HUD Survey Requirements: Form 91073M and the ALTA/NSPS Land Title Survey

Every HUD-insured multifamily loan closes with two survey documents: an ALTA/NSPS Land Title Survey, and Form HUD-91073M, which supplements the ALTA Survey. If you've financed apartments with Fannie Mae, Freddie Mac, or a bank, you've ordered an ALTA survey before. The 91073M is the HUD-specific supplemental report. The first part of the HUD report is simply an instruction set to the surveyor on how to complete the ALTA survey per HUD requirements: which edition of the ALTA/NSPS standards to follow, which Table A optional items HUD requires, and a set of conditions (flood elevations, blanket easements, common elements) where HUD's scope is different than a standard survey. The second part of the HUD report is ten questions about the property that the surveyor answers from fieldwork and title research, followed by a surveyor certification.

Both documents must come from a licensed surveyor — an engineer's signature does not satisfy the requirement — and the report must carry the surveyor's original signature and professional seal. The 91073M report also has to be signed and dated on or after the date of the last revision to the ALTA survey.

HUD mainly requires the supplemental report as a convenient way to instruct the surveyor on exactly what is needed. Every plottable easement, restriction, and exception on the title policy must be depicted on the survey. Blanket easements that can't be plotted get listed with their recording information and a "not plottable" notation next to the title exception. Access roads are labeled public or private.

We reviewed these packages from the HUD side for years. The surveys that clear review are the ones where the surveyor was handed the preliminary title review, the blank 91073M, and any prior surveys early on at engagement.

ALTA and NSPS revise the Minimum Standard Detail Requirements on a five-year cycle. The 2026 edition was adopted in October 2025 and took effect on February 23, 2026, superseding the 2021 standards for any survey contracted on or after that date. It should be known, however, that the version of Form 91073M posted on hud.gov still recites the 2021 standards, because HUD wrote the current form when the 2021 edition took effect and hasn't finished revising it.

HUD partially closed that gap on March 20, 2026, when it issued transition guidance stating that until the revised form is published, HUD will accept surveys performed to the 2026 standards on the current form, with the certification language conformed per a redline HUD circulated with the notice. The redline changes five things. Four are simply the year — 2021 becomes 2026 in the standards-of-performance paragraph, in Section A, and in both certification blocks. The fifth is a cross-reference: the wetland-delineation amendment now points to Table A Item 21 instead of Item 20, because the 2026 standards added a new optional Item 20 — a summary table of observed encroachments and access issues — and pushed the client-negotiated slot down one.

The required Table A items are the same list: 1, 2, 3, 4, 6a, 6b, 7a, 8, 9, 10, 11a, 12, 13, 16, 17, and 18. The 180-day and 120-day fieldwork windows are untouched.

Two situations still put the edition in play:

• A survey update contracted after February 23, 2026 must follow the 2026 standards — with one exception. If the original survey was contracted under the 2021 standards and a delayed closing forces an update, the update may stay on 2021 (becoming less and less common each day).
• An as-built survey for Final Endorsement contracted after February 23, 2026 must follow the 2026 standards even if the initial closing survey was performed under 2021. Every 221(d)(4) under construction today closes its final on a 2026 survey.

Put the edition in the surveyor's engagement letter: specify a "2026 ALTA/NSPS Land Title Survey" and attach the current 91073M with HUD's redline. Reused certification templates sometimes still recite the 2016 or 2021 standards; a certification to the wrong edition is a HUD closing comment, so it's worth a quick look at survey delivery rather than at closing.

Table A is the menu of optional survey services at the back of the ALTA/NSPS standards. HUD requires sixteen of them — items 1, 2, 3, 4, 6a, 6b, 7a, 8, 9, 10, 11a, 12, 13, 16, 17, and 18. Here is what each one makes the surveyor do.

• Item 1 — Monuments. Physical markers set at every major corner of the boundary, unless corners are already marked. The recorded legal description gets tied to objects in the ground.
• Item 2 — Address. The property address as disclosed in the documents or observed in the field, stated on the plat.
• Item 3 — Flood zone. The flood zone classification from the FEMA Flood Insurance Rate Map, plotted graphically. The 91073M then goes further than Table A: where any part of the site is in a flood hazard area, the form requires the 100-year flood elevation and zone, and for existing projects the elevations at building entrances, the lowest habitable finished floor, basements, and the parking areas serving each primary building. That elevation data is what HUD's environmental review and the flood insurance requirement use.
• Item 4 — Gross land area. Total site area, in acres and square feet. Feeds the plat legend, the appraisal, and the application exhibits.
• Items 6a and 6b — Zoning. If the client provides a zoning report or letter, the surveyor lists the classification, setbacks, height and floor-area restrictions, and parking requirements on the plat (6a) and graphically depicts the setback lines (6b), citing the date and source.
• Item 7a — Building dimensions. Exterior dimensions of every building at ground level.
• Item 8 — Substantial features. Parking lots, signs, billboards, pools, landscaped areas, substantial refuse areas — i.e. the improvements beyond the buildings themselves.
• Item 9 — Parking. A count of clearly identifiable spaces by type — regular, disabled, motorcycle, other marked types — plus striping on surface lots. HUD underwriting compares this count to the zoning requirement from 6a and to the parking shown in the appraisal; discrepancies among the three are a standard review comment.
• Item 10 — Party walls. Where the client designates, a determination of the location of division or party walls with respect to adjoining properties. In the 2026 standards this is one consolidated item — the old 10(a)/10(b) split from earlier editions is gone.
• Item 11a — Underground utilities from plans. Evidence of underground utilities developed from plans and reports the client provides, combined with what the surveyor observes on the surface — manholes, valves, meters, pedestals, overhead lines. HUD requires 11a only. Item 11b, a private utility locate coordinated in the field, is not on HUD's list.
• Item 12 — Governmental agency requirements. Checking Item 12 and providing the surveyor the 91073M is what makes HUD's instructions part of the ALTA official scope of work. The relevant requirements come from the client, which means the 91073M is connected to the survey engagement letter.
• Item 13 — Adjoining owners. Names of adjoining property owners from current tax records. HUD reads this alongside the encroachment answers — it establishes who is on the other side of every shared line, fence, and drive.
• Item 16 — Recent earth moving. Observed evidence of recent earth moving, building construction, or additions. Recent work can mean unrecorded mechanic's lien exposure, which could also be a title policy problem.
• Item 17 — Street changes. Proposed changes in street right-of-way lines where the jurisdiction makes that information available, plus observed evidence of recent street or sidewalk construction. A planned widening that takes ten feet of frontage is something HUD wants to see before endorsement.
• Item 18 — Offsite easements. Plottable offsite easements that benefit the property — the access drive over the neighboring parcel, the offsite drainage easement — surveyed as part of the work. These appurtenant rights are part of HUD's collateral, so they get surveyed like the fee parcel does.

If the first half of the HUD 91073M are the instructions, the second half is ten questions the surveyor answers from fieldwork and title research. Each question gets a detailed answer or the word "none." "As shown on survey" is expressly not an acceptable response. HUD's closing attorney reads the ALTA Survey and the ten questions side by side to make sure they are aligned.

The ten questions, and what HUD is screening for:

• 1. Rights of way and utility crossings. Old highways, abandoned roads, lanes, drains, sewer and water pipes over or across the site. Unrecorded physical rights of way are exactly the survey matters title insurance excepts unless someone finds them.
• 2. Water features. Springs, streams, rivers, ponds, and lakes on, bordering, or running through the property. Water raises boundary questions (a water line that moves could be a title line that moves) and it also flags any floodplain and wetlands issues for the environmental review.
• 3. Cemeteries. Cemeteries or family burial grounds on the premises. Rare, but a burial ground carries access rights and removal restrictions that survive a deed, which is why the question has stayed on the form.
• 4. Towers and lines. Electrical and communications towers, antennas, lines, and supports on, overhanging, or crossing the site. Overhanging lines are encroachments, and transmission corridors usually mean recorded easements with building restrictions inside them.
• 5. Disputed boundaries and encroachments. Boundary lines, setbacks, and easements in dispute; buildings, cornices, signs, or fences crossing lines in either direction. Whatever gets listed here has to be resolved, insured over, or accepted by the HUD Regional Director before closing.
• 6. Recent earth moving. Earth moving, building construction, or additions within recent months — the report-level cross-check of Table A Item 16, and HUD's screen for unrecorded work that could ripen into mechanic's liens ahead of the insured mortgage.
• 7. Building and possession lines. For city property, whether walls are independent or party walls, and any easements of support or beam rights. For rural property, how the boundary is evidenced on the ground — fences or otherwise. Where lines of possession differ from lines of title, adverse possession questions are raised.
• 8. Street construction and street line changes. Recent or proposed street and sidewalk work per the controlling jurisdiction — the report companion to Table A Item 17.
• 9. Flood zone classification. This answer has to match the flood determination in the environmental review and the flood insurance in the closing package.
• 10. Dump, sump, or landfill use. Whether the site was ever used as a solid waste dump, sump, or sanitary landfill. A "yes" belongs in the Phase I before it appears in a surveyor's report — this question exists so that nothing surfaces for the first time at closing.

The report closes with the surveyor's certification that the survey was made on the ground per the record description, that except as shown there are no encroachments across property lines, that title lines and lines of actual possession are the same, and whether the premises sit in a 100- or 500-year flood hazard with the FIRM community panel number.

The survey and the Surveyor's Report must be signed and sealed by the surveyor no more than 180 days before closing, and the last site inspection or fieldwork can be no more than 180 days before closing. For the as-built survey at the final closing of a construction loan (only HUD 221(d)(4) or 241(a)), both windows tighten to 120 days. The Surveyor's Report must be dated on or after the date of the last revision to the survey, so the report date follows the plat.

The clock runs from fieldwork to closing, not from engagement, and HUD reviews the draft closing package before the closing date. A survey delivered five months before a closing that then slips a quarter is out of the time window.

The form and the timing rules above apply to every program. What differs is how many surveys a deal needs and when each one is due.

HUD's closing review reads the survey against the pro forma title policy. An encroachment or unrecorded use the surveyor reports has a short list of resolutions: the title company insures over it with an endorsement, the parties cure it with a recorded easement or license, the condition is removed, or the HUD Regional Director accepts it as minor. Each of those takes time in inverse proportion to how early the survey was ordered.

If the project shares a drive, parking, drainage, or amenities with an adjacent parcel, HUD wants a recorded agreement that runs with the land and the agreement has to exist in the record early enough for the surveyor to plot it and the title company to schedule it. Papering a shared-use agreement during the closing window means revising the survey, the title commitment, and the 91073M at the same time.

For a typical multifamily site, an ALTA/NSPS survey with the 91073M scope runs around $10,000 or more, moving with acreage, the number of improvements, the count of title exceptions to plot, and the region. Plan on five to six weeks from engagement to a reviewable draft. This means that we recommend Borrowers order the survey in the first wave of third-party reports, alongside the appraisal and environmental, not when you are trying to wrap up the rest of the checklist before the Firm Application is going in.

The surveyor will typically ask for the title commitment with the exception documents, the blank 91073M with HUD's 2026 redline, any prior surveys, the recorded legal description, and the zoning report, if available. A surveyor working from that package prices the job accurately and plots the exceptions the first time.

If the closing slips and the survey goes stale, the update or recertification is materially cheaper than starting over. The expensive version of a survey problem is the one discovered in HUD's closing review; the inexpensive version is the one your lender catches at survey delivery. We read every survey and Surveyor's Report on our deals against the title commitment before either goes to HUD.