BROADCAST EMAIL – Regulatory Update

July 21, 2015

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, CARH 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.  We discussed many of these issues at CARH’s Annual and Midyear meetings, Board meetings, and in regular communications from members and state affiliated associations.

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. 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.

Time to collect information is limited so we would appreciate all responses by no later than August 7, 2015. While we understand many of the issues based on past meetings, we want to ascertain if additional concerns have arisen or if the same issues remain. We will convey the feedback we receive to USDA for hopefully action and resolution and to assist in improvements to the multi-family programs.

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