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Credit Exception: When the Numbers Don't Work

How to request—and get approved for—deviations from Freddie Mac's standard underwriting criteria.

Definition

Credit Exception: Formal approval from Freddie Mac to proceed with a loan that doesn't meet one or more standard Guide requirements, granted based on compensating factors and documented justification.

Your deal is 90% there. The property is strong, the borrower is solid, the market is good—but the DSCR comes in at 1.18x instead of the required 1.20x. Do you walk away from an otherwise fundable deal? Not necessarily. This is where credit exceptions come in.

What Triggers the Need for a Credit Exception?

Exceptions are required when a deal deviates from published Freddie Mac Guide requirements:

Exception CategoryExample DeviationApproval Difficulty
DSCR1.18x vs. 1.20x minimumModerate (if marginal)
LTV77% vs. 75% market tier limitModerate
Credit EventsBankruptcy 5 years ago (vs. 7-year lookback)Difficult
Property TypeStudent housing concentrationVery Difficult
MarketDeclining market with negative trendsVery Difficult
Borrower ExperienceFirst-time multifamily ownerModerate
Key Point
Not all exceptions are created equal. A marginal DSCR shortfall with strong compensating factors is very different from a recent bankruptcy with weak financials. Know which battles to fight.

The Credit Exception Request Format

Your lender prepares the exception request, but you provide the ammunition. A strong request includes:

1. Clear Statement of the Deviation

What specific Guide requirement isn't met, and by how much?

Weak: "DSCR is below minimum."

Strong: "DSCR of 1.18x is 2 basis points below the 1.20x minimum for Standard Markets. At the requested loan amount of $4,200,000, the DSCR shortfall equates to approximately $8,400 in annual debt service coverage."

2. Root Cause Explanation

Why does the deviation exist? Is it temporary or structural?

Weak: "Rents are below market."

Strong: "Current rents average $1,050/unit versus market rents of $1,175/unit. The property was acquired 18 months ago with significant deferred maintenance. Borrower has completed $450,000 in capital improvements and is executing a rent increase program. Average rent has increased $75/unit in the past 6 months with no increase in vacancy."

3. Compensating Factors

What strengths offset the weakness? Be specific and quantify:

Compensating FactorWeak PresentationStrong Presentation
Borrower Liquidity"Borrower has strong liquidity""Post-closing liquidity of $2.4M (18 months debt service) vs. 9-month minimum"
Net Worth"Substantial net worth""Net worth of $8.2M (195% of loan amount) vs. 100% minimum"
Track Record"Experienced operator""12-year ownership history with 0 defaults across 847 units in 6 properties"
Property Quality"Well-maintained property""PCA identified $45,000 immediate repairs on a $6.2M asset (0.7% of value)"

4. Mitigating Structures

What deal terms reduce risk?

  • Lower leverage: "Requesting 72% LTV despite 75% eligibility"
  • Additional reserves: "Borrower agrees to 18-month operating reserve"
  • Recourse carveouts: "Expanded recourse provisions for first 24 months"
  • Interest rate buydown: "Accepting 15 bps rate premium"

Common Exception Types and Strategies

DSCR Exceptions

The most common exception request. Strategies that work:

  • Rent growth narrative: Document below-market rents with clear path to market
  • Expense reduction: Show specific expense savings from operational improvements
  • Conservative underwriting offset: If lender underwrote aggressively on vacancy or expenses, show actuals
  • Liquidity cushion: Significant post-closing liquidity (12+ months debt service)
Warning
Don't request DSCR exceptions on properties with structural income problems (declining market, obsolete product, tenant concentration). Freddie Mac distinguishes between "numbers that will improve" and "numbers that are what they are."

LTV Exceptions

Less common because LTV limits are firm. When they work:

  • Appraisal timing: Value has increased since appraisal due to documented improvements
  • Conservative cap rate: Appraiser used higher cap rate than comps support
  • Recent comparable sales: Market has moved since appraisal

Credit Event Exceptions

Borrowers with historical credit events face the borrower interview and often need exceptions:

Credit EventStandard LookbackException Considerations
Bankruptcy7 yearsBusiness vs. personal, cause, recovery demonstrated
Foreclosure7 yearsStrategic vs. distress, different asset class, market conditions
Deed-in-Lieu7 yearsNegotiated resolution vs. default, lender relationship
Loan Modification3 yearsTemporary hardship, current performance

For credit events, the narrative is everything. A bankruptcy caused by a business partner's fraud, followed by 5 years of clean credit and successful operations, tells a different story than serial financial mismanagement.

The Exception Approval Process

Step 1: Lender Pre-Screen

Your lender evaluates whether the exception is worth requesting. They won't waste Freddie Mac's time (and their relationship capital) on long-shot requests.

Step 2: Exception Memo Preparation

The lender's underwriter prepares a formal Credit Exception Memo including:

  • Deal summary and exception requested
  • Detailed compensating factors
  • Risk analysis and mitigants
  • Lender recommendation

Step 3: Freddie Mac Credit Committee Review

The exception goes to Freddie Mac's credit team. Timeline varies:

  • Minor exceptions: 3-5 business days
  • Significant exceptions: 5-10 business days
  • Complex/multiple exceptions: 10-15 business days

Step 4: Decision

Three possible outcomes:

  • Approved: Exception granted, proceed with loan
  • Approved with conditions: Exception granted if specific mitigants implemented
  • Declined: Exception denied, restructure deal or find alternative financing

Building Relationships for Future Exceptions

Exception success isn't just about the individual deal—it's about track record:

What Helps

  • Performing loan history: Your previous Freddie Mac loans paying as agreed
  • Clean exception track record: Past exceptions that performed well
  • Lender relationship: Working with a Seller/Servicer that has strong Freddie Mac standing
  • Transparency: Full disclosure of issues, no surprises

What Hurts

  • Repeated exception requests: Pattern of deals that don't meet criteria
  • Exceptions that defaulted: Previous exceptions that went bad
  • Incomplete disclosure: Issues discovered that weren't disclosed upfront
  • Adversarial approach: Fighting the underwriter instead of working together
Key Point
Your reputation follows you. Borrowers known for quality deals that perform get more benefit of the doubt than borrowers known for pushing boundaries on every transaction.

When NOT to Request an Exception

Some deals shouldn't be fought for:

  • Fundamental property problems: Declining market, obsolete product, environmental issues
  • Multiple major exceptions: Needing exceptions on DSCR, LTV, AND credit events
  • Recent/severe credit events: Bankruptcy in past 3 years, active litigation
  • Structural issues: Problems that won't improve (bad location, shrinking tenant base)
  • Weak compensating factors: Nothing to offset the deviation

Know when to pivot to alternative financing (bridge loans, bank debt, private lenders) rather than forcing a square peg into a round hole.

Insider Terminology

Credit Exception Memo
Formal document prepared by the lender requesting deviation from Guide requirements. Includes deal summary, exception requested, compensating factors, and lender recommendation.
Compensating Factors
Strengths that offset weaknesses in the deal. Strong borrower liquidity, excellent property condition, below-market leverage, and experienced management are common examples.
Variance
The degree of deviation from standard requirements. A 2% DSCR variance is more approvable than a 15% variance.
Guide Waiver
Another term for credit exception. Formal approval to waive specific Guide requirements for a particular transaction.
Underwriter Discretion
Limited flexibility underwriters have within Guide parameters. Some minor items don't require formal exceptions; others have no discretion.

Key Takeaways

Bottom Line
  • Exceptions exist for good deals with minor issues: Not for fundamentally broken deals
  • Compensating factors are everything: Quantify strengths that offset the deviation
  • Narrative matters: Especially for credit events—tell the story clearly
  • Track record builds credibility: Past performance influences future exceptions
  • Know when to walk away: Some deals aren't worth the exception fight

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