The words this desk uses on purpose
Glossary.
LTV is not CLTV. AFR is not FRED. PITIA is not P&I. If a seller or a CPA uses these interchangeably, the file is already in trouble.
Live file · rev 1
$500,000 · first $350,000 · second $150,000 · check $14,650
- AFR floor met
- AFR not locked
- Below usury cap
- CLTV 100% over cap
- Senior DSCR
- Investment occupancy
- Zero down · check still due
- AFR
- Applicable Federal Rate. IRS monthly table (Rev. Rul.), short / mid / long buckets. Note #2 must sit at or above the bucket for its term or §§1274 / 7872 impute interest. Not FRED. Not a 30-year mortgage average.
- DSCR
- Debt service coverage ratio. On this desk, senior DSCR = effective NOI ÷ first PITIA. Combined DSCR = effective NOI ÷ (first PITIA + Note #2). They are not the same number. Label them.
- LTV / CLTV
- LTV is the first lien ÷ value. CLTV is first + second ÷ value. A $0-down 70/30 stack is 70% LTV and 100% CLTV. Most DSCR firsts underwrite CLTV, and 100% disclosed CLTV is usually a dead file.
- PITIA
- Principal, interest, taxes, insurance, association. Senior DSCR uses first PITIA, not just P&I. Insurance resets in Florida can break a file that looked fine on rate alone.
- OID / imputed interest
- Original issue discount. A below-AFR or 0% note can be recharacterized so part of “principal” is interest. That can unwind the installment-sale story. Do not paper 0%.
- IRC §453 / §453A
- Installment sale. Gain is recognized as principal is received. §1250 recapture is not deferred. §453A interest on deferred tax can apply when the face of deferred payments crosses the statutory threshold (this desk flags $5M+).
- Florida usury
- Chapter 687: generally 18% under $500,000 and 25% at or above. AFR is a floor. Usury is a ceiling. They are not the same rule. Counsel cites the subsection.
- Intangible tax + doc stamps
- Deed stamps $0.70 / $100 statewide ($0.60 Miami-Dade SFR, $1.05 other). Note stamps $0.35 / $100, $2,450 cap per instrument. Intangible $0.20 / $100 of the mortgage, uncapped. Rounded up per $100 of consideration.
- Purchase Money Mortgage
- Buyer takes title by warranty deed; seller records a mortgage. Florida courts treat land contracts as equitable mortgages anyway. Use the instrument the court already knows.
- Silent second
- Recording the seller second after the senior closes, hoping the first never sees it. Most firsts treat that as fraud. This desk will label it; it will not recommend it.
- Escrow / closing funds
- Florida purchase money sits with a licensed title company (Fla. Stat. § 626.8473), a Florida attorney trust, or — earnest money only — a licensed broker. SSDF Inc. and StackDesk never hold deal funds. Stripe is a card processor for software fees later, not for price, stamps, or table-fund. Note #1 tax/insurance “escrow” is the senior’s impound, also not yours.
- CRE vs 1–4 vs business+land
- The same triangle (deed, PMM, AFR, simultaneous close, ICA) works on Florida realty: SFR, land, 5+, warehouse. Occupancy/Dodd-Frank drop off on true business-purpose files — owner-occ office and live-work stay on caution until counsel says so. Fits on CRE only when a shop publishes a CRE max CLTV and a subordinate-financing policy; greying 1–4 DSCR is not enough. An operating business sitting on that dirt is two collateral stacks (PMM + UCC-1, IRC §1060). Do not model a shop + lot as a 70/30 rental file.
- §1031 vs carry
- A full like-kind exchange needs cash through a qualified intermediary. A current-pay seller second is installment treatment under §453 — a different exit. If the seller wants the exchange, they list. If they carry, they are not exchanging this property. StackDesk will not invent a 1031-friendly stack. Compare list vs carry on the tax-year table.
- Owner will carry / free-and-clear
- OWC on a listing is a keyword, not a market. The hunt overlay is the share of owner-occupied units with no mortgage (Census ACS B25081). That is who can say yes. A recorded purchase-money mortgage in official records is a closed-file comp, not inventory. Contract for deed, land contract, and agreement for deed are hard stops — warranty deed + recorded PMM only. NAL rolls do not flag free-and-clear; outstanding liens live at the clerk.
- Cash-to-close vs cash-down
- Cash-down is equity. Cash-to-close is the check: equity plus Florida stamps, intangible, title, points, prepaids. A $0-down stack is not a $0 check. Lender credit (higher coupon, dollars at the table) and a true seller concession (seller cash falls; note does not grow) can cut the check. Rolling costs into Note #1 only works with unused LTV and CLTV room — dead on a 70/30 at 100% CLTV. Pouring a concession onto Note #2 is financed costs, not a concession. A personal loan or HELOC for stamps is outside this file.