FOR YOUR INFORMATION
I consult with owners and managers on the full range of 515 issues:
appeals related to OIG audits; Workout Plans; appeals of adverse RHS
decisions; issues with the Agency; and, prepayments and equity loans.
I have the following comments on the program:
OUTSIDE EQUITY LOAN & PREPAYMENT. The Agency now permits an equity loan
to be funded by a conventional lender. Thus, it may not be necessary to wait
for an equity loan. With the Agency outlook on RA, however, it may be best
to
strongly consider prepaying.
OIG AUDIT. Equity Skimming and Identity of Interest are major issues in
the program. Look for increased OIG Audits, Investigations and indictments.
And, look for increased Agency concerns.
RA. Without sufficient RA and with the Agency looking upon RA as a
declining resource, it may be time to consider how best to protect project
owners against the loss and unavailability of RA. That is, there may be no
RA
for servicing, no RA for rehab loans, and no RA for equity loans. Suffice it
to say the owners will likely be blamed and held hostage.
I have worked with and advised owners, developers and managers on 515 program issues and problems since 1988. If you have an issue with RHS or on your projects, or don’t have the expertise on your staff, please contact me.