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Mark-to-Market

The Mark-to-Market (M2M) program preserves affordability and availability of low income rental multifamily properties with federally insured program. The purpose of M2M is to reduce rents to market levels by restructuring existing debt to levels supportable by these rents.  The Green Initiative is also available through this program to assist owners in rehabilitating their properties in the most sustainable way feasible.

Owner/Project Eligibility
  • Multifamily Housing with more than four dwelling units. Covered in whole or in part by a project based Section 8 rental housing assistance contract.
  • Financed by a mortgage insured by FHA or held by the Secretary under the National Housing Act, excluding Section 202 and Section 515.
  • Determined to have current contract rents for all project based Section 8 assisted units that, in the aggregate, exceed the comparable unsubsidized market rents.
  • Determined to be in good standing.
Regulation, Legislation and Notices
  • Notice H-2012-10, "Guidelines for Assumption, Subordination, or Assignment of Mark-to-Market (M2M) Loan in Transfer of Physical Assets (TPA) and Refinance Transactions."  For more information on the notice refer to the Frequently Asked Questions (FAQs) to Housing Notice 2012-10.
  • Multifamily Assisted Housing Reform and Affordability Acts of 1997 (aka "MAHRA") was included in the Departments of Veterans Affairs, HUD and Independent Agencies Appropriations Acts, 1998. MAHRA was enacted to reduce the cost of federal housing assistance, enhance HUD's administration of such assistance, and to ensure the continued affordability of units in certain multifamily housing projects. Project owners with rents greater than market may request to participate in the Mark- to- Market program authorized by MAHRA. Contracts are renewed at existing rent levels temporarily while the mortgage is being restructured.
  • The Final Rule implements the legislation that created a Mark-to-Market program through which Section 8 rents for multifamily projects with HUD-insured or HUD-held mortgages will be reduced.
Post Mark-to-Market
  • A component of the M2M, addresses the processing of owner requests to refinance or to sell a property that has received the benefits of a debt restructuring under Mark-to-Market Program (M2M Program) 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 Recapitalizatoin (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, which have been traditionally mailed and/or emailed should be submitted electronically to PostM2M@hud.gov. Post M2M Processing documentation is also available.  
M2M Interest Group Information
M2M Resources
M2M Reports
  • The M2M Transactions Report provides a list of all the properties in the Mark-to-Market portfolio, it's ownership information and the last milestone of the property's program in the program. (Latest Update 10/1/2019: PDF / Excel).  For questions contact Recap's Systems Support Manager.

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