Berkadia | HUD 2025 Green MIP FAQs

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2025 GREEN MIP ELIMINATION & OVERALL MULTIFAMILY MIP REDUCTION

Frequently Asked Questions

SEPTEMBER 2025

On September 22nd, 2025, the U.S. Department of HUD officially enacted the leveling of all FHA multifamily mortgage insurance premiums (MIP) to 25 basis points, eliminating the Green MIP Program. The MIP changes will be effective October 1, 2025; the elimination of the Green MIP Program is immediate. Please find below answers to frequently asked questions. For further information, please reach out to your Berkadia representative. Full details can be found here: https://public-inspection.federalregister.gov/2025-18379.pdf

When does the new MIP become effective?

The MIP changes will be effective October 1, 2025 for all transactions that have yet to reach initial endorsement; the elimination of the Green MIP Program is immediate.

Applications prior to Commitment:

How do I switch my application to eliminate the Green requirements now that all MIP is 25bps?

Unless otherwise discussed, your Berkadia team is making appropriate requests to eliminate all Green MIP requirements in the application prior to submission.

For cost-limited applications which had previously incurred costs to pursue Green, are these sunk costs eligible as mortgageable costs?

Berkadia believes these are eligible mortgage costs.

Applications with Commitments:

What action should be taken for non-Green applications that have a Firm Commitment?

Unless otherwise discussed, your Berkadia team will submit a commitment amendment for MIP reduction and debt service changes, with approval expected after October 1.

What action should be taken for Green MIP applications that have a Firm Commitment?

Unless otherwise discussed, your Berkadia team will submit a commitment amendment to address changes in MIP reduction, debt service, and Non-Critical repair scope of work, with approval expected after October 1.

For Construction Loans – can development scope be reduced to eliminate items and costs which were previously included for Green only?

The Berkadia team will submit a commitment amendment to address the MIP reduction, debt service, and removal of the green building certification scope. Approval is expected after October 1.

Closed Loans in Construction Period:

Must all construction be completed as previously approved by HUD?

For construction projects in process, the green building inspection and certification can be discontinued as part of construction. No change orders for change of scope or green materials will be accepted.

2025 GREEN MIP ELIMINATION & OVERALL MULTIFAMILY MIP REDUCTION

Frequently Asked Questions

SEPTEMBER 2025

Closed (Post-Construction) Loans

Currently with Green MIP:

What action should be taken for in-place loans currently with Green MIP?

Effective Immediately, Green MIP compliance and reporting requirements are no longer applicable. Please stop all Green MIP-related work and contracts with any 3rd party consultants.

Based on the fact that HUD has a long history of changing their focus as administrations change, how do existing deals comply with their closing notes when HUD no longer wants annual reporting? Additionally, the required reporting website the EPA uses for annual audits is down. Is that permanent?

The final published regulation will supersede those closing notes.

How should planned, future refinances in four to eight years be approached? Should Green Certification be pursued now to plan for a future changing HUD leadership?

As we have seen, requirements can change with administration priorities, and it is certainly possible that new requirements will be published in the future related to energy efficiency. It is impossible to know when or whether such a change would occur, or to define potential scope. Speak with your Berkadia Mortgage Banker to weigh the pros and cons of obtaining such a certification.

What happens to loans that currently have a failing score?

Since Green MIP compliance has been eliminated, no further action is needed to meet any previous requirements.

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