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Applications for either FHA mortgage insurance or Mark up to Market contract renewal are subject to restrictions on choice-limiting actions as described at MAP Guide 9.2.1.C. Once a federal nexus for a project is established, rehabilitation activities that exceed maintenance must not occur until after the environmental review has been completed. HUD guidance in Notice CPD-16-02 and Housings Maintenance Fact Sheet allows tree trimming as maintenance but not tree removal.

After HUD has issued a firm commitment, certain activities must not occur until closing unless an early start is requested and granted. Questions on early starts are case-specific and should be referred to the regional program office. In most cases, removal of this tree on its own would not require an early start request. The combined action of a tree removal and the UST removal would likely require an early start request.

Greg Hunter Changed status to publish July 12, 2022
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