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Mark to Market for Owners

Owners of properties with expiring Section 8 contracts initiate the Mark to Market (M2M) process when they request a Section 8 contract renewal and select options in accordance with the Section 8 Renewal Policy Guide Book, last published in 2017, 120 days before Section 8 contract expires.

The owner notifies the HUD Multifamily Program Center or Hub of their renewal selection.

Owners with questions about the status of their M2M properties may e-mail us at m2minfo@hud.gov or refer to the status reports: PDF format or Excel spreadsheet.

Mark-to-Market Process
  • Owner requests Section 8 contract renewal option (in accordance with Section 8 Renewal Policy Guide Book) 120 days before Section 8 Contract Expires
  • Recap assigns property to PAE for debt restructuring or rent reduction only ("Lite")*
  • Recap notifies owner of PAE assigned to property
  • Kick off meeting held with owner and PAE
  • Owner performs data collection PAE performs due diligence
  • Tenant meeting held PAE performs underwriting
  • Tenant meeting held PAE submits restructuring plan to Recap
  • Recap reviews and approves plan
  • Owner executes restructuring commitment
  • Closing
Post M2M and DEMO Accounting and Audit Questions
  • General Filing Questions: Owners and accountants with questions related to technical aspects of filing AFS using HUD's FASS should refer to the Real Estate Assessment Center (REAC) website - FASS. That site includes contact information for REAC staff and a toll free number for the FASS Technical Assistance Center.  
  • Questions unique to M2M and DEMO properties: In response to questions from owners and accountants of previously restructured properties, Multifamily Housing has issued accounting letters annually to owners, since 2004. Those letters address many of the most common accounting questions raised in relation to properties that have completed the M2M and/or DEMO restructuring process and the most common errors from prior years? filings. Letters have been mailed in hard copy to M2M and DEMO owners' monthly billing addresses, emailed to accountants identified in FASS that have filed M2M and/or DEMO AFSs, and have been emailed to HUD MF, REAC and DEC staff. The letters are available in both PDF and WORD formats:
  • The Excel workbook was developed as a tool to assist users searching for answers to M2M/DEMO accounting questions. It consolidates all Q&As issued from 2004 through 2009 and may be searched and filtered more easily than possible when using the individual Word files. Please refer to the source documents (posted above) for introductory comments which address timing and put individual letters into context. Multifamily Housing staff have annotated in the Excel workbook when an answer changed a prior decision (the source documents above are not modified). We have also annotated questions that are similar, with significant nuances. Look for the phrases "see also" or "superseded" in the answer. Changes in formatting required that some answers be split among two or more cells, so check to be sure you are reviewing the ENTIRE answer (e.g., column C lists the first question from 2005 as #1a and 1b because the entire answer did not fit in one cell).

Owners (or their accountants) may also submit questions related to the M2M aspects of the Annual Financial Statement (AFS)to the M2M Resource Desk.

M2M Resources
  • The Green Initiative was introduced in 1997 as a nationwide pilot initiative to encourage owners and purchasers of affordable, multifamily properties to rehabilitate and operate their properties using sustainable Green Building principles. These principles comprise sustainability, energy efficiency, recycling, and indoor air quality, and incorporate the "Healthy Housing" approach pioneered by HUD. To date, the Green Initiative is in full swing with a focus on properties within HUD's Section 8 portfolio, specifically properties in the Mark to Market (M2M) Program.
  • Mark-to-Market Rehabilitation Escrow Completion: This memo sets forth guiding principles under which HUD will act to ensure the timely completion of the physical repairs specified under each Rehabilitation Escrow Deposit Agreement (REDA). The memo is available in PDF only. (April 27, 2004) 
  • Clarification of Multifamily Housing's 401.600 Waiver Policy: The documents below clarify Multifamily Housing's 401.600 Waiver Policy. Significant points are:(1) Owner cooperation is required for any waiver; (2) Waivers will be granted for a minimum of 90 days, maximum 180 days; (3) Owners who do not cooperate while under an above market interim contract will find their rents reduced to market prior to expiration of the interim contract; (4) Waivers will be requested only during the first week of every month through Norman Dailey, Multifamily Housing Field Liaison; and (5) Sample 10 Day Notice to Cure Letters are also attached.
  • Prospective Mark-to-Market owners may now evaluate how their properties might be effected by the Mark-to-Market program by using this Freeware evaluation MS Excel Tool. A sample of the Freeware Evaluation is also available. Any questions on the use of the software should be sent to Rick Harris via e-mail or at (202) 708-3856, ext. 3617.
  • Multifamily Housing is discontinuing attempts to close "consolidated restructuring plans." Memo dated January 23, 2003.
  • Multifamily Housing will not be offering additional incentives to owners of "out year" properties (properties whose HAP contracts have not yet expired). Research concluded that restructuring now is financially preferable to waiting until an out year contract expires for most owners. Memo dated January 22, 2003.
Helpful Tools
  • Owner and Purchaser Initiatives
  • Housing Cooperatives. Housing cooperatives include those properties held by a nonprofit cooperative ownership housing corporation or nonprofit cooperative housing trust. Housing cooperatives are eligible for restructuring through the M2M program. If processed through the M2M program, housing cooperatives must be renewed with project based assistance. Please see Recap's regulations and the Operating Procedures Guide (Chapter 3, Section 3-6-E) for details on other restructuring requirements unique to housing cooperatives.
Other Resources