fha office of residential care facilities section 232 – underwriting highlights, insurance,...
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FHA Office of Residential Care Facilities
Section 232 – Underwriting Highlights, Insurance, Closings, New
Construction
Underwriting HighlightsQueue updates, Closings & Timing
Firm Commitments Issued as of 4/25/2014
232 NC $166.1
f $1,848
(a)(7) $260.7
Firm Commitments Issued
$ in millions TOTAL298 for $2,275M
40 14
239
Firm Applications in Reviewas of 2/19/2014
232 NC $151.8
223(f) $1,558.3
(a)(7) $103.9
In Underwriting
TOTAL219 for $1,814M
$ in millions
1415
190
Firm Application Queue Numbersas of 4/25/2014
232 NC
223(f) .
(a)(7)
In Firm Queue
TOTAL 13
0
4
9
ORCF Underwriting Contract
Total in Firm Review
219
Contract Underwriters ORCF Underwri
ter
178 41 82% 18%
223(f) = 170
(a)(7) = 8
Current Contract Underwriter Assignments
Applications ReceivedFY 14 to 3/21/14
Type of Application
FY 11 FY 12 FY 13 FY 14
223f 347 458 456 187
223(a)(7) 302 221 399 23
Other 59 35 34 14
Total 708 714 889 224
Firm Commitments IssuedFY 14 to 4/25/14
Type of Application
FY 11 FY 12 FY 13 FY 14
223f 231 404 250 239
223(a)(7) 210 354 522 40
Other 32 25 34 19
Total 473 783 806 298
Insurance Changes
Proposed changes were vetted with MBA and large FHA servicing lenders along with FNMA New Requirements:• 90 % of Estimated Replacement Cost.• Loss of Business Income• Windstorm coverage• Expanded flood insurance coverage if facility is
located in flood zone
Decision Circuit
• Tool for setting the scope of the appraisal review.
• All applications are looked at by an ORCF appraiser.
• The scope of review is on a spectrum depending on risk factors.
Flags - Continued
NOI trending down for 3 years.Recent NOI at half of concluded rate.Private Pay or Medicare census higher than proven history. Medicaid census lower than history.Occupancy lower than 75%Change in potential resident daysRecent purchases
Green Flags (tend to offset red flags)
DSCR over 2.00LTV under 80%
• (LTV evaluated under two Scenarios)1. As underwritten2. Using most recent NOI and Avg Market Cap rate.
Special Consideration
Loans over $25 million History doesn’t match Operating Statement. Purchase within 3 years.
ORCF Loan Committee
For 223f main concerns and example mitigation:
• Valuing/sizing the loan using prospective NOI– Mitigation: Debt service reserve, reduce mortgage
• Patient/Resident care issues– Mitigation: Third-party risk management (one-time or on-going)
• Market concerns, facility low historical occupancy levels– Mitigation: Let season until operations turn-around,
management/marketing efforts• Loan term as it relates to some functional obsolescence
– Mitigation: Reduce loan term, reduce mortgage
Continued ORCF Loan Committee
New construction concerns• Borrower/Operator’s lack of experience in
developing and operating similar facilities • Low equity contribution less than 20 %• Market concerns• Size of facility in relation to comparable• Aggressive metrics used in loan sizing
Underwriting Highlights
What is going well New Process for Reviews – changesExpediting Processing & Reviews
Underwriting Highlights
Valuation Issues & ConcernsProspective or Aggressive NOI conclusionsNOI Conclusion not yet AchievedFluctuating NOI HistoryDeclining NOI trendAggressive Expense RatioAggressive Cap Rate
New Construction
Proposed New Construction
SUPPLY Competition – existing and proposed
(pipeline) Market position within PMA Saturation rates Reasonable capture rates
Replacement Facilities
SUPPLY Proximity Same demographics Same services – adding or deleting How many current residents will
transfer
New Construction Supply
CON’s and Moratoriums
CON (Certificate Of Need) Moratoriums on adding new beds State need calculations Only transfer within county
New Construction Supply
Transitional Rehab Facilities
Hospital discharges to rehab ALOS (Average Length of Stay) Hospital incentives Rehab purpose (cardio, stroke, hip,
orthopedic, etc.)
New Construction Demand
Demand determinants for Assisted LivingAgeHousehold IncomeHome ValueIncome QualificationLiving StatusAcuity, Mobility and Care LimitationsMemory Care Adjustments
New Construction Demand
Demand determinants for Skilled Nursing
AgeAcuityIncome QualificationMobilityDemand for Transitional Rehabilitation
Closings
Expediting Section 232 Closings
Closing TeamUpdates
ORCF’s Closing Team is keeping the “conveyor belt” of closing moving! FY 2013 had 766 closings, compared to 706 in FY 2012, 415 in FY 2011,
and 309 in FY 2010 Fiscal year to date volume much lower, mostly due to 223a7 volume
dropping off.
How do I get a HUD Closer assigned? For a HUD Closer assignment (and any other closing related
issues, including extensions) email [email protected] when the HUD Attorney closing package is mailed.
Average turnaround time for closer assignment right now: 1-2 business days
ORCF has 11 full time Closers and 3 contract Closers (most pictured below at our January 2014 Closing Kaizen)
Partnership & CollaborationPlease Remember: Complete, clean, and accurate closing packages get reviewed and
closed quicker All special conditions must be met and properly documented
prior to closing Use the Special Conditions Matrix!
Responsiveness to HUD Closer and HUD Attorney and fast turnaround is KEY
Closing Docs Closing Table