Predictika · Commercial real estate finance

An AI sales agent's Greystone loan structure, checked before it goes out

An AI sales agent structures a commercial real estate loan using Greystone programs: FHA/HUD Section 223(f), 221(d)(4), 232/223(f) and 232 loans, the Fannie Mae Fixed Rate and Freddie Mac Conventional Fixed-Rate loans, and the Multifamily and Healthcare Bridge Loans, with the loan amount, term, amortization, fees and escrow due at closing. Before the structure goes out, the agent sends it to Predictika, which checks it against a declarative model of the program terms Greystone publishes and returns a verdict, every reason, a fee schedule and the figures it computed.

Scope: Greystone loan structures: FHA/HUD 223(f), 221(d)(4), 232/223(f) and 232, Fannie Mae Fixed Rate, Freddie Mac Conventional Fixed-Rate, and the Multifamily and Healthcare Bridge Loans, for any property and loan size. See everything this validator covers

This validator models the structure of a Greystone loan as described in the public Greystone term sheets, not just the scenarios shown below. Where a rule is a published Greystone term it says so; the annual debt service constant, some bridge fees, thresholds and the approvals are labelled as invented.

  • FHA/HUD loans — Section 223(f) (acquisition and refinancing of multifamily, loans up to and above $130 million), Section 221(d)(4) (multifamily construction and substantial rehabilitation), Section 232/223(f) (acquisition and refinancing of licensed nursing homes and assisted living) and Section 232 (healthcare construction and substantial rehabilitation).
  • Agency and bridge loans — the Fannie Mae Fixed Rate loan, the Freddie Mac Conventional Fixed-Rate loan, the Multifamily Bridge Loan ($7.5 to $75 million) and the Healthcare Bridge Loan ($5 to $75 million).
  • Sizing — the largest loan is the least of the loan-to-value, loan-to-cost and debt service coverage limits, which differ by program, property type (market rate, affordable, subsidized, manufactured housing, assisted living, skilled nursing, independent living), borrower type, purpose and loan size.
  • Eligibility and structure — property and purpose per program, single-asset borrower, term and amortization, commercial space limits, 20-bed, license, Special Focus Facility and certificate of occupancy tests for 232/223(f), Davis-Bacon wages, rehabilitation scope tests, working capital escrow, the interest rate cap on bridge loans.
  • Fees due at closing — HUD application fee, upfront FHA mortgage insurance premium, HUD inspection fee, lender application fee, Freddie Mac application fee, bridge commitment fee and working capital escrow, with the stated cash due at closing checked against the total.
  • Approvals — a loan at $130 million or more under 223(f) or 221(d)(4), a coverage cushion under 5 percent, a Freddie Mac loan outside $7.5 to $100 million or a term over 10 years, a bridge loan above $75 million, cash equity under 15 percent and an interest reserve on a healthcare bridge go to a person.

Any Greystone loan structure that touches these programs and rules is in scope — not only the scenarios pictured here. Not covered: the other Greystone programs (223(a)(7), 241(a), Express Lane, interest rate reduction, Fannie Mae and Freddie Mac affordable, seniors, student housing and small loans, mezzanine, preferred equity, CMBS, tax-exempt bonds, Alt Capital), statutory per-unit limits, the Section 232 rehabilitation extra limit, prepayment terms and servicing. The borrowers are fictional.

The AI sales agentBuilds the loan structure from the conversation with the borrower and says it is ready.
Predictika validatorChecks every rule at once and returns the verdict, each finding, and the computed figures.

7 scenarios in 3 groups · each group runs from the agent’s first attempt to the outcome · click one to switch

What the agent proposes

The AI sales agent says

Illustrative agent statement. The validator receives the structured request below.

Proposing agent: AI sales agent (scripted)

Before sending, the agent must call Recorded run

Predictika validator


      
Waiting for the call.

Where rules-based CPQ gets it wrong

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Our assessment of what a typical rules-based CPQ (product rules, price rules and validation rules, as in Salesforce CPQ) does with the same cases. It is a judgment about effort and reliability, not a claim that nothing can be built.

What the validator caughtTypical rules-based CPQPredictika
Loan tiers that change at $130 millionOnly with workarounds
Under 223(f) and 221(d)(4) a market-rate loan is limited to 87 percent and 1.15 times coverage below $130 million and 75 percent and 1.30 times above it. A rules engine needs the tier test repeated in every limit, and a loan resized across the line changes four numbers at once.
The tier is computed once from the loan amount and every limit reads it.
A maximum loan that is the least of several limitsOnly with care
Loan-to-value, loan-to-cost and debt service coverage each give a ceiling, and each differs by program, property type, borrower type and purpose. Calculated fields can do it, but the set multiplies with every program.
The three ceilings and the largest loan are computed together and every finding names its own limit.
Eligibility tests that belong to one programOnly with workarounds
A 20-bed minimum, the Special Focus Facility list, a three-year-old certificate of occupancy and a license apply to 232/223(f); the same property under 221(d)(4) has other tests. Each is a field with a rule for one program.
Each test is checked against the program quoted, in the same pass as everything else.
Fees of different kinds that add up to cash at closingOnly with workarounds
A percent of the loan, a premium per year times the construction months, a greater-of fee, a size-tiered commitment fee and an escrow all land in one total that the agent also states.
Every fee is computed, listed as a line, and the total is compared with the figure the agent stated.
Rehabilitation scope testsOnly with care
A 221(d)(4) rehabilitation must cost more than 15,000 dollars per unit times a local cost factor, and a Section 232 rehabilitation more than 15 percent of value or more than half of two major systems. A rule can hold one number; the either-or test and the cost factor take more.
The scope tests are checked against the repairs and the cost factor given.
Every problem returned in one answerOnly with workarounds
Rules tend to fire as the structure is saved or a step is completed, so a person often fixes one error and meets the next.
All findings come back together, whatever order the choices arrived in.

What this validator catches: findings from its test cases

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Every rule is checked on every call, in any order the choices arrive; one problem never hides another. Blocking findings stop the loan structure; approval findings need a person to sign off; everything else is computed.

1A manufactured housing community under 223(f) is limited to governmental, nonprofit or cooperative borrowers and allows no cash-out.
2The loan of $33,000,000 is above $32,000,000, the 80 percent loan-to-value limit on a value of $40,000,000.
3The property type is not eligible for the selected program; the multifamily programs finance market rate, affordable and subsidized apartments (manufactured housing communities only under 223(f), Fannie Mae Fixed Rate and the Multifamily Bridge Loan), and the healthcare programs finance licensed assisted living and skilled nursing facilities (independent living only under the Healthcare Bridge Loan).
4The property has 4 units or pads; the Fannie Mae Fixed Rate loan needs at least 5 (5 units, or 50 pad sites for a manufactured housing community).
5The loan purpose is not available in the selected program; 223(f), Fannie Mae and Freddie Mac loans acquire or refinance (cash-out only there), 232/223(f) acquires or refinances, 221(d)(4) and Section 232 build or substantially rehabilitate, and bridge loans acquire, refinance or fund moderate rehabilitation.
6The borrower is an operating company; HUD, Fannie Mae and Freddie Mac loans need a single-asset, special-purpose borrowing entity.
7The loan of $33,100,000 is above $33,060,000, the 87 percent loan-to-cost limit on a cost of $38,000,000.
8The loan of $130,000,000 is in the $130 million and above tier, where HUD may impose stricter loan-to-value, loan-to-cost and coverage limits in a particular case, so a person should confirm.
9Net operating income of $9,900,000 covers the annual debt service of $7,800,000 only 1.26 times; the program minimum is 1.30 times.
10Net operating income of $2,277,000 is less than 5 percent above the $2,277,000 that the minimum coverage of 1.15 times requires on this debt service, so a person should confirm.
11The repairs cost $5,700,001; a 223(f) loan allows up to $5,700,000 (15,$0 per unit times the local cost factor).
12Commercial space is 26 percent of the area; the program allows 25 percent.
13Commercial income is 21 percent of effective gross income; the program allows 20 percent.
14The structure has a term of 421 months; the program term is between 1 and 420 months.
15The structure amortizes over 420 months; the HUD loan must fully amortize over 421 months.
16Davis-Bacon prevailing wages are not committed; 221(d)(4) and Section 232 construction and rehabilitation loans require them for all contractors and subcontractors.
17The structure has a term of 504 months; a construction loan runs the construction period of 0 months plus 40 years, 480 months in all.
18The construction period is 0 months; a construction loan needs a period of 1 to 36 months.
19The working capital escrow is $1,599,999; the loan needs at least $1,600,000 (2 percent of the loan).
20The renovation costs $8,000,000, not more than $8,550,000 (15,$0 per unit times the local cost factor); 221(d)(4) rehabilitation needs more, otherwise 223(f) fits.
21The facility has 19 beds; a Section 232/223(f) project needs at least 20.
22The facility is on the Special Focus Facility list or its candidate list, which Section 232/223(f) does not allow.
23The last certificate of occupancy is 2 years old; Section 232/223(f) needs at least 3 years to have passed.
24The facility is not state licensed; Section 232 financing needs a licensed nursing home, assisted living, intermediate care or board and care facility.
25The renovation costs $6,000,000, not more than 15 percent of the post-rehabilitation value of $50,000,000, and 1 major building systems are more than half replaced; Section 232 rehabilitation needs more than 15 percent of value or more than half of two or more major systems.
26The structure amortizes over 31 years; Fannie Mae and Freddie Mac fixed-rate loans amortize over 30 years at most.
27The loan of $7,499,999 is outside the usual $7.5 million to $100 million Freddie Mac range, which is considered case by case, so a person should confirm.
28The Freddie Mac fixed-rate loan has a term of 72 months; it is offered for 5, 7 or 10 years (up to 30 years only if the loan is not sold for securitization).
29The Freddie Mac term of 180 months is longer than 10 years, which is offered only if the loan is not sold for securitization, so a person should confirm.
30The loan of $7,499,999 is below the program minimum of $7,500,000.
31The bridge loan of $75,000,001 is above $75 million, which Greystone considers on request, so a person should confirm.
32The loan of $32,000,001 is above $32,000,000, 80 percent of the stabilized value of $40,000,000.
33The loan is 85 percent of cost, above the usual 85 percent; up to 90 percent is considered case by case, so a person should confirm.
34No interest rate cap is purchased; a bridge loan needs one for the full term from a counterparty rated A2/A or better.

Scenarios and results

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The recorded result of the validator for each scenario on this page: the request the AI agent sent, the verdict, and every finding, in the order they appear above.

1. Market-rate apartments, 221(d)(4): A $142 million FHA/HUD 221(d)(4) loan to build a 480-unit market-rate apartment community

The agent's request. Please structure an FHA/HUD Section 221(d)(4) loan of $142,000,000 to build a 480-unit market-rate apartment community. The borrower is a single-asset entity. The property has an eligible cost of $186,000,000, net operating income of $11,000,000 and an annual debt service constant of 6.05 percent. The construction period is 30 months. The term is 480 months, amortized over 40 years. Commercial space is 12 percent of the area and 18 percent of income. The working capital escrow is $1,500,000. The structure states cash due at closing of $1,313,500. It is ready to send.

Verdict: Blocked.

  • Loan above the loan-to-cost limit. The loan of $142,000,000 is above $139,500,000, the 75 percent loan-to-cost limit on a cost of $186,000,000.
  • Debt service coverage too low. Net operating income of $11,000,000 covers the annual debt service of $8,591,000 only 1.28 times; the program minimum is 1.30 times.
  • Term must include construction plus 40 years. The structure has a term of 480 months; a construction loan runs the construction period of 30 months plus 40 years, 510 months in all.
  • Commercial income above the limit. Commercial income is 18 percent of effective gross income; the program allows 15 percent.
  • Davis-Bacon prevailing wages not committed. Davis-Bacon prevailing wages are not committed; 221(d)(4) and Section 232 construction and rehabilitation loans require them for all contractors and subcontractors.
  • Working capital escrow too small. The working capital escrow is $1,500,000; the loan needs at least $2,840,000 (2 percent of the loan).
  • Stated cash due at closing does not match. The structure states cash due at closing of $1,313,500; the fee schedule gives $2,813,500.
  • HUD may tighten limits at $130 million and above. The loan of $142,000,000 is in the $130 million and above tier, where HUD may impose stricter loan-to-value, loan-to-cost and coverage limits in a particular case, so a person should confirm.

2. Market-rate apartments, 221(d)(4): The agent resubmits after fixing the errors

The agent's request. Please structure an FHA/HUD Section 221(d)(4) loan of $139,000,000 to build a 480-unit market-rate apartment community. The borrower is a single-asset entity. The property has an eligible cost of $186,000,000, net operating income of $11,000,000 and an annual debt service constant of 6.05 percent. The construction period is 30 months. The term is 510 months, amortized over 40 years. Commercial space is 12 percent of the area and 14 percent of income. The working capital escrow is $2,800,000. Davis-Bacon prevailing wages are committed. The structure states cash due at closing of $4,085,750. It is ready to send.

Verdict: Needs approval.

  • HUD may tighten limits at $130 million and above. The loan of $139,000,000 is in the $130 million and above tier, where HUD may impose stricter loan-to-value, loan-to-cost and coverage limits in a particular case, so a person should confirm.
  • Thin debt service coverage cushion. Net operating income of $11,000,000 is less than 5 percent above the $10,932,350 that the minimum coverage of 1.30 times requires on this debt service, so a person should confirm.
  • Structure summary. Cash due at closing of $4,085,750 on a loan of $139,000,000; the largest loan the limits allow is $139,500,000.

3. Market-rate apartments, 221(d)(4): The agent resubmits after fixing the errors

The agent's request. Please structure an FHA/HUD Section 221(d)(4) loan of $128,000,000 to build a 480-unit market-rate apartment community. The borrower is a single-asset entity. The property has an eligible cost of $186,000,000, net operating income of $11,000,000 and an annual debt service constant of 6.05 percent. The construction period is 30 months. The term is 510 months, amortized over 40 years. Commercial space is 12 percent of the area and 14 percent of income. The working capital escrow is $2,800,000. Davis-Bacon prevailing wages are committed. The structure states cash due at closing of $3,984,000. It is ready to send.

Verdict: Allowed.

  • Structure summary. Cash due at closing of $3,984,000 on a loan of $128,000,000; the largest loan the limits allow is $158,102,766.

4. Skilled nursing, 232/223(f): A Section 232/223(f) loan to refinance a 240-bed skilled nursing facility

The agent's request. Please structure an FHA/HUD Section 232/223(f) loan of $45,000,000 to refinance a 240-bed skilled nursing facility. The property has a value of $52,000,000, an eligible cost of $41,000,000, net operating income of $5,600,000 and an annual debt service constant of 7.00 percent. The term is 420 months, amortized over 35 years. The remaining economic life is 36 years. Repairs and renovation cost $300,000. Commercial space is 4 percent of the area and 3 percent of income. The facility has a certificate of occupancy 10 years old. The structure states cash due at closing of $142,200. It is ready to send.

Verdict: Blocked.

  • Borrower must be a single-asset entity. The borrower is an operating company; HUD, Fannie Mae and Freddie Mac loans need a single-asset, special-purpose borrowing entity.
  • Loan above the loan-to-value limit. The loan of $45,000,000 is above $41,600,000, the 80 percent loan-to-value limit on a value of $52,000,000.
  • Loan above the loan-to-cost limit. The loan of $45,000,000 is above $41,000,000, the 100 percent loan-to-cost limit on a cost of $41,000,000.
  • Term outside the program range. The structure has a term of 420 months; the program term is between 1 and 324 months.
  • Stated cash due at closing does not match. The structure states cash due at closing of $142,200; the fee schedule gives $592,200.

5. Skilled nursing, 232/223(f): The agent resubmits after fixing the errors

The agent's request. Please structure an FHA/HUD Section 232/223(f) loan of $41,000,000 to refinance a 240-bed skilled nursing facility. The borrower is a single-asset entity. The property has a value of $52,000,000, an eligible cost of $41,000,000, net operating income of $5,600,000 and an annual debt service constant of 7.00 percent. The term is 324 months, amortized over 27 years. The remaining economic life is 36 years. Repairs and renovation cost $300,000. Commercial space is 4 percent of the area and 3 percent of income. The facility has a certificate of occupancy 10 years old. The structure states cash due at closing of $540,200. It is ready to send.

Verdict: Allowed.

  • Structure summary. Cash due at closing of $540,200 on a loan of $41,000,000; the largest loan the limits allow is $41,000,000.

6. Healthcare bridge to HUD: A Healthcare Bridge Loan to acquire a 310-bed assisted living community

The agent's request. Please structure a Healthcare Bridge Loan of $50,200,000 to acquire a 310-bed assisted living community. The property has an eligible cost of $54,500,000, net operating income of $5,200,000 and an annual debt service constant of 8.20 percent. The term is 48 months, interest-only. The structure states cash due at closing of $266,000. It is ready to send.

Verdict: Blocked.

  • Loan above the loan-to-cost limit. The loan of $50,200,000 is above $49,050,000, the 90 percent loan-to-cost limit on a cost of $54,500,000.
  • Term outside the program range. The structure has a term of 48 months; the program term is between 1 and 36 months.
  • Interest rate cap required. No interest rate cap is purchased; a bridge loan needs one for the full term from a counterparty rated A2/A or better.
  • Stated cash due at closing does not match. The structure states cash due at closing of $266,000; the fee schedule gives $517,000.

7. Healthcare bridge to HUD: The agent resubmits after fixing the errors

The agent's request. Please structure a Healthcare Bridge Loan of $46,000,000 to acquire a 310-bed assisted living community. The property has an eligible cost of $54,500,000, net operating income of $5,200,000 and an annual debt service constant of 8.20 percent. The term is 36 months, interest-only. An interest rate cap is purchased for the full term. The structure states cash due at closing of $475,000. It is ready to send.

Verdict: Allowed.

  • Structure summary. Cash due at closing of $475,000 on a loan of $46,000,000; the largest loan the limits allow is $49,050,000.

Narration transcript

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The text of the narrated walkthrough, step by step.

  1. Welcome to a demo of Predictika's Validator. An AI sales agent structures a commercial real estate loan using Greystone programs: FHA/HUD Section 223(f), 221(d)(4), 232/223(f) and 232 loans, and more. Before the structure goes out, the agent sends it to Predictika, which checks it against a declarative model of the program terms Greystone publishes and returns a verdict, every reason, a fee schedule and the figures it computed.
  2. I will start with the first request by the agent.
  3. The agent says. Please structure an FHA/HUD Section 221(d)(4) loan of $142,000,000 to build a 480-unit market-rate apartment community. The borrower is a single-asset entity. The rest of the request is on screen. The structure states cash due at closing of $1,313,500.
  4. Before it goes out, the agent calls the validator.
  5. Blocked, with seven findings and one approval, all in one answer. The loan of $142,000,000 is above $139,500,000, the 75 percent loan-to-cost limit on a cost of $186,000,000. Net operating income of $11,000,000 covers the annual debt service of $8,591,000 only 1.28 times; the program minimum is 1.30 times. The structure has a term of 480 months; a construction loan runs the construction period of 30 months plus 40 years, 510 months in all. The other four are on screen.
  6. The validator returned seven blocking findings and one approval in one answer. A check that reads one field at a time would pass most of this; it shows only when the choices in the loan structure are checked against each other.
  7. What this shows: for loan tiers that change at $130 million, a rules-based CPQ can do this only with workarounds.
  8. Now the agent resubmits.
  9. The corrected request. It changes the loan amount to $139,000,000, the term to 510 months, the commercial income share to 14 percent, the working capital escrow to $2,800,000, the Davis-Bacon wages to committed and the stated cash due at closing to $4,085,750.
  10. It calls the validator again.
  11. Not blocked, but held for a person.
  12. The validator also returns the line-item quote. It starts with HUD application fee and FHA mortgage insurance premium paid at closing; the other line is on screen.
  13. The seven blocking findings are cleared; two approvals remain for a person: HUD may tighten limits at $130 million and above and thin debt service coverage cushion.
  14. The agent resubmits once more.
  15. The revised request. It changes the loan amount to $128,000,000 and the stated cash due at closing to $3,984,000.
  16. It calls the validator once more.
  17. This time the validator clears it.
  18. The validator also returns the line-item quote. It starts with HUD application fee and FHA mortgage insurance premium paid at closing; the other line is on screen.
  19. Both earlier findings are cleared, and the validator's total, $3,984,000, matches the loan structure.
  20. Eight problems caught in one call, fixed in two passes, and a clean $3,984,000 loan structure. That is the value of Predictika's validator: catching mistakes before they reach the customer.