9.2.3 Timing Considerations
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. Lenders are required to submit all the exhibits necessary to identify and resolve any environmental issues with the Firm application submission via HEROS. For Lenders that use the pre-application process for new construction or substantial rehabilitation proposals, HUD requires the environmental documentation to be submitted via HEROS at pre-application. The purpose of completing HEROS at preapplication is to help make an early evaluation of any environmental issues so HUD can determine if all environmental issues can be resolved or a plan for mitigation can be approved prior to issuance of the Firm Commitment. The letter of invitation will condition the issuance of a Firm Commitment upon the environmental review finding that there are no unresolved environmental concerns.
B. Certain environmental issues cannot be resolved until the final plans and specifications have been submitted, which may result in HUD finalizing the environmental review during the Firm application rather than at pre-application.
28 For examples of acceptable conditions to the Firm visit https://www.hudexchange.info/programs/environmental-review/housing/#faq.
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Chapter 9 Environmental Review and Requirements 9.2 Procedures
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C. Any environmental problems present at the site will require a discussion of impacts to human health and appropriate mitigation measures. The Lender must provide mitigation plans for those environmental problems, as discussed in Section 9.2.1.B.
D. The implementation of mitigation and remediation plans may, with HUD approval, commence prior to initial endorsement or at commencement of and continuing throughout the construction period. HUD will review the Lender’s plan and make it a condition of the Firm Commitment if HUD considers the plan acceptable.
E. Lenders are strongly encouraged to request a HUD concept meeting to discuss all known and/or suspected environmental issues and concerns, and HUD staff are strongly encouraged to invite REO/FEOs to the concept meeting as discussed in Section 9.2.2.H.
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