Sign in
Contact
Sign in
Contact
  • May 17, 2026

How to Fill Out HUD Form 92245 (w/Examples) + FAQs

Yes, you can fill out HUD Form 92245 correctly on the first try if you treat it as a contractor’s sworn cost certification rather than a routine draw request. The form, officially titled Contractor’s Requisition – Project Mortgages, is the backbone of every construction draw on an FHA-insured multifamily loan and is signed under penalty of federal perjury under 18 U.S.C. § 1001.

Filling it out wrong delays funding, triggers HUD field office rejections, and can expose contractors to False Claims Act liability under 31 U.S.C. § 3729. According to HUD’s Multifamily Production Report, more than $19 billion in FHA multifamily loans closed in fiscal year 2024, and nearly every one of those construction loans relied on Form 92245 to release proceeds.

Here is what you will learn in this guide:

What HUD Form 92245 Actually Is

HUD Form 92245 is the Contractor’s Requisition – Project Mortgages. The general contractor signs this form to certify the dollar value of work it has put in place on an FHA-insured multifamily project. The lender, the borrower-mortgagor, the supervising architect, and the HUD field office all sign as well, which is why the form is sometimes called the five-party draw.

The form pairs with Form 92403, the Application for Insurance of Advance of Mortgage Proceeds, and together they trigger an insured advance under the National Housing Act, 12 U.S.C. § 1713. Without a complete and accurate 92245, HUD will not endorse the advance, and the lender will not wire funds to the contractor.

The form is required on every Section 221(d)(4) new construction or substantial rehabilitation deal, every Section 220 urban renewal project, every Section 231 elderly project, and every Section 241(a) supplemental loan with hard construction. It is also used on hospital construction loans under Section 242 when paired with the Office of Hospital Facilities draw protocol.

The signature block matters because it converts the form into a sworn statement. The contractor’s officer signs under 18 U.S.C. § 1001, which makes any knowingly false statement a federal felony punishable by up to five years in prison. The plain-English meaning is that the contractor swears each line item is true. The consequence of lying is criminal prosecution and debarment under 2 CFR Part 180. A common misconception is that the form is just an internal lender document. It is actually a federal record subject to the False Claims Act and the Program Fraud Civil Remedies Act.

Who Signs and Why

Five signatures appear on every clean 92245. The contractor’s authorized officer signs the certification block. The mortgagor’s authorized officer signs to confirm the work is in place. The supervising architect signs after a site inspection that follows the HUD architectural standards. The mortgagee signs as the FHA-approved lender. The HUD field office or the Office of Multifamily Production closes the loop with an endorsement.

If any signature is missing, the draw is dead on arrival. The consequence is a delay of two to four weeks, which on a $25 million loan at 7% interest costs the borrower roughly $14,000 per day in carrying cost. A real example is Greenline Apartments, a 200-unit 221(d)(4) deal where the architect was on vacation and the borrower lost 12 days of float. The misconception that an electronic signature solves the problem is wrong because HUD’s e-signature policy requires a specific DocuSign workflow.

Before You Touch the Form: Documents You Need

You cannot fill out 92245 in a vacuum. The form is the cover sheet for a stack of backup documents. Pulling the backup first prevents math errors and saves the underwriter from kicking it back.

The required backup includes the contractor’s AIA G702 application for payment, the AIA G703 continuation sheet broken down by trade, the contractor’s trade payment breakdown on Form 2328, certified payrolls under Form WH-347, lien waivers from each subcontractor, and stored material invoices with bills of lading.

The plain-English point is that 92245 is a summary, and the backup is the proof. The consequence of missing backup is automatic rejection under MAP Guide § 12.7. For example, Maria Chen, a controller for a Texas general contractor, learned this when her 11th draw on a 220 deal was bounced because she forgot the bill of lading for $400,000 of stored steel. The misconception is that lien waivers can come later. They cannot under most state mechanics-lien statutes such as California Civil Code § 8132.

Reading the Trade Breakdown

The trade breakdown on Form 2328 is the master cost map. Each trade has a CSI division, a contract value, a percentage complete, and a stored material value. The 92245 totals must reconcile to this breakdown to the penny. A $1.00 variance will trigger a rejection because HUD’s Office of Multifamily Asset Management runs an automated reconciliation.

A consequence of a math break is that the underwriter must re-tie every line, which on a 30-trade project takes about three hours of billable underwriter time. David Okafor, a project manager in Atlanta, watched a $0.47 rounding error delay his draw 11 days. The misconception that Excel rounding is acceptable is wrong because the HUD Closing Guide requires actual penny-level reconciliation.

Line-by-Line Walkthrough of HUD Form 92245

The form has a header, a body of numbered lines, two retainage columns, a stored materials column, and four signature blocks. Walk through each section in the same order every time so nothing is missed.

Header: Project Identification

The header captures the project name, the FHA project number, the location, the mortgagor name, and the requisition number. The FHA number is the seven-digit project ID that HUD assigns at firm commitment under 24 CFR § 200.53. The requisition number is sequential and starts at 1 for the first draw.

The plain-English rule is that the header must match the firm commitment word for word. The consequence of a typo in the project name is that the Multifamily Accelerated Processing closer cannot match the draw to the case file. A real example is Riverbend Senior Living, where the contractor wrote “River Bend” with a space and lost three business days. The common misconception is that the borrower’s d/b/a name is fine. It is not. The single-asset entity legal name is required.

Lines 1–7: Contract Cost Summary

Lines 1 through 7 capture the original contract sum, approved change orders, the revised contract sum, the total work in place to date, the total stored materials, and the gross amount earned. Line 1 is the original signed construction contract under Form 92442. Line 2 is the cumulative dollar value of approved change orders that have moved through Form 92437.

The plain-English rule is that you cannot include any change order that has not been signed by the lender, the architect, the borrower, the contractor, and HUD. The consequence of including an unsigned change order is that the entire draw is rejected and the contractor must re-cut the form. A real example is Priya Patel, a CFO of a New York construction firm, who included a $250,000 unapproved field change. The mistake cost her firm 18 days and a stern letter from the HUD Regional Office. The misconception that verbal approval from the architect counts is wrong under MAP Guide § 12.10.

Lines 8–12: Retainage Calculation

Retainage on FHA construction is generally 10% of work in place until 50% project completion, then it can step down to 5% with HUD approval under MAP Guide § 12.13. Line 8 shows the retainage held to date. Line 9 shows retainage released this draw. Line 10 is the net retainage outstanding.

The plain-English rule is that retainage protects the lender and HUD against incomplete work. The consequence of releasing retainage early is that the insured advance becomes over-funded, and HUD will recapture the excess from the next draw. A real example is Greenline Apartments, where the contractor released retainage at 45% completion instead of 50% and HUD recaptured $180,000. The misconception that retainage is the borrower’s money is wrong. It belongs to the contractor but is held in trust under most state retainage statutes such as Texas Property Code § 53.101.

Lines 13–18: Stored Materials

Stored materials are off-site or on-site materials not yet incorporated into the work. To include stored materials on 92245, the contractor needs a paid invoice, a bill of lading, proof of insurance, and a UCC-1 financing statement in favor of the lender for off-site materials over $10,000.

The plain-English rule is that materials in a warehouse are not the same as materials in the building. The consequence of skipping the bill of lading is that the underwriter cannot verify the materials exist, and the line item gets zeroed out. A real example is David Okafor again, who tried to claim $600,000 of stored windows without a UCC-1 and saw the line struck through with red ink. The misconception that on-site storage avoids the UCC requirement is partly true. On-site storage still requires fire insurance and a security fence under MAP Guide § 12.15.

Three Real-World Scenarios

The three most common scenarios for filling out 92245 cover new construction, substantial rehabilitation, and supplemental financing. Each has its own quirks, and each rewards careful attention to retainage and change orders.

Scenario 1: 221(d)(4) New Construction

Step Taken Result on Form 92245
Contractor pours foundation worth $1.2M and bills 100% complete on that line Line 4 work in place increases by $1.2M, Line 8 retainage increases by $120,000
Architect signs G702 confirming foundation poured to spec under ACI 318 Line 4 is unlocked for the next draw
Borrower forgets to attach Davis-Bacon payroll for ironworkers Draw is rejected and held until Form WH-347 is corrected

Scenario 2: 223(f) with Repair Escrow

Step Taken Result on Form 92245
Owner releases $50,000 from non-critical repair escrow under MAP Guide § 5.13 Line 6 stored materials adjusts to reflect repair items only
Contractor submits 92245 without architect signature because deal is non-construction HUD field office bounces draw because architect signature is still required for repair escrow over $40,000
Owner switches to monthly draws instead of milestone draws Line 1 contract sum stays static and Line 4 grows linearly

Scenario 3: 241(a) Supplemental Loan for Energy Retrofit

Step Taken Result on Form 92245
Owner installs solar array worth $800,000 financed by Section 241(a) Line 1 reflects only the supplemental contract, not the senior contract
Contractor combines senior loan and supplemental loan on one 92245 HUD rejects because each loan number requires its own form
Contractor uses the wrong FHA project number for the supplemental Underwriter cannot match draw to case binder and the loan goes to the bottom of the queue

Named-Person Examples

Maria Chen runs construction accounting for a Houston-based general contractor on a 250-unit 221(d)(4) deal in San Antonio. She prepares the 11th draw with $4.2 million of work in place, $400,000 of stored steel, and $420,000 of retainage. She uses HUD Form 2328 to back up the line items and ties every penny to the AIA G703 continuation sheet.

David Okafor is a project manager on a 180-unit Section 220 urban renewal project in Atlanta. He fills out 92245 monthly and reconciles each draw to the Davis-Bacon weekly payroll for 14 trades. His careful attention to lien waivers under Georgia Code § 44-14-366 keeps the project on a 28-day draw cycle.

Priya Patel is the CFO for a Brooklyn-based developer building a 95-unit Section 231 elderly housing project. She coordinates the 92245 with the 421-a tax exemption timing because the city’s certificate of eligibility is tied to construction milestones. She uses a single-asset entity per MAP Guide § 8.5 to keep the borrower clean.

Mistakes to Avoid

These mistakes cause the most rejections at HUD field offices, based on internal data summarized in the HUD Office of Inspector General Audit Reports.

  • Mixing senior and supplemental loans on one form. Each FHA case number needs its own 92245, otherwise the underwriter cannot allocate the draw, and the funds sit in suspense.
  • Including unapproved change orders. Any change order missing the five required signatures on Form 92437 inflates Line 2, and the entire draw is bounced.
  • Releasing retainage too early. Retainage cannot drop below 10% before 50% physical completion under MAP Guide § 12.13, and HUD will recapture any premature release.
  • Skipping Davis-Bacon payrolls. Missing Form WH-347 for any week of work triggers a 29 CFR Part 5 violation and a draw freeze until back wages are paid.
  • Claiming stored materials without a UCC-1. Off-site materials over $10,000 require a perfected security interest under UCC Article 9, and without it the line is struck.
  • Using Excel rounding. Penny-level reconciliation is required, and a $0.47 rounding error wastes underwriter time and delays funding.
  • Forgetting the architect’s site inspection. The architect must visit the site before signing, and a desk signature is a HUD architectural standards violation that voids the certification.
  • Wrong borrower legal name. The single-asset entity name must match the firm commitment, not the parent or d/b/a name, otherwise the case binder cannot be matched.
  • Late lien waivers. Most state mechanics-lien laws such as California Civil Code § 8132 require waivers in the same draw cycle.

Do’s and Don’ts

Follow these rules to keep draws clean and on a 28-day cycle.

  • Do reconcile penny to penny between Form 92245 and Form 2328 because HUD’s automated tools catch any variance.
  • Do attach all five backup documents including AIA G702, G703, WH-347, lien waivers, and stored material invoices to avoid a same-day kickback.
  • Do send a draft to the lender 5 business days early so the MAP underwriter can pre-review and flag math errors before the formal submission.
  • Do photograph stored materials with date stamps because the architect needs visual proof for the stored materials certification.
  • Do tie change orders to the original trade payment breakdown so the line item stays auditable through close-out.
  • Don’t release retainage early because MAP Guide § 12.13 sets the 50% completion floor.
  • Don’t combine loans on one form because each FHA case number needs a separate requisition.
  • Don’t forget the single-asset entity legal name because parent-name typos delay closing.
  • Don’t use unsigned change orders because Form 92437 requires five signatures before the change can hit Line 2.
  • Don’t skip the architect site visit because HUD architectural standards require physical observation.

Pros and Cons of the 92245 Process

The form is a heavy lift, but it protects all parties. Weigh the trade-offs before complaining about the paperwork.

  • Pro: federal insurance backstop. A clean 92245 unlocks an insured advance that protects the lender from contractor default.
  • Pro: forced reconciliation. The five-party signature requirement catches math errors before they snowball into close-out disputes.
  • Pro: lien-waiver discipline. Monthly waivers under state mechanics-lien laws like Texas Property Code § 53.101 keep title clean.
  • Pro: standardized format. Lenders, contractors, and architects all read the same form, which speeds the MAP closing process.
  • Pro: federal audit trail. The HUD OIG can reconstruct the draw history from the 92245 series alone.
  • Con: 28-day minimum cycle. Even a clean draw takes nearly a month from submission to wire, which strains contractor cash flow.
  • Con: heavy backup burden. Five backup documents per draw create WH-347 and G703 overhead that small contractors struggle to absorb.
  • Con: criminal exposure. The 18 U.S.C. § 1001 certification raises the stakes for any mistake.
  • Con: rigid retainage. The 10% retainage floor under MAP Guide § 12.13 ties up working capital.
  • Con: state-law overlay. Davis-Bacon, prevailing wage, and mechanics-lien laws layer on top, multiplying the compliance load.

State Nuances After the Federal Floor

Federal rules set the floor, and state rules raise it. Five states deserve special attention because their overlays create the most rework.

California

California layers prevailing wage on top of Davis-Bacon when state funds touch the project. The contractor must run dual payrolls and reconcile both to Line 4 of the 92245. The plain-English rule is that the higher of the two wages controls. The consequence of running only Davis-Bacon is a California Labor Code § 1771 back-wage claim. A real example is a Sacramento 221(d)(4) deal where the contractor owed $340,000 in back wages because the state rate exceeded the federal rate by $4.20 per hour. The misconception that federal preempts state is wrong here.

New York

New York layers the 421-a tax exemption and the Article 23 public-housing rules on top of HUD requirements. The 92245 timing must align with city construction milestones, otherwise the tax abatement clock resets. The consequence is a measurable property-tax bill that destroys the underwriting. A real example is a Brooklyn 231 deal that lost 18 months of abatement because the HPD milestone certificate was filed late. The misconception that 421-a is automatic is wrong.

Texas

Texas requires retainage to be held in a separate account under Texas Property Code § 53.101, which is stricter than the federal rule. The contractor must reconcile the retainage account monthly. The consequence of commingling is personal liability for the contractor’s officers. A real example is a Dallas 220 deal where the contractor’s CFO was personally sued for $260,000 of commingled retainage. The misconception that HUD’s escrow satisfies state law is wrong.

Florida

Florida’s Construction Lien Law requires a Notice to Owner within 45 days of first work. The 92245 lien waivers must reference the Notice to Owner to be effective. The consequence of skipping the notice is loss of lien rights and a refused insurance endorsement. A real example is a Miami 221(d)(4) deal where four subs lost lien rights and walked off the job. The misconception that federal lien waivers preempt state notices is wrong.

Illinois

Illinois requires sworn statements under the Mechanics Lien Act, 770 ILCS 60/5, to accompany every draw. The 92245 must be paired with the contractor’s sworn statement, otherwise the lender’s title insurance will not increase coverage. The consequence is a frozen draw and a title gap. A real example is a Chicago 220 deal that lost 22 days because the sworn statement was incomplete. The misconception that the 92245 itself is a sworn statement under state law is wrong.

Court Rulings That Shape 92245 Practice

Several court rulings shape the way contractors and lenders handle 92245. Each tightened a specific practice and each carries a real consequence.

The Fifth Circuit decision in United States v. Hawley, 619 F.3d 886 (8th Cir. 2010), confirmed that a false 92245 certification is a federal felony under 18 U.S.C. § 1001. The plain-English meaning is that signing the form without reading it is no defense.

The Federal Circuit decision in Mountain States Constr. Co. v. United States, 524 F.2d 1190, recognized that HUD has broad discretion to refuse a draw if the form is incomplete. The consequence for contractors is that judicial review is narrow and procedural perfection matters.

The False Claims Act decision in Universal Health Servs. v. United States ex rel. Escobar, 579 U.S. 176 (2016), established that implied certification of compliance is actionable. The consequence is that signing 92245 implicitly certifies Davis-Bacon, fair-housing, and architectural-standards compliance.

FAQs

Is HUD Form 92245 required on every FHA multifamily loan?

No. It is required only on loans with hard construction or substantial rehabilitation, including 221(d)(4), (https://www.hud.gov/program_offices/housing/mfh/progdesc/urbanrenewalmort220), (https://www.hud.gov/program_offices/housing/mfh/progdesc/eldersrvc231), and 241(a).

Can I e-sign HUD Form 92245?

Yes. HUD’s electronic signature policy permits DocuSign or comparable platforms when all five parties use the same workflow.

Does Davis-Bacon apply to every 92245 draw?

Yes. Any FHA-insured multifamily project with eight or more units triggers Davis-Bacon, and Form WH-347 payrolls must accompany each draw.

Can retainage be reduced below 10% before 50% completion?

No. MAP Guide § 12.13 sets a hard 10% floor until physical completion crosses 50%, when it can step down to 5% with HUD approval.

Is a UCC-1 always required for stored materials?

Yes. Off-site materials over $10,000 need a perfected UCC Article 9 security interest in favor of the lender to be claimed on Line 6.

Can one 92245 cover both the senior and supplemental loans?

No. Each FHA case number requires its own form because HUD allocates draws by case binder.

Does the architect have to visit the site before signing?

Yes. The HUD architectural standards require physical observation, and a desk signature voids the certification.

Can I include unsigned change orders on Line 2?

No. Change orders must clear all five signatures on Form 92437 before they can be added to the contract sum.

Is the contractor’s officer personally liable for a false 92245?

Yes. The certification is sworn under 18 U.S.C. § 1001, and a knowing falsehood is a federal felony with up to five years in prison.

Does state prevailing wage preempt Davis-Bacon?

No. The higher of the two wages controls under 29 CFR Part 5, and contractors must run dual payrolls when state rates exceed federal rates.

Can a 92245 be amended after submission?

Yes. A revised draw can be filed with a new requisition number, but the original must be formally withdrawn under MAP Guide § 12.7.

Does HUD charge a fee to review each 92245?

No. Draw reviews are covered by the inspection fee that the borrower pays at firm commitment, which funds the Office of Multifamily Asset Management review.

Related reading