In cost-controlled mortgages for FHA New Construction and Substantial Rehabilitation Programs BSPRA is allowed. BSPRA is a mortgageable cost but not a source of cash. For affordable programs (such as Low-Income Housing Tax Credits, Rental Assistance Demonstration (RAD), and Section 202 refinancing), a Developer Fee may be mortgageable as long as BSPRA or SPRA is not also included. In no event may a non-mortgageable Developer Fee be included as part of a market rate transaction, with or without BSPRA