HUD 223f loan - Accessibility Requirements

[Charles Pope]

I am considering using a HUD 223f loan to refinance a 100 unit conventional apartment complex. As part of the closing process, a PCNA (Property Condition and Needs Assessment) will be performed to determine what repairs the property requires. Repairs to correct noncompliance to accessibility laws must be completed prior to closing.

The property is a conventional/market rate project built in 1979. It currently has no handicap units, no Fair Housing units, no handicap parking spaces, and the leasing office is not ADA compliant with respect entry, bathrooms, sidewalk and parking.

My question is... what level of accessibility will HUD require for the project?  Will accessibility repairs be restricted to bringing the leasing office up to ADA compliance or will it include the common areas or even the units as well?