HomeMy WebLinkAboutR33-Economic Development Agency
ECONOMIC DEVELOPMENT AGENCY
OF THE CITY OF SAN BERNARDINO
SUBJECT: PROPOSED MODIFICATIONS TO THE
ACQUISITION, REHABILITATION AND
RESALE (ARR) PROGRAM PURSUANT
TO THE DEPARTMENT OF HOUSING
AND URBAN DEVELOPMENT (HUD)
_______________________________________________________________________________________________________~~~}!~g!!!,~:!:!Q.~L___________________________
FROM:
Maggie Pacheco, Deputy Director/Director
Housing & Connnunity Development
0,..,,-..., 'L
May 24, 2002 hI...; I . ~ Ii
DATE:
SvnoDsis of Previous Commission/Council/Committee Action(s):
On May 23, 2002, the Redevelopment Committee recommended approval of this item to the
Community Development Commission.
Recommended Motion(s):
(Commnnitv Development Commission)
MOTION:
That the Community Development Commission (I) approve the proposed
modifications to the ARR Program in order to comply with the 2001-30 HUD
regulations and (2) authorize staff and Agency Special Counsel to prepare
modifications to the standard form of the ARR Agreement between the ARR Partner
and the Agency to reflect the changes discussed in Attachment "A" to this staff
report.
Contact Person( s):
Project Area(s)
Maggie Pacheco Phone:
All Ward(s):
o Staff Report 0 Resolution( s) 0 Agreement( s )/Contract( s) 0 Map( s)
Supporting Data Attached: 0 Letter/Memo/New ARR Outline
FUNDING REQUIREMENTS Amount: $ N/A
663-1044
1-7
Source:
N/A
Budget Authority:
N/A
SIGNATURE:
MoJ~
I, "0 Gary Van asdel, Executive Director
\..-::r-- Economic Development Agency
U(JlAJU--
Maggie Pacheco, Deputy Director/Director
Housing & Connnunity Development
Commission/Council Notes:
GVO:MP:sj:6-17-02 ARR Program
COMMISSION MEETING AGENDA
Meeting Date: 06/03/2002
Agenda Item Number: _Il. 93
'/JI(J~
ECONOMIC DEVELOPMENT AGENCY
STAFF REPORT
Proposed Modifications to the Acquisition, Rehabilitation and Resale CARR) Prol!ram
Pursuant to the Department of Housinl! and Urban Development mUD) New Rel!ulations
BACKGROUND:
In 1996, the Mayor and Common Council approved the Acquisition, Rehabilitation and Resale
Program, commonly known as (ARR). In November 1997, the City of San Bernardino and the
U.S. Department of Housing and Urban Development (BUD) agreed to join together to reduce
the number of BUD Real Estate Owned (REO) inventory, to reduce the blighted conditions in
the City, and to create homeownership opportunities for City residents. To meet this goal, the
Mayor and Common Council authorized the execution of a Resolution expanding and enhancing
the ARR Program (the "Expansion Resolution"). The Expansion Resolution, signed by the
Mayor and BUD's secretary, allowed the City to purchase uninsurable properties at a 30%
discount, plus an additional $2,500 discount, provided the City closed 10 or more properties
simultaneously within 45 days. More importantly, the Expansion Resolution acknowledged and
authorized the City to have "back-to-back" escrows with for-profit private partoers (the "ARR
Program"). At the time the Resolution was approved, BUD's inventory in the City consisted of
over 1 ,200 housing units. This large BUD inventory of vacant properties had a tremendous
negative impact, both physically and fiscally on the San Bernardino community as well as BUD.
The ARR Program which has served as a pilot and national model, and has been adopted by
many other cities, has evolved into a successful housing renovation program, addressing the
preservation of housing and neighborhoods in the City. The ARR Program functions as a
public/private partnership between BUD, the Agency and the pre-selected for-profit or non-profit
partoers. Under the existing ARR Program, the Agency buys foreclosed units at a discount,
directly from HUD and concurrently (back-to-back escrow) sells the units to pre-selected for-
profit private partoers for the rehabilitation and resale to qualified income eligible buyers. Other
than administration and staffing costs, there is no financial risk to the Agency. If a buyer is
eligible for HOME or Redevelopment Housing funds, the Agency provides up to 10% down
payment and closing costs directly to the prospective homebuyer.
At the end of each calendar year, the Agency is required to submit an annual report to BUD
reporting all its acquisition and resale activities. To this date, the Agency has not been notified
in writing of any non-compliance issues.
GVO:MP:sj:6-17-02 ARR Program
COMMISSION MEETING AGENDA
Meeting Date: 06/03/2002
Agenda Item Number:
Economic Development Agency Staff Report
ARR Program
May 24, 2002
Page Number -2-
CURRENT ISSUE:
In January 2002, HUD published new regulations, 2001-30, relative to the disposition ofHUD's
foreclosure inventory. In late February 2002, HOO's Santa Ana Homeownership office,
conducted a workshop for participating governmental agencies on the new 2001-30 regulations,
(the "Single Family Direct Sales Program"). The workshop provided a detailed clarification of
HUD's new regulations, specifically, clarification of the "net development cost" calculation,
eligible project costs, and modifications were also made to HUD's Land Use Restriction
Addendum (LURA), which the Agency must sign with each sales contract for each property it
purchases from HUD. This LURA contains certain restrictions and conditions related to the
disposition of property and the Agency passes on these obligations to the ARR Partner via the
ARR Agreement.
Historically, HUD has never defined "actual, and allowable net development costs". The only
direction given to non-profits and participating governmental entities was that project costs had to
be "reasonable and customary" for the area; nor did the regulations prohibit back-to-back escrows
with for-profit entities.
During the course of training, HUD's Representative verbally stated to Agency Staff that the
ARR Program was not in compliance with HUD's Single Family Direct Sales Program,
guidelines 2001-30. Staff asked why the City or Agency had not been notified? The HUD
Representative did not provide an explanation. Consequently on April 23, 2002, a letter was sent
to Mr. Tom Rose, Director of the REO Program requesting a determination that the Agency's
ARR Program was not in compliance with the Single Family Direct Sales Program (see attached).
Staff did not receive a written response to said letter, and as such, on May 3, 2002, Staff contacted
Mr. Rose, who stated that the ARR Program as currently structured did not meet the 2001-30
Regulations. Mr. Rose stated that the Agency would be receiving a letter within three weeks to
confirm his statement and that HUD would be requesting a meeting with Agency Staff in order to
assist the Agency in its effort to revise the ARR Program to meet the new HUD Regulations.
Per the standard form of the ARR Agreement, approved by the Commission in 1999, the ARR
Partners are responsible for securing financing for the acquisition, rehabilitation and management
of HUD homes they purchase from the Agency. The Agency only serves as a conduit between
HUD and the ARR Partner, there is no financial risk to the Agency. The ARR Partner is one
hundred percent (100%) responsible for the rehabilitation of the home and the ultimate sale to a
qualified homebuyer. The Partner is limited to a 10% profit on the sale of each home. All HUD
conditions and requirements on the Agency are passed on to the ARR Partner.
Because 2001-30 Regulations have been revised, the Agency will no longer be able to implement
the ARR Program in its current configuration. The new regulations require that all costs for
rehabilitation and marketing must occur during the time that the governmental entity holds title.
GVO:MP:sj:6-17-02 ARR Program
COMMISSION MEETING AGENDA
Meeting Date: 06/03/2002
Agenda Item Number:
Economic Development Agency Staff Report
ARR Program
May 24, 2002
Page Number -3-
OtheIWise the Agency is unable to pass on the "net development costs" definition to the ARR
Partner. Accordingly, Staff, Agency Special Counsel, and the ARR Partners are proposing to
revise the ARR Program in order to comply with the new regulations. The proposed revisions to
the ARR Program are described in Attachment "A".
The ARR Program has been a successful and a viable tool for revitalizing neighborhoods in our
City. Since its inception, over 800 foreclosed homes have been purchased by the Agency,
rehabilitated to Agency high quality standards and resold only to homebuyers. The ARR Program
has significantly reduced the number of vacant homes in our community.
In revising the ARR Program to incorporate HUD's new regulations, particular emphasis was
placed on minimizing the financial exposure and risk to the Agency.
ENVIRONMENTAL IMPACT:
None.
FISCAL IMPACT:
The proposed revisions to the ARR Program are intended to mitigate the fiscal impact to the
Agency.
RECOMMENDATION:
Based on the foregoing, staff recommends adoption of the form motion.
VW{j ~
Maggie Pacheco, Deputy Director/Director
Housing & Community Development Director
GVO:MP:sj:6-17 -02 ARR Program
COMMISSION MEETING AGENDA
Meeting Date: 06/03/2002
Agenda Item Number:
City of San Bernardino
ECONOMIC DEVELOPMENT AGENCY
.
Redevelopment. Community Development. Housing. Business: Recruitment. Retention. Revitalization. Main Street. Inc.
~
April 23, 2002
Thomas A. Rose, Director REO
US DEPARTMENT OF HOUSING
AND URBAN DEVELOPMENT
Santa Ana Homcowncrship Center (HOC)
1600 Broadway, Suite 100
Santa Ana, Califomia 92760
RE: CITY OF SAN BERNARDINO ACQUISITION, REHABILITATION AND
RESALE (ARR) PROGRM'I AND IIUD DIRECT SALES PROGRA!\I
Dear Tom:
On February 21, 2002, the U.S, Department of Housing and Urban Development (I-IUD) held a
training seminar at the Homcownership Center in Santa Ana for ll1unil:ipalities that purchase
HUD foreelosed properties under the HUD Direct Sales Program. The purpose of this meeting
",as to rcview recent changes established by HUD Mortgagee Letter 2001-30, It was our
c,\pcctation that this meeting would proviJc clarification on the proper calculation of the Net
De\'clopment Costs as it pertains to properties purchased under the Direct Sales Program. We
"ere pleased to participate in this training because up until this point there has not been a clear
delinition of what constitutes net development costs. It is our goal to keep apprised of HUD
regulations so that we insure \Ve pass 011 the new rcquin:mcnts ::lI1d rcgubtions to ollr ARR
p:j[lllcrs.
T\\'o of my staff members, as well as our Consultant, CivicStonc, attended this seminar on my
behalf. I understand from them, that during this meeting Mr. Bill McKee, Program Compliance
Manager, slated, "i/ H'US Hel'er lite ill/cllI of tlte HUD Direct Sales Program" to Iw\'e
II/III/ieipolities sell HUD foreclosures to ''for-profit Call/ponies ", (further understand, that you
personally reinforced this statement to Mr. Adam Eliason, Agency ARR Consultant. It surprised
me to hear such statements could be madc after six ycars of successfully opcrating our ARR
Program and with HUD's concurrence. (fthis statement is truc and Mortgagee Lettcr 2001-30 is
an indircet attempt to stop the City/Agency from using the ARR Program as a means of reducing
thc numbcr of HUD foreclosures in our community, I hope that after rcading this letter we can
reach a mutual eonscnsus about the Agency's participation in HUD's direct sales program.
207 North E Street. Suite 30T - San Bernardino. California 92401-:1507- (909) 663-1044 - Fax (909) 888-94 13
www.sanbernardino-eda.org.
.1;
MR. THOMAS A ROSE
April 23, 2002
Page Number 2
Over the past six (6) ycars, the structurc of ARR Program has always bcen to utiliZl: for- prot;t
companics and has been rccognizcd at all Icvels as one of the most innovative and pro-activc
local govcrnment programs. Thc necd to partner with private companies began in 1996 when
San Bernardino had one of the highest inventories ofHUD foreclosures in the nation (1200 units).
Recognizing that the City/Agency's resources were extremely limited and that without private
capital and enterprise, HUD nor the City, could see a dramatic decrease in the HUD inventory in
our community. Thus, the City/Agency established partnerships with sevcral qualified and
reputable for-profit companies who would have access to resources and in order to perfornl a high
volume of purchase, high quality rehabilitation and resale of HUD homes in an efficient manner.
Our ARR Partners brought experience, capital and capacity to help resolve the housing crises that
our community and HUD were experiencing. The partnership that the Agency cstablished with
private enterprise was no different than the partncrship HUD had and has established with private
industries such as Goldenfeather Realty who contracts with HUD to dispose of all its assets and in
hopes of expediently replenishing resources to the national government and tax payers.
Because of the success of the ARR Program, in partnership with HUD, the City of San
Bernardino has seen a dramatic change in neighhorhood stabilization and improvement.
Furthermore, the ARR Program has provided an avenue lur low to moder:lte-ineome families to
realize the dream of homeownership. Due to the City/Agency approach, in 1997, HUD
Secretary. Andrew Cuomo, met with City officials and endorsed the ARR Program. As you
know, in 1997, he and the Mayor of San Bernardino signed the Expansion Resolution that greatly
enhanced the ability of the ARR Program to continue and to provide a successful means for I-lUD
to reduce the number of I-lUD foreclosures in our City.
Since the Secretary's official endorsement of the ARR Program in 1997, three HUD Best
Practices Awards have further recognized the ARR Program with accolades of superior
achievement and have distinguished the program as a model for other communities. In t"et,
many otber communities have adopted and arc currently using the San Bernardino model today.
The City of San Bernardino ARR program was also awarded the I-lUD Blue Ribbon Practices in
I-lousing and Community Development (John J. Gunther Award) in 1998 and as I understand this
award continues to be posted on the I-lUD web site. Prcsident Clinton discussed the ARR
Program at the U.S. Conference of Mayors on January 28, 2000 as a model for othcr communities
to embrace. Furthermore, numerous HUD Staff, Goldenfeather Realty, threc HUD escrow
companies, six I-IUD Annual Reports and on-sitc inspections of the ARR Program by HUD
auditors have contributed to the success of our Program. Clearly the President, the Seerctary and
all top officials at HUD supportcd the ARR Program in its design, function and perfornlanec and
never once, to my knowledge, has the City/Agency been infonned by correspondence or proper
notification that the ARR Program is not in compliance with HUD policy and regulations. Since
1996, the City/Agency, through the use of the ARR Program, has purchased more than 700
properties directly from HUD and has concurrently passed on these properties to our ARR
Partners who have bcen required under contract with the Agency to abide by all HUD regulations
and most importantly to pass on a high quality home to our low income homebuyers. Thus far,
our partncrship has created in excess of 531 million in real estate resourecs to HUD and I venturc
to estimate that the ARR Program has stimulated over 556 million in private real estate
investment in the local economy.
In closing, I ask you once again, as I did back on September 2 I, 2000 (see attached Ictter), to
confirm that the Agency's ARR Program is not in compliance with HUD's Direct Sale Program
regulations.. Should you determine that the Agency is not in compliance, I respectfully request a
r J f,
MR. THOMAS A ROSE
April 23, 2002
Page Number 3
meeting with you to discuss which progmm approach would be acceptable to HUD in hopes of
continuing our collaborative and mutual goals of reducing HUD foreclosures and stabilizing our
community.
As always, I look forward to continuing our long-term partnership and please feel free to call me
at (909) 663-2277.
Sinc,ere.~ ,~i ~
'~ (I .
LV ~ C 1..,..' .
Maggie Pacheco, Dep ty irectorlDirector
Housing & Commun'tty Development
Enclosure
CC: Mayor Valles
Chief of Starr Rubi
Executive Director Van Osdel
Assistant Project Managcr Espinoza
Construction Managcment Specialist Willmott
Adam Eliason, CivicStonc
Joscph Batcs, Dircctor, Santa Ana HOC
,I,
City of San Bernardino
ECONOMIC DEVELOPMENT AGENCY
Redevelopment. Community Development. Housing. Business: RecrUItment. Retention, Revitalization. Main Street, Jne.
September 21, 2000
Mr. Thomas A. Rose, Director REO
U.S. Department of Housing and Urban Development
Santa Ana Homeownership Center
1600 Broadway, Suite 100
Santa Ana, California 92706
RE: ARDEN-GUTHRIE
f(J~
Dear ~ose:
This Ieller is in response to your leller of August 3 and your e-mail of September 14,2000.
Inasmuch as you have denied our one (I) year extension request for Arden-Guthrie, we appreciate thc six
(6) month extcnsion and look forward to receiving the extension leller per your leller of August 3, 2000.
With regard to the vacant ACA/HUD properties, please understand that the County's inability to close the
HUD properties in a timely manner negatively impacts our community and naturally requires the Agency
to be proactive and to step in to resolve the problcm. Towards this end, [ am in agreement that the most
expedient manner in which to proceed with the acquisition of the units is to move forward under the
current County/HUD/ Agency Agrecment provided you are able to get the County to transmit a complete
list of all properties to the Agency, prepare sales contracts and close escrow within the respective
timeframe. By way of an example, the Agency was offered the property located at 1450 Sheridan Road in
January 2000. The County did not sign a sales contract until August 14, 2000. As you can see, the
acquisition process and closing is clearly out of my control.
We are committed to reducing HUD's inventory in the ACA's and [ will be taking an amendment to the
County and Agency Agreement to our Board on October 2, 2000, assuming the County is in agreement.
This amendment will allow the Agency to buy all of the HUD units in Target Area # I. For that matter, I
intend to recommend to the Agency Board that they buy all HUD units in the ACA's, thus eliminating the
need for the County to buy HUD units in our City. The Agency with the assistance of the ARR
Participants will buy, rehabilitate and resell the units to homebuyers, not investors. It might interest you
to know that according to Arrowhead Escrow, there are 68 properties on their records that are listed as the
City of San Bernardino properties when in fact there are only II located within the City ACA's and the
City has never been offered those 11 properties by the County. The remaining properties lie within
County or other jurisdictions. Accordingly, as of July 17,2000, the County provided us with a list of 57
properties of which we intend to buy all of these properties despite the financial gap. We have also
previously closed 22 properties, for a total of 79 properties the Agency will purchase from the County and
eoncurrently convey to approve ARR Participants. In conclusion, I trust that you will ensure that the
201 North E 5treet, 5uite 301. 5an Bernardino, California 92401.1507. (909) 553.1044 . FAX (909) 888.9413
-
..
MR. THOMAS A. ROSE
September 20, 2000
Page Number Two
County complies with their agreement to pursue the acquisition of the units In our City In a timely
schedule.
Lastly, the City of San Bernardino's ARR Program has been nationally recognized for its leadership and
partnership with HUD and its commitment to the provision of affordable housing opportunities for first
time homebuyers. The City has carried out the program in compliance with federal regulations, in
accordance with the procedures outlined by Mr. Byron Duplantier, Deputy Assistant Secretary, on a lener
dated September 10, 1997, and the Expansion Resolution dated November 6, 1997.
As such, after consultation with legal counsel, we are of the opinion that the City has not been properly
noticed pursuant to the Expansion Resolution to specifically express an unequivocal action of HUD to
terminate the Expansion Resolution. In fact, the e-mail that I received on November 12, 1999, sought my
concurrence with the dates by which HUD intended to terminate the exclusivity provisions and the S2,500
per house bulk discount arrangement. In my response to your November 12, 1999 and July 14, 2000,
various c-mails, I agreed as to the termination date for the exclusivity provision but clearly disagreed with
any termination of the S2,500 per house bulk discount or Expansion Resolution. The subsequent actions
and ongoing discussions of !-IUD and its escrow company, Arrowhead Escrow, would lead anyone to
believe that the S2,500 per house bulk discount arrangement was in effect and continues to be in effect as
of today. No notice of termination or any other direction has been delivered to Arrowhead Escrow
directing them to cease processing the documentation for the S2,500 per house bulk discount. This
continued processing by HUD's escrow company is consistent with my prior e-mails to !-IUD staff and
follow-up telephone discussions. We are of the opinion that !-IUD's actions confirm that the Expansion
Resolution remains valid and in full force and effect. Consequently, should you desire to terminate the
Expansion Resolution, at this time, I ask that you provide the requisite 30 day written notice directly to
Mayor Judith Valles, at 300 North "D" Street, 6th Floor, San Bernardino, California 92401 to enable her
to take appropriate actions under the present circumstances.
As always, thank you in advance for your assistance.
~IY' ~
Maggi~O' Direetor
Housing and Community Development
cc: Judith Valles. Mayor
Executive Director Van Osdcl
Agency Special Counsel Sabo
Adam Eliason, CivicStonc
rl,-.
.
ATTACHMENT 'A'
OUTLINE OF POINTS FOR ARR PROGRAM MODIFICATIONS TO
ACCOMMODATE NEW DEFINITION OF "NET DEVELOPMENT
COST" UNDER FHA MORTGAGEE LETTER NO. 2001-30
(Redevelopment Agency of the City of San Bernardino)
· Old ARR structure of back-to-back escrow closings between Agency and pre-approved
ARR Participant is modified to provide for Agency acquisition of individual HUD
Parcels by Agency (solely using funds provided to the Agency by ARR Participant) and
then the Agency grants a license to ARR Participant to enter the specific HUD Parcel as
purchased by Agency from HUD in order for ARR Participant to perform rehabilitation
work and prepare HUD Parcel for resale to Qualified Homebuyer.
· After ARR Participant (i) completes rehabilitation work on HUD Parcel (as certified by
Agency); AND (ii) ARR Participant presents pre-qualified and private mortgage lender-
approved Qualified Homebuyer to the Agency, THEN (iii) Agency transfers fee title in
fully rehabilitated HUD Parcel to ARR Participant who in turn simultaneously transfers
fee title to Qualified Homebuyer.
. ARR Participant Contract shall be modified to provide for a four (4) stage procedure:
STAGE I New ARR Participant Contract sets forth general ARR Participant
qualifications, representations and warranties in favor of Agency and
Qualified Homebuyer, general development/rehabilitation standards and
procedures and Qualified Homebuyer general eligibility and underwriting
tests;
STAGE II provides for ARR Participant to give specific notice to Agency for each
HUD Parcel which the ARR Participant seeks to rehabilitate and market to
Qualified Homebuyer;
STAGE III provides for funds transfer by ARR Participant to Agency to acquire HUD
Parcel identified in ARR Participant Notice and provides a rehabilitation
and HUD Parcel marketing and resale license agreement by and between
the Agency and the ARR Participant for specific HUD Parcel
(rehabilitation work to proceed promptly and to be completed by the ARR
Participant within 6 months after issuance by Agency of license for entry
by ARR Participant onto HUD Parcel);
STAGE IV Qualified Homebuyer eligibility verification and, if Agency MAP funds
are to be used, Agency MAP underwriting eligibility verification is
completed; ARR Participant completes HUD Parcel transfer sale escrow
arrangements among Agency, ARR Participant and Qualified Homebuyer
SB2002:16867.1 1
.
. New ARR Participant Contract contains new provisions and safeguards for the Agency in
light of ARR Participant license arrangement for entry onto HUD Parcel pending close of
escrow between ARR Participant and Qualified Homebuyer in order to accommodate
new FHA definition of "Net Development Cost":
(i) Agency will need to grant the ARR Participant's lender a deed of trust in the
HUD Parcel during the license period-this ARR Participant lender deed of trust
will be non-recourse against any other assets or lands of the Agency-ARR
Participant lender security shall be special and limited to HUD Parcel only-
Agency has no liability or obligation to ARR Participant lender except to transfer
HUD Parcel to ARR Participant lender upon default by ARR Participant;
(ii) additional insurance coverage in favor of the Agency will be required to cover
building rehabilitation work design and construction issues; additional ARR
Participant indemnity in favor of Agency against mechanic liens during license
period and ARR Participant lender releases in favor of Agency, ARR Participant
builder's warranty contract in favor of Qualified Homebuyer may be added as part
of ARR Participant's responsibilities (this will likely pose additional costs on
each ARR Participant);
(iii) LUC (a HUD land use covenant) will be recorded by Agency at time of purchase
of HUD Parcel which will be a "senior lien" to ARR Participant lender deed of
trust and ARR Participant's collateral assignment to its lender-if ARR
Participant lender acquires HUD Parcel upon its borrower's default-lender must
still sell/resell the HUD Parcel to Qualified Homebuyer subject to "Net
Development Cost" maximum sale price limitations;
(iv) since new definition of "Net Development Cost" imposes certain new limits on
Agency/ARR Participant's carrying costs to 6 months the Agency will need to
provide for very fast rehabilitation plan review and approval and City/Agency
coordination/cooperation with ARR Participants for building permit issuance and
field inspection of work performed as well as Qualified Homebuyer verification
work will be key focus of Stage IV work by Agency staff and ARR Participants.
New or Substantially Modified ARR Program Documents Required to Implement Modifications:
1. ARR Participant Pre-Qualification Agreement (substantial modifications of old ARR
Agreement)
2. LUC (new document to be recorded by Agency at time of purchase ofHUD Parcel)
3. ARR Participant Notice to Agency of Intent to Rehabilitate and Resell Specific HUD
Parcel (new document; ARR Participant Notice will contain certification that ARR
Participant Lender approves transaction and consents to license agreement)
SB2002:16867.l
2
..
.
4. ARR Participant Lender Deed of Trust (new document and non-recourse protections in
favor of Agency)
5. ARR Participant License Agreement (new document)
6. Collateral Assignment of ARR Participant in HUD Parcel to lender as consented to by
Agency (new document)
7. Agency Grant Deed to ARR Participant/Qualified Homebuyer (minor changes)
8. Agency MAP Documents With Qualified Homebuyer (if Agency MAP used by Qualified
Homebuyer) (minor changes to these documents except in cases where Agency low-
moderate income housing funds are used to extend "Affordability Period" to 45 years)
8B2002:16867.\
3