32% is reachable in genuine active adult. It isn't reachable in independent living with a dining program, and that fork is probably what your lender's comp set is doing to you. Once a building serves even one meal a day you pick up kitchen payroll, food cost, and a hood and grease contract, and the ratio moves toward the high 30s or worse.
So the argument is about what's inside your $7,900. Check four lines specifically. Management fee, because senior product often prices at 4 to 5% of collections rather than the 3% you'd assume on conventional apartments. Replacement reserves, since lenders will impose their own number whatever you modeled. Sales and marketing, which in age-restricted product behaves like a cost per move-in rather than a flat per-unit ad budget, and can run several thousand dollars a lease. And insurance, where carriers have been repricing anything with the word senior on the rent roll regardless of whether you provide care.
If all four are in there honestly and you still land at 32%, hand them the line-item build rather than the ratio. Ratios lose arguments; a payroll schedule with named positions wins them.
The piece you haven't raised is why residents leave. Active adult attracts the youngest, healthiest end of the market, and those residents age in place until they need care you don't provide. That produces involuntary move-outs you don't control the timing of, plus the harder situation where a resident's health declines in place and you're weighing what you can and can't do about it. How that plays out depends on state landlord-tenant law and federal fair housing obligations, so it's a question for counsel before it's a question for your model. Whatever the lender says about coverage, get the final expense and reserve assumptions from them in writing.
