HUD multifamily loan fees: every charge, with a worked $20 million example

The fee table

These are the charges the MAP Guide fixes. Everything else on a HUD closing statement (third-party reports, title, survey, borrower’s counsel) is priced by the provider, not by HUD.

The application fee is earned when HUD accepts the application for processing. If the loan is rejected or you walk away, it is not refunded.

The 223(f) inspection fee schedule

For a 223(f) purchase or refinance, the inspection fee follows the size of the repair scope, not the loan:

Repairs and improvements	Inspection fee
Less than $100,000 in total	$1,500 (HUD may reduce it if the lender takes on the inspection)
More than $100,000 in total and $3,000 or less per unit	$30 per unit
More than $3,000 per unit	the greatest of $30 per unit, 1% of repair cost, or $1,500

New construction pays $5 per $1,000 of the mortgage, and substantial rehabilitation pays $5 per $1,000 of total improvement costs. The fee is no longer calculated on BSPRA or SPRA.

The lender fee cap

For every program except 223(a)(7), the lender’s financing and placement fees, in any combination of origination, financing and permanent placement, may total no more than 3.5% of the mortgage, and that 3.5% must also cover the lender’s legal fee. In bond transactions the cap is 5.5%.

Three things sit outside the cap:

• Third-party reports. The appraisal, market study, capital needs assessment and similar reports are mortgageable soft costs and do not count against the 3.5%.
• MIP. It is a HUD charge, not a lender fee.
• Prepayment costs on the debt you are paying off. Defeasance or yield maintenance on existing debt can be included in a 223(f) loan up to 10% of the FHA loan amount.

The MAP Guide also bars lenders from advancing discount fees on the borrower’s behalf without a written HUD waiver. A February 2026 HUD drafting-table document would make discount fees mortgageable inside the 3.5% cap and allow 4.5% on loans of $2 million or less. That is a draft only. No final Mortgagee Letter has been issued, so the 3.5% cap stands.

If a mortgage broker or advisor brings the deal to a MAP lender, the MAP Guide (section 2.4) requires that their fee be paid from the lender’s fees and disclosed in the lender’s underwriting narrative.

223(a)(7) uses a two-tier cap

A 223(a)(7) streamlined refinance caps lender fees at 3.5% of the first $2,000,000 and 2.0% of everything above $2,000,000 (5.5% and 4.0% in bond deals). Lender legal fees are left out of that calculation.

Opportunity Zone reduction

For properties in a qualified Opportunity Zone, the application fee on 221(d)(4), 220 and 223(f) drops from 0.30% to 0.20%. The MAP Guide also lists a 0.10% fee for Opportunity Zone properties that were “Broadly Affordable” under HUD’s 2016 MIP notice. The September 2025 MIP notice eliminated the Broadly Affordable category, and HUD has not said how the 0.10% tier applies now. Ask the lender to confirm with the HUD office before counting on it.

MIP, the fee that changed most

Since applications submitted or amended on or after October 1, 2025, every FHA multifamily program pays 0.25% upfront and 0.25% a year. A market-rate 223(f) used to pay 1.00% upfront and 0.60% a year. Construction loans pay the annual rate for each year of construction (rounded up) at initial endorsement. The MIP guide has the history and the mechanics.

Worked example: a hypothetical $20,000,000 223(f) loan

This is a hypothetical deal to show the arithmetic, not a quote. Assumptions: 200 units, market rate, not in an Opportunity Zone, $500,000 of repairs ($2,500 per unit), application filed after October 1, 2025.

What the table leaves out, because HUD does not set it: the appraisal, capital needs assessment and Phase I environmental report, title and survey, your own legal counsel, and any rate lock or Ginnie Mae execution costs. Get those as quotes.

Two other cash items show up on many 223(f) closings:

• Repair escrow. Non-critical repairs finished after closing are escrowed at 120% of cost. On $500,000 of deferred repairs that is a $600,000 escrow, and the extra 20% ($100,000) cannot be financed. For affordable deals and 223(a)(7) loans the extra can drop to 10%.
• Replacement reserve. Every HUD loan funds a reserve for replacements; the initial deposit and monthly amount come out of the capital needs assessment, so they vary property by property.

If the repairs were larger. At $1,000,000 of repairs ($5,000 per unit), the inspection fee becomes the greatest of $6,000 (200 x $30), $10,000 (1% of repairs) or $1,500, so $10,000.

If the property were in an Opportunity Zone. The application fee would be $40,000 (0.20%), saving $20,000.

Under the old MIP. The same loan as market rate before October 2025 would have paid $200,000 upfront (1.00%) and about $120,000 in the first year (0.60%), so $150,000 more at closing and about $70,000 more in year one.

The same $20,000,000 as a 223(a)(7)

Line	Calculation	Amount
Application fee	$20,000,000 x 0.15%	$30,000
Inspection fee	none for 223(a)(7)	$0
Upfront MIP	$20,000,000 x 0.25%	$50,000
Maximum lender fees	3.5% x $2,000,000 + 2.0% x $18,000,000	up to $430,000

If the firm commitment expires

A firm commitment can be extended to no more than 180 days from issuance, plus a discretionary 60 days for good cause with HUD Headquarters approval. After that, reopening costs $0.50 per $1,000 ($10,000 on a $20 million loan), the request must reach HUD within 90 days of expiration, and the file needs updated third-party reports and mortgage credit documents. Rate lock delays can also trigger Ginnie Mae investor extension fees, which the MAP Guide leaves to the lender and borrower. The timeline guide covers how to avoid that.