How to Fill Out the FHA Condo Spot Approval Form (HUD-9991)

The HUD 9991 form is the FHA Condominium Loan Level/Single-Unit Approval Questionnaire, and the mortgage lender completes and submits it through FHA Connection when a borrower applies for FHA-insured financing on a condo unit.¹ Most of the data comes from the homeowner association or its management company: occupancy figures, insurance declarations, budget and reserve numbers, delinquency rates, and any pending litigation. The lender assembles the package, certifies it, and takes on the responsibility for accuracy.

The current fillable PDF and a separate instructions document are on HUD’s forms page. Download both. The instructions walk field by field in the same order the form presents them and cite the matching sections of Handbook 4000.1.²

When You Need Form 9991

Two situations trigger the questionnaire. The first is full project approval, a comprehensive review that makes every unit in the development eligible for FHA financing. The second is single-unit approval, which backs one specific unit in a project that is not on HUD’s approved list.³ The single-unit path is common for smaller or newer buildings that never went through full approval.

For single-unit approval, the lender submits Form 9991 when requesting an FHA case number. The case sits in pending status until HUD reviews the questionnaire and either approves or rejects the unit.⁴ FHA-to-FHA streamline refinances and HUD Real Estate Owned cases are exempt from the requirement.

Documents to Collect Before You Start the Form

Lenders request these items from the HOA or management company. Having them in hand keeps the form from stalling halfway through.

The project’s legal name as it appears in the master deed or declaration, plus the FHA Condo ID Number if the project was previously submitted to HUD. If it has never been submitted, leave the ID field blank; HUD assigns one during processing.¹
Total unit count, broken out by owner-occupied and non-owner-occupied.
Current declarations for hazard, general liability, and fidelity (crime) insurance. FHA requires fidelity coverage equal to at least three months of aggregate assessments plus the total held in reserves.
A current balance sheet, income statement, and budget showing revenue, expenses, and reserve fund balances.
Delinquency records: how many owners are more than 60 days behind on assessments.
Details on any pending litigation involving the association, especially structural-defect suits or claims with significant financial exposure.

Filling Out the Form Section by Section

Section 2: Project Identification and Eligibility

Enter the legal name, address, and FHA Condo ID Number if one exists. The instructions require every field in this section to be completed.² You’ll also describe the project physically: construction type, number of buildings, and whether construction is complete. If it isn’t, report the percentage of units already conveyed or under contract.

Commercial space is reported here too. Federal regulations allow HUD to set the maximum non-residential portion anywhere between 25 and 55 percent of total floor area.⁵ The current cap is fixed by HUD notice and has historically been around 25 percent for standard approval, with higher thresholds available by waiver. Report actual square footage accurately. Underreporting is one of the quicker ways to get a rejection.

Section 3: Financial and Operational Data

This is where the preparation pays off. Enter the total unit count, then split it between owner-occupied and non-owner-occupied.¹ FHA sets owner-occupancy minimums that vary by project size; two-to-four-unit projects require 75 percent owner occupancy under Handbook 4000.1.⁶ Second homes count toward the owner-occupied figure. Investor-owned rentals do not.

The assessment delinquency field asks what percentage of units are more than 60 days past due on HOA fees. FHA guidelines generally cap this at 15 percent; exceed it and the project will likely be rejected. A separate field covers FHA concentration, which limits how many units in the project can carry active FHA-insured mortgages. Projects with ten or more units are capped at 10 percent FHA-insured. Projects with fewer than ten units are limited to two FHA-insured units.⁷

Report the association’s annual budget and the amount allocated to replacement reserves. FHA expects at least 10 percent of the annual budget to go toward reserves for long-term capital items such as roof replacement, elevator maintenance, and repaving. Disclose any special assessments and explain what they paid for. A pattern of recent special assessments reads as financial instability unless the context is on the page.

Finally, disclose active litigation. Structural-defect suits and claims that exceed insurance coverage can disqualify a project. Minor matters like a collections action against a delinquent owner generally don’t sink an application, but they still have to be reported.

Submitting the Form

The lender, not the HOA or the borrower, submits Form 9991 through FHA Connection. For single-unit approvals it goes in as part of case number assignment.⁴ The lender certifies that the information is accurate and that the project meets FHA standards. That certification carries weight: federal law provides for fines up to $10,000 and possible imprisonment for knowingly making false statements on this type of form, under 18 U.S.C. § 1001 and § 1010.⁸ Lenders also face civil money penalties under HUD’s enforcement regulations.⁹

Along with the completed questionnaire, upload the supporting documents: insurance declarations, financial statements, and any litigation disclosures. For single-unit approvals, HUD publishes a required documentation checklist that spells out the minimum package.¹⁰

What Happens After You Submit

HUD’s Homeownership Center reviews the package. For full project approvals the stated processing target is 30 calendar days from receipt. Single-unit approvals submitted during case number assignment hold the case in pending status until HUD finishes its review.⁴ Timelines stretch during high-volume periods.

You can track a project through HUD’s public condominium lookup tool.¹¹ The database shows one of four statuses: Approved, Expired, Rejected, or Withdrawn. If the status is Approved, any unit is eligible for FHA financing for the duration of the approval period. If it’s Rejected, the lender receives a notice identifying the specific deficiencies, and can resubmit once the HOA addresses them. Full project approvals last two years, and recertification can begin as early as six months before expiration.

Common Reasons the Questionnaire Gets Rejected

Most rejections come back to the same handful of thresholds. Checking each one against the form before you upload saves a round trip through the 30-day review cycle.

Owner-occupancy too low. If too many units are investor rentals, the project fails the occupancy threshold. This is the most common stumbling block and depends on actual ownership patterns.
Assessment delinquencies above 15 percent of units more than 60 days past due.
Replacement reserves funded at less than 10 percent of the annual budget.
Missing fidelity coverage, lapsed hazard policies, or limits below FHA minimums. Fidelity must cover at least three months of aggregate assessments plus reserves.
FHA concentration already at the cap, meaning no additional FHA-insured loans can be added until existing ones pay off or refinance into conventional financing.⁷
Litigation alleging structural defects, or claims that exceed the association’s insurance coverage.

Some deficiencies clear in days, like a lapsed insurance policy that just needs renewal. Others, like an owner-occupancy ratio, depend on facts about the building that take months to change. Running the form against the known thresholds before submission is the shortest path to an approval.

1
U.S. Department of Housing and Urban Development. HUD Form 9991 – FHA Condominium Loan Level/Single-Unit Approval Questionnaire
2
U.S. Department of Housing and Urban Development. HUD Form 9991 – FHA Condominium Loan Level/Single-Unit Approval Questionnaire Instructions
3
U.S. Department of Housing and Urban Development. FHA Condominiums
4
U.S. Department of Housing and Urban Development. Case Number Assignment – Processing – FHA Connection
5
Federal Register. Project Approval for Single-Family Condominiums
6
U.S. Department of Housing and Urban Development. Handbook 4000.1 – FHA Single Family Housing Policy Handbook
7
U.S. Department of Housing and Urban Development. FHA Connection Single Family Origination – Condominiums Help
8
U.S. Department of Housing and Urban Development. HUD Form 92900-B – Don’t Commit Loan Fraud
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eCFR. 24 CFR Part 30 – Civil Money Penalties: Certain Prohibited Conduct
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U.S. Department of Housing and Urban Development. FHA Single-Unit Approval Required Documentation List
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U.S. Department of Housing and Urban Development. Condominiums – HUD