’ QC Plans. The Conflict of Interest risk may be mitigated by meeting the following requirements:

  1. The IOI relationship must be fully disclosed as a planned business practice in both MAP Lenders’ QC Plans. With each application, the Underwriting MAP Lender must include a certification that includes the applicable criminal penalty warning. The warning must certify that the IOI MAP Lender had no involvement in the underwriting process and that the referring entity had a “firewall” such that only employees of the owner/ equity investor affiliate of the IOI Map Lender provided information to the Underwriting MAP Lender.

  2. The Underwriting MAP Lender must have made no specific written or oral obligation to assign the loan to the IOI Map Lender after Final Endorsement and must retain the right to assign, or refuse to assign, the loan to any servicer or to hold the loan.

  3. The IOI Map Lender must have made no written or oral obligation to purchase the loan from the Underwriting MAP Lender after Final Endorsement and must retain the right to sell, or refuse to sell, the loan.

  4. Any dealings between the IOI MAP Lender and the Underwriting MAP Lender must be arm’s length and independent at all times, including after issuance of a Firm Commitment. The IOI MAP Lender may not advise or assist the Underwriting MAP Lender in processing the loan or with making any underwriting decisions.

  5. The IOI MAP Lender may not receive a mortgage broker’s, consultant’s or correspondent’s referral fee from the mortgage proceeds.

  6. HUD will only accept application packages, correspondence and information related to the loan that are submitted by the Underwriting MAP Lender.

  7. The IOI MAP Lender may not hire or interact with third-party contractors, except that its equity affiliate may respond to inquiries from the Underwriting MAP Lender’s third parties. Such interactions must be isolated by the firewall described in the Lenders’ QC Plans.

  8. Third-Party contractors may not have any IOI with the Borrower or the Underwriting MAP Lender at the time they are providing their services.

MAP Guide, March 2021 Go to beginning of Chapter 2

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Chapter 2 Page 2-11

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Chapter 2 Lender Qualifications and Practices 2.6 Identity of Interest, Conflicts of Interest

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  1. Both Lenders must have appropriate and acceptable QC practices that provide for an effective firewall and must provide for objective and independent loan origination and underwriting processes. Such practices and procedures must be defined in each MAP Lenders’ QC Plan and be approved by COB.

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▸Contents — HUD Multifamily Accelerated Processing (MAP) Guide, HUD Handbook 4430.G (2020 ed., rev. Mar. 19, 2021)
HUD Multifamily Accelerated Processing (MAP) Guide, HUD Handbook 4430.G (2020 ed., rev. Mar. 19, 2021)

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