91-Day Flip Rule 2015

[Mike V.]

Hello everyone! I'm having some trouble understanding a few things. Let me start with this:

in HUD's Single Family Housing Policy Handbook updated in 2015 it says this: (Straight out of their pdf edition on the website)

(i) Time Restriction on Transfers of Title

The eligibility of a Property for a Mortgage insured by FHA is determined by the time that has elapsed between the date the seller has acquired title to the Property and the date of execution of the sales contract that will result in the FHA-insured Mortgage.

FHA defines the seller’s date of acquisition as the date the seller acquired legal ownership of that Property. FHA defines the resale date as the date of execution of the sales contract by all parties intending to finance the Property with an FHA-insured Mortgage.

(ii) Restriction on Resales Occurring 90 Days or Fewer After Acquisition

A Property that is being resold 90 Days or fewer following the seller's date of acquisition is not eligible for an FHA-insured Mortgage.

My question is this: When does the 91 days begin? From the time of Aquisition (Date of Settlement) or the time that it's recorded at the courthouse? Also, is it lender preference or do all lenders function the same way in regards to the understanding of this. 

They didn't really make it easy for any regular person to understand which is in line with how government does thing. It's a big deal though because for us it means that the 91st day starts on 9/8/15 or 9/30/15 which is a difference of 22 days. 22 days of interest is not something we really want to pay if we don't have to. It's late, so my plan to call a bunch of lenders will have to hold until tomorrow, but I thought I'd engage with my real estate investment community. If there are any lenders out there, I would love to here you 2 cents.

What is your experience? Thanks so much!