Post Mark-to-Market (M2M)
Post M2M is an extended component of the Mark-to-Market program under the Office of Recapitalization (Recap). The program addresses the processing of owner requests to refinance or to sell a property that has received the benefits of a debt restructuring under M2M or M2M Program’s predecessor program, the Portfolio Reengineering Demonstration Program (Demo Program). This also applies to applications for either debt assumption or forgiveness for a non-profit qualified by HUD for such benefits (QNP). These procedures require coordination between the Office of Recap and other staff within Multifamily Housing (typically Field Office staff). All inquiries and requests related to Post Mark-to-Market (Assumption Subordination and Qualified Non Profit) transactions, should be submitted electronically to PostM2M@hud.gov.
Guidance and How to Apply
- Guidelines for Certain HUD Approvals Regarding Properties Encumbered by HUD-Held Mark-to-Market Program Debt and Portfolio Reengineering Demonstration Program Debt (Note: This Notice, published June 30, 2021, supersedes Notice H 2012-10 and Appendix C of the Mark-to-Market Operating Procedures Guide)
- Draft M2M Waiver Request Applicant Checklist
- M2M Waiver Request Application (Microsoft Excel: Use Microsoft Edge or Internet Explorer to View/Open the File)
- Multifamily Regional Office Review Guidance for Post Mark-to-Market Transactions without Remaining HUD Debt
Post Mark-to-Market Forms and Templates
Post M2M is an extended component of the Mark-to-Market program under the Office of Recapitalization (Recap). The program addresses the processing of owner requests to refinance or to sell a property that has received the benefits of a debt restructuring under M2M or M2M Program’s predecessor program, the Portfolio Reengineering Demonstration Program (Demo Program). The purpose of this page is to provide form documents and templates relevant to PM2M processing as part of the Paperwork Reduction Act (PRA) collection 2502-0533. For questions on the documents listed on this page send us an email at postm2m@hud.gov.
Document Index: Qualified Non-Profit Purchaser (QNP) Legal Documents | Final Sale or Refinance Legal Documents
Budget Based Rent Adjustments (BBRA) for Mark-to-Market (M2M) Properties
Overview
BBRAs are available for existing M2M properties that lack sufficient project income to operate and maintain the property on a sustainable basis for the long-term. BBRAs are to increase housing assistance payment contract (HAP) rents to levels that can support property expenses, including debt service coverage and deposits into a reserve for replacements. Properties will be prioritized based on its condition and the relationship between the property’s contract rents and the Fair Market Rent, due to limited funding.
Highlights
- PM2M BBRA Wait List (Updated 04/30/2025)
- Have questions on BBRA? The Post-M2M BBRA Processing Clarifications can provide answers to basic questions about the program.
- HUD published Housing Notice 2024-05, which implements the Department's authority to make BBRAs.
- The training that was held on March 12, 2024 is now available on HUD's YouTube channel or view the Presentation slides.
Apply Now
Initial Submission are now being accepted in the Multifamily Preservation Desk for properties that meet Group A criteria and notice eligibility requirements only. Requests will be reviewed on a first-come-first-served basis, but applications received within 28 calendar days after the publication of the notice (before 11:59 PM EST on March 28, 2024,) shall be deemed received simultaneously. Please submit any questions to bbra@hud.gov.
Apply for a BBRA
Group A Properties (must meet one (1) of the following criteria):
- REAC score < 30
- 2 consecutive REAC scores < 60
- Operating Cost Coverage Ratio < 1.0
- Owner Contributions of over $3,000 in the last year or a 3-year record of Owner Contributions over $1,500 per year
- Property is with the Multifamily Property Disposition Center
- Vacancy Rate >= 25% for 24-months