Will quitclaim deed from personal names to LLC trigger FHA flip rules?

[Melanie Serrato]

Hello,

My husband and I operate an LLC from which we buy and sell (flip) properties. We've also purchased a few properties that were burned, torn them down and built new. This describes our latest project, a house that has been built new from the ground up. The "lot" was purchased in our LLC, but we considered keeping the house for ourselves, so transferred to our personal names to make a refi easier once construction was completed.

Now, we have decided to sell, and need to transfer title back to LLC for the resale, but we're concerned about triggering FHA's flip rules - is that likely? Property was purchased in May 2013, so we've owned it about 9 months. We purchased from a company that bought at trustee sale, so there have technically been 3 transfers in the last year, 4 if we transfer back to LLC, but the last transfer would not be to a new entity, just back to our company that purchased initially. Beyond the general flip rules, we're concerned about them perceiving a "pattern of flipping activity". The transfers seem reasonable to me, but do we get an opportunity to explain the transfers, or do they just shut us down? Does the fact that this is new construction, with permits and documentation of the work done, make any difference?

Thanks in advance for any help.

Mel