The same apartment project sizes three different ways. HUD's 221(d)(4) lends against cost and projected income at a
fixed rate; a bank is held to an 80% loan-to-value limit and HVCRE's 15% equity rule; a debt fund lends what it
negotiates. Put in your project and the terms you've been quoted.
The spreads and the bank and fund loan-to-cost figures are placeholders, not market data: replace them with the terms you're quoted. Results are rounded illustrations, not offers.
HUD 221(d)(4)
$41,760,000
limited by 87% of cost
Rate
5.54%
Loan to cost
87.0%
Equity needed (before interest and escrows)
$6,240,000
Construction interest and upfront MIP
$2,230,000
Fixed rate through construction and a 40-year amortizing term; no refinance at completion.
Interest by HUD's MAP formula plus 0.5% upfront MIP.
Davis-Bacon wages; a 4% working capital escrow and an initial operating deficit escrow on top.
Bank construction loan
$28,800,000
limited by the bank's 60% loan-to-cost
Rate
6.89%
Loan to cost
60.0%
Equity needed (before interest and escrows)
$19,200,000
Construction interest
$1,570,000
Floating over SOFR, usually interest-only, with a take-out loan needed at stabilization.
Rate and loan-to-cost are your quote; the 80% and 15% limits are regulatory.
Debt fund
$36,000,000
limited by the fund's 75% loan-to-cost
Rate
8.89%
Loan to cost
75.0%
Equity needed (before interest and escrows)
$12,000,000
Construction interest
$2,530,000
Not a bank, so not bound by the supervisory limits or HVCRE. Terms are whatever you negotiate.
Floating and interest-only, with a take-out needed at stabilization.
Where the limits come from
HUD 221(d)(4). Since Mortgagee Letter 2025-03 (January 8, 2025), market-rate projects can borrow 87% of
cost at 1.15 debt service coverage, and affordable or heavily assisted ones 90% at 1.11. HUD counts principal, interest
and the 0.25% mortgage insurance premium as debt service (MAP Guide 3.1.25; 90 FR 45789). Construction interest uses
HUD's own estimate: half the mortgage, at the note rate, for the construction months plus two (MAP Guide 7.11.1). The
upfront premium is 0.25% for each year of construction. The 5.54% default is the median note rate on FHA
apartment loans endorsed in the year to September 30, 2026, from HUD's insured mortgage file. The sizer leaves out
HUD's per-unit statutory limits, which can bind on studios, one-bedrooms and high-cost projects.
Banks. The federal banking agencies' supervisory loan-to-value limit for commercial and multifamily
construction is 80% (12 CFR Part 365, Appendix A, with the same table in the OCC's and Fed's rules). A loan stays out of
the high volatility commercial real estate category, and its 150% capital charge, when the loan-to-value is within that
limit and the borrower contributes capital of at least 15% of the as-completed appraised value before the bank funds
(12 CFR 324.2). Banks set their own loan-to-cost on top.
Debt funds aren't banks, so neither rule applies. Everything in that column is your input.
Interest on floating loans uses the same half-the-loan average balance HUD's formula uses, at SOFR plus
your spread, for the construction months. SOFR defaults to the New York Fed's 30-day average of 3.889% on
. Construction months default to the Census Bureau's 2025 national average for
buildings with 20 or more units, 19 months.
Comparing real quotes?
Send the project to the commercial mortgage team at Janover Capital LLC with the budget and pro forma. A person there will
reply with a first read on which path fits. Any terms come from the lender.