BROADCAST EMAIL – Regulatory Update

August 3, 2015

As noted in a broadcast email dated July 21, USDA’s Office of General Counsel (OGC) is currently reviewing legal documents to improve RD’s closing procedures and documents, to hopefully streamline preservation and new construction transactions. As you know, CARH members are actively working on preserving Section 515 and 514 multifamily and farm labor housing throughout the country. As part of preservation, and in some cases new construction, members are closing new loans with third party lenders and transferring existing loans. All of these procedures mean that CARH members regularly access multi-family closing documents and procedures.

While we understand many of the issues based on past CARH meetings and communications from members and state associations, we want to ascertain if additional concerns have arisen or if the same issues remain. We will provide the feedback we receive to USDA for hopefully action and resolution and to assist in improvements to the multi-family programs.

If you have not already done so, please email CARH at carh@carh.org with issues which you may be experiencing or have experienced while working on transactions, and suggestions and recommendations that we might pass on to USDA’s OGC.  Examples of issues you may raise are local requirements or differences needed in the RD 515 subordination agreements. The time to collect information is limited and the deadline for all responses is Friday, August 7, 2015.

Please contact the CARH national office at carh@carh.org or 703-837-9001 should you have questions or concerns.