Appendix 2 Quality Control Plans and Identity of Interest
A.5.10.1 Cost Not Attributable for New Construction
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. For new construction projects, costs not attributable is calculated as a percentage. The percentage consists of the ratio of the cost of the non-attributable spaces and facilities (abbreviated “B”) to the total cost of land improvements and structures (abbreviated “A”), known as the B over A ratio, or simply B over A.
B. Costs are generally based on gross floor area of the building, area of exterior site improvements, and/or lump sums.
To calculate “B” costs:
- Prepare a worksheet describing by category each item considered in Cost Not Attributable, showing the calculation of the cost of each item. Do not include General Requirements or fees in the calculation.
Show the basis of measurement and the unit price.
Summarize the categories and total in form HUD-92326 and Section M of form HUD-92264.
To calculate “A” costs:
- “A” is the sum of Total Structures and Total Land Improvements, before General Requirements or fees are added. To calculate “A”, add the amounts in lines 36c and 41 in Section G of form HUD92264.
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Appendix 5 Architectural and Construction Analysis A.5.10 Costs Not Attributable for New Construction
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To calculate B over A:
- Divide the “B” costs by the “A” costs. Express as a percentage and enter in Section M of form HUD92264.
C. There are two main categories of Costs Not Attributable: Residential and Commercial. Each is calculated independently of the other and each has a maximum limit of 15%, resulting in a total cost not attributable of up to 30% (see the example in Appendix 5, Section A.5.10.1.C.2 below). Every use must be categorized either as Residential or Commercial, but not both.
Residential Costs Not Attributable. This consists of non-attributable items solely for the use of residents of the project. Items to consider as not attributable to dwelling use are:
- Parking areas and the walks and driveways specifically leading to them and serving them. Do not include public roads and streets or walks and driveways that lead to and serve the building entrance.
Garages, garage spaces, and covered parking, and the walks and driveways leading to them, excluding public roads and streets.
Other improvements include :
- Community space, such as: multipurpose rooms, game rooms, lounges, libraries, and hobby or craft rooms, including furniture or movable equipment.
- Project administrative and maintenance spaces, such as: offices, repair shops, employee toilets, and janitor or cleaning closets, including furniture or movable equipment.
- Storage facilities that are not for tenant use.
- Recreational facilities, such as: swimming pools, tennis courts, basketball courts, and tot lots, including furniture or movable equipment.
- Works of art that are fixed in place, such as wall murals or permanent ornamental fountains.
Special Exterior Land Improvements are features unusual or in excess of those typical in projects for similar occupancy.
- Include such items as patios, sitting areas, and gazebos for the use of all project occupants. Include fountains and pools, exterior works of art, unusual trees and shrubs, and ornamental lighting and fencing.
- Do not include typical earthwork, roads and walks leading to and serving the dwellings, typical lawns and plantings, private balconies and patios, utility lines, retaining walls, or security lighting and fencing.
- Commercial Costs Not Attributable. This consists of areas or buildings and improvements intended for the use of the public as well as project residents. The most common commercial uses in residential developments are:
Shops,
Offices, and
Public parking.
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Appendix 5 Architectural and Construction Analysis A.5.10 Costs Not Attributable for New Construction
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Include only the basic and permanent structural improvements typical in vacant commercial space. Do not include equipment, fixtures, movable partitions, special finishes, etc., for a specific business.
- D. Limitation on Cost Not Attributable
Residential: The B over A ratio for residential costs not attributable should not exceed 15%. This is exclusive of any commercial space in the project, which will have a separate commercial cost not attributable.
Commercial: Commercial costs not attributable applies to commercial space such as shops that are in a residential structure but serve the general public as well as the residents. This is calculated separately from residential costs. The B over A ratio for commercial costs not attributable should not exceed 15 percent. The Lender’s Underwriter should be aware of the higher risk inherent in commercial space and take special care to evaluate the commercial market in order to determine the maximum commercial space that can be included in the project without imposing undue risk . Example: A project has residential Cost Not Attributable of 12% and commercial Cost Not Attributable of 7%. Each Cost Not Attributable category is within the 15% guidelines. Total Cost Not Attributable for the project is 12% residential plus 7% commercial, equaling 19%.
- E. Items not to be included in Costs Not Attributable:
Dwelling units. No portion of any dwelling unit, or any balcony or patio solely for the private use of the resident of the individual dwelling unit, is to be included in costs not attributable.
Utility rooms. Do not include utility rooms or portions of basements devoted to utilities such as boilers or furnaces, hot water heaters, water and sewer mains, gas mains, or electrical panels or closets.
Circulation elements. Do not include entrances, lobbies, halls, corridors, stairs, and elevators used by the occupants to enter and leave dwelling units. Do not include roads and walks that lead to and serve the dwellings.
Prorating of circulation elements. A prorating of circulation elements between dwelling use and any category in costs not attributable is not permitted.
Minor movable items that are not part of the real estate.
Commercial costs not attributable. Do not include equipment, fixtures, movable partitions, special finishes, etc., for a specific business.
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