Chapter 3: Commit to Project and Construct Units

Once the PJ has reviewed the HOME-LIHTC application and makes a decision to fund a project, it must take certain steps to secure that funding commitment, and must ensure that the property is constructed in accordance with applicable HOME requirements. This chapter reviews the requirements that apply to a HOME-LIHTC project during the project commitment and construction phases of development. Specifically, it reviews:

Environmental Review

HOME projects, unlike LIHTC projects, are subject to certain Federal environmental review requirements. Therefore, when HOME funding is invested in a tax credit project, the PJ must undertake an environmental review. The presence of tax credits presents important timing issues that the PJ must consider. LIHTC projects are under strict deadlines to meet carryover commitments and for placement in service. To ensure the LIHTC project meets these deadlines, the PJ must be sensitive to the LIHTC time constraints and undertake the environmental review as quickly as possible.

Environmental Review Requirements

Before a PJ can commit any HOME funds to a project, it must conduct an environmental review in accordance with 24 CFR Part 58 (also known as a “Part 58 review”) to ensure that the proposed project does not negatively impact the surrounding environment and that the property site itself is safe for development. The PJ and LIHTC owner are prohibited from taking any “choice limiting action” on the project (such as acquisition, demolition, or construction) until the environmental clearance is secured.

The environmental review is not generally required for the LIHTC program, and therefore it will not have been completed prior to the LIHTC owner’s application to the PJ for HOME funding. Under most tax credit project funding circumstances, the PJ will be considered the Responsible Entity (RE), and the release of funds must be approved by HUD.

PJs may also be subject to state or local environmental review laws. State or local requirements do not pre-empt the Federal standards. Both sets of requirements must be met. Generally, adherence to the more stringent standards (usually the Federal standards) can help to achieve compliance for both.

For more information on the PJ’s responsibilities in performing its environmental reviews in accordance with 24 CFR Part 58, see HUD Notice CPD-01-11, Environmental Review and the HOME Investment Partnerships Program , issued July 17, 2001, and available on the HOME Program website at https://www.hud.gov/program_offices/comm_planning/affordablehousing/programs/home/.

Determining the Level of Environmental Review

The environmental review process is the same for a HOME-LIHTC project as it is for any project that has HOME funding alone. HOME-LIHTC projects most likely will be classified as one of the following:

• Subject to an environmental assessment (24 CFR 58.36). Multifamily new construction, conversion, or substantial rehabilitation projects are subject to a full environmental assessment, known as the NEPA Environmental Assessment (EA). An Environmental Impact Statement (EIS) may be triggered as a result of the EA, but this is not common among tax credit projects. It is unlikely that an EIS could be completed within the strict deadlines under the LIHTC rules, and such projects are not likely to be awarded credits until the environmental issues are resolved.
  
  Note: Part 58 defines “major rehabilitation” to include projects where the costs of rehabilitation exceed 75 percent of replacement cost, the project increases density by more than 20 percent, or the project converts nonhousing space to housing use.



• Categorically excluded from NEPA requirements (24 CFR 58.35). Existing residential projects that are subject to only minor rehabilitation and do not involve increases in density or changes in use are generally classified as “categorically excluded,” and are subject to only Part 58.5 and 58.6 authorities (commonly referred to as the “non-NEPA requirements” or the “Statutory Checklist”). If no environmental compliance issues are found, the project may be converted to exempt (24 CFR 58.34(a)(12)).

Timing for the Environmental Review in a HOME-LIHTC Project

In any project, it is desirable to secure the environmental review quickly because no activity on a project can move forward until it is complete. However, if a project has an LIHTC allocation or that allocation is imminent, PJs will need especially to commence with the environmental review and determine the environmental classification of the project quickly. LIHTC projects are under strict deadlines to meet carryover and for placement in service requirements. Since PJs cannot commit funds and the developer cannot undertake “choice limiting activities” before clearance is secured, PJs need to be able to move quickly to conduct the review, so as not to jeopardize the developer’s ability to meet tax credit deadlines.

• For some projects, there may be time-saving steps the PJs can take when initiating the environmental review process:
• For projects with other Federal assistance in addition to HOME, there may be opportunities to cooperate on the environmental review with other state or local entities that might also need to conduct environmental review for the other Federal funding source(s).
• For projects that are planned for multiple phases (because of tax credit availability or market absorption issues), aggregation is encouraged under Part 58. Aggregation enables the PJ to conduct the review of the entire project up-front. It gives a better picture of environmental impact, and it might save time in review of later phases.

HOME Written Agreements and Legal Documents

When underwriting is complete and environmental clearance is secured, the PJ is ready to execute a HOME written agreement and other legal documents that detail the HOME requirements and enable the project to proceed. In addition to the HOME written agreement and other legal documents required by the HOME Program, in a HOME-LIHTC project, the PJ also should review a set of project agreements and documents related to the LIHTC transaction. This is critically important so that the PJ can understand the structure of the LIHTC deal and ensure protection of HOME Program interests. Tax credit projects tend to be complex deals with multiple legal agreements.

PJs will need to analyze the following agreements:

• Use restrictions imposed by the allocating agency and perhaps other lenders
• Joint venture agreement, if the project involves multiple development partners
• Partnership (or syndication) agreement between the developer and the investors
• Inter-creditor agreement(s) between the lenders, including the PJ.

The PJ’s legal counsel with expertise in both real estate law and tax law should be involved in the review of these documents.

HOME Written Agreement

HOME requires the PJ to execute a written agreement with all recipients of HOME funds. Mortgage and loan documents are not sufficient to meet this requirement. The HOME written agreement must convey HOME requirements and impose enforcement provisions; it can also be a vehicle for the PJ to clarify roles and responsibilities, and establish terms and conditions that will enhance its asset management during the affordability period.

The HOME written agreement is the basis of making a commitment of funds. It precedes other legal documents that are recorded at closing, including the note and mortgage (or deed of trust) and the required deed restrictions. PJs may have different terms to refer to the commitment document for rental projects. The most common terms are the “loan commitment” or “project funding agreement.”

Provisions in a HOME Written Agreement with a Developer

The written agreement should describe all of the requirements of the HOME Program with which the developer must comply. Certain required provisions of the HOME written agreement with owners, developers, and sponsors of HOME-assisted housing are specified in the HOME Rule at 24 CFR 92.504(c)(3), as follows:

• Use of HOME funds
• Affordability requirements
• Project requirements (rental and tenant provisions)
• Property standards
• Other program requirements (such as affirmative marketing, relocation, etc.)
• Records and reports
• Enforcement of the agreement
• Disbursement of funds provisions
• Duration (affordability period)
• If a CHDO project, CHDO provisions.

In addition to these required provisions, the PJ should incorporate additional provisions that facilitate monitoring and asset management, including:

• Definition of roles and responsibilities
• Procurement
• Performance standards
• Project audit or cost certification
• Buyout provisions (discussed in more detail in Chapter 6).

It is very important that the PJ have a clear understanding of how the owner will meet the HOME requirements. The written agreement should include strong enforcement provisions, to ensure that the PJ can enforce the HOME affordability requirements for the duration of the affordability period. In a HOME-LIHTC project, if the HOME affordability period is longer than the 15-year LIHTC compliance period, the PJ should evaluate whether it needs to tailor its enforcement provisions to the specific project. Chapter 6 of this guide discusses exit strategies LIHTC investors might use upon expiration of the LIHTC compliance period, and how these might impact HOME compliance. The PJ should become familiar with the investor’s exit strategy and determine if it needs to document any mitigating strategy in the HOME written agreement.

More information about developing HOME written agreements with owners, developers, and sponsors of HOME-assisted housing is forthcoming from HUD. When available, these guidebooks will be posted at https://www.hud.gov/program_offices/comm_planning/affordablehousing/programs/home/.

HOME Deed Restriction or Covenant

In addition to requirements and restrictions in the HOME written agreement, the HOME Rule at 24 CFR 92.252(e) requires the PJ to impose a deed restriction or covenant running with the land (or some other legal mechanism approved by HUD) that places specific use or other restrictions on the property. This use restriction is needed to impose HOME requirements throughout the period of affordability, even in the event the HOME loan is repaid. The deed restriction or covenant should be a stand-alone document that is properly recorded as part of the closing package and is received by the PJ after recording. Do not put the use restrictions in the mortgage or loan documents.

Recording the HOME Covenant

It is imperative that PJ staff verify that this legal mechanism is duly recorded to preserve its rights.

The PJ should also require that the HOME restrictive covenants be recorded before mortgage documents are recorded to ensure their enforceability and survivability.

For a HOME rental project, the deed restriction or covenant imposes the following requirements:

• Designation of HOME-assisted units (24 CFR 92.252(j))
• Occupancy of assisted units (24 CFR 92.216(a) and 92.252(a) and (b))
• Initial and ongoing rent restrictions (24 CFR 92.252(a) through (c) and (f))
• Tenant eligibility (24 CFR 92.203 and 92.252(h) and (i))
• Period of affordability (24 CFR 92.252(e)).

Some PJs also incorporate property standards under 24 CFR 92.251 in this document. The PJ may also choose to incorporate its authority under zoning ordinances and local and state building codes to condemn a unit or building, fine an owner, or take possession of a property.

Note and Mortgage

Typically, a note and mortgage (or a deed of trust in some states) and other loan documents are signed at closing and recorded. The note (also known as a promissory note) sets out the specific terms of the loan (interest rate, term, payment schedule); and the mortgage provides the lender a security interest in the property.

For HOME rental projects, a note and mortgage are not sufficient to meet regulatory requirements for a written agreement or to convey the HOME requirements. The HOME Program requires the use of a deed restriction to secure the HOME affordability requirements throughout the affordability period, as discussed in the previous section.

Nevertheless, a note and mortgage (or deed of trust) may be important and valuable tools for the PJ to secure its lien position to claim repayment of the HOME funds in the event of foreclosure, noncompliance, or other outcomes. Therefore, while not required by regulation, a note and mortgage should be considered by PJs in discussion with legal counsel.

If such documents are used, the PJ should ensure that they are recorded, and that copies of all closing documents, including agreements between other lenders and the owner/sponsor, are received after recording.

Locally-Imposed Affordability Period

The PJ can opt to establish a longer period of affordability than that required by HUD. If the PJ does this, it is prudent to record two deed restrictions or covenants— the first to secure the HOME requirements and the second to establish the additional time period that is locally-imposed. Using two agreements ensures that the PJ does not inadvertently extend the period during which it might be subject to repay HOME funds to HUD in the event of noncompliance. After the end of the affordability period required by the HOME Rule, the local PJ specifies what requirements apply.

Foreclosure-Proof Restrictions

In a foreclosure, the HOME Rule allows the affordability restrictions required by the HOME Rule to be removed before the primary lender takes the property. This is a way of permitting lenders to maximize the amount of investment recouped in the event of a default and can remove concerns private lenders may have about participating in the HOME Program. Notwithstanding the termination of affordability restrictions conveyed to a lender due to foreclosure or transfer in lieu of foreclosure, the PJ must repay the HOME account because the project has not met the affordability requirements for the full affordability period.

The PJ may wish to include in its agreement with the owner, a right of purchase, right of first refusal, or other preemptive rights to help it reclaim the property in the event the property defaults to avoid foreclosure and loss of the affordable units.

For a complete discussion of this issue, see HUD’s HOMEfires, Vol. 5 No. 2, issued June 2003. This is available on the HOME Program website at https://www.hud.gov/program_offices/comm_planning/affordablehousing/programs/home/.

Other Use Restrictions

The LIHTC program, and potentially other public funding sources, also imposes use restrictions. These may be slightly different from those imposed by HOME. The PJ should review the LIHTC use restrictions to:

• Determine if there are any possible conflicts with the use restrictions imposed by HOME. The key differences between the affordability requirements of HOME and LIHTC are discussed throughout this guide. PJs should be aware of differences in income levels, rent limits, property standards, and over-income requirements.
• Identify any priority of these use restrictions over HOME, and possible compliance conflicts. PJs should also determine if there are opportunities for the various enforcement entities to cooperate in enforcing restrictions and doing workouts. These should be addressed in the inter-creditor agreements discussed below.

It is prudent to record separate deed restrictions or use agreements to impose the affordability requirements of each program , so that the PJ does not inadvertently extend the requirements of both programs throughout the period of compliance of the other program.

Development Entity Agreements

By nature, LIHTC ownership entities are complex. At a minimum, there is likely to be an agreement between the general partner (the developer) and limited partners (the investors). This is usually called the “Partnership Agreement.” Sometimes, there are multiple general partners, especially in cases where CHDOs and other nonprofits team with for-profit developers.

While it is not the responsibility of the PJ to review the legality of these agreements, it is important that the PJ review these agreements to identify issues that may affect the ability of the project to comply with HOME requirements, to remain viable for the HOME affordability period, and to repay the HOME investment under various circumstances.

Partnership or syndication agreements are executed between the general partner(s) and the investors; they document the terms under which the limited partner investments will be made. Some of the key items to review are:

• Performance obligations and guarantees of the developer
• Residual interests and buyout provisions at the end of the partnership. These are discussed in more detail in Chapter 6.

CHDO Joint Venture Negotiation Tips

See Tool 5 in the CHDO Survivor Kit in the HOME Model Guide series for some tips on negotiating joint ventures and executing joint venture agreements. This guide is available on the HOME Program website at https://www.hud.gov/program_offices/comm_planning/affordablehousing/programs/home/.

In projects where there are multiple general partners, there is typically a joint venture agreement or other legal agreement between the partners. This agreement governs how the roles, responsibilities, risks, and fees are to be divided. This is important because it specifies how the entity will implement the project. It should be reviewed by the PJ to determine if everything is clearly laid out.

PJs need to review carefully those joint venture agreements that involve CHDOs. 24 CFR 92.300(a)(1) specifies that CHDO set-aside funding may only be provided to projects in which the CHDO is the managing general partner. HUD’s requirement is that the CHDO must have 51 percent interest in this joint venture entity, and be in control of the key development decisions. PJs need to review the joint venture agreement to determine if the CHDO has the controlling interest and control of the decision-making process.

CHDO Joint Venture Negotiation Tips

See Tool 5 in the CHDO Survivor Kit in the HOME Model Guide series for some tips on negotiating joint ventures and executing joint venture agreements. This guide is available on the HOME Program website at http://www.hud.gov/homeprogram/.

Some CHDOs and nonprofits are inexperienced with tax credit projects, and may not negotiate agreements that adequately protect their interests or controlling rights. While the primary focus of PJ review should be on the regulatory compliance issue, PJs may want to use this opportunity to provide technical assistance to these organizations to help them negotiate better partnerships in the future.

Inter-Creditor Agreements

Many LIHTC projects involve multiple lenders, both public and private. Typically, a private lender provides a first mortgage, and one or more public lenders or intermediaries provide gap financing – construction, bridge, and permanent. With multiple lenders involved, there is a need to determine issues that arise among and between the creditors. These are documented in an Inter-Creditor Agreement.

Some of the key inter-creditor issues are:

• Lien priority. The lien position is critically important to PJs because of the requirement to repay the HOME funds in the event the project is foreclosed upon or otherwise fails to achieve completion and compliance (see 24 CFR 92.503(b)). If there is a foreclosure, lien holders are paid in order of lien priority, so the lower the PJ’s lien position, the greater the risk it will not recover all of its HOME funds. The PJ should negotiate the highest lien position possible, particularly when there are multiple subsidy lenders involved in a project. An emerging trend is for multiple subsidy lenders to agree to a pari passu lien structure, where the lien position and rights are shared to simplify legal negotiations and documents. Exhibit 3-1 provides an example of this.

Exhibit 3-1: Example of Pari Passu

Consider a project where the HOME PJ and a CDBG grantee share a second lien position behind the private 1st mortgage lender on a deal that has outstanding balances on the mortgages at the time of foreclosure as follows:

$2,500,000 - 1st mortgage private lender shared 2nd mortgage

$ 500,000 - shared 2nd mortgage HOME PJ

$ 500,000 - shared 2nd mortgage CDBG grantee

The 1st mortgage lender forecloses and sells the property at auction for $3,000,000. The 1st mortgage holder gets the first $2,500,000, reflecting its first lien position. The remaining $500,000 is split on a pro rata basis between the HOME PJ and the CDBG grantee, providing each with $250,000.

• Disbursement order and procedures. Most lenders and developers assume that public funds like HOME should be the first disbursed to a project, as these funds usually have the lowest interest rates. However, the first dollars disbursed are the riskiest dollars in the project. The PJ has a number of competing needs to balance when negotiating this point. To equally share risk with the other investors, the PJs may want to seek pro-rata distribution from the various sources. By investing HOME funds early in the construction process, however, the PJ may be able to reduce the need for construction financing, thereby reducing the cost of the project, and reducing the overall need for HOME funds. Additionally, if the PJ funds are invested early and the contribution of equity from the LIHTC investor is delayed, this may result in a higher price for the tax credits (as discussed in Chapter 2).
• Enforcement of provisions. The PJ needs to be able to enforce all HOME rules, both during construction and in occupancy. Typical subordination requirements limit a junior lien holder’s ability to enforce provisions without the consent of the senior lien holder. This needs to be resolved in advance. Senior lenders will need assurance that rule enforcement will not jeopardize the viability of the project.
• Foreclosure rights and procedures. In the event of default and foreclosure, the senior lender usually wants to reserve all rights to itself, and to be able to proceed as necessary toward foreclosure, unfettered by junior lien holders. However, PJs need to communicate their repayment risk in the event of foreclosure, and secure agreement with the senior lien holder to give the PJ rights to prevent foreclosure or take action in lieu of foreclosure to ensure continued affordability. Senior lien holders cannot be expected to have endless patience, but may accept terms which provide for a notification of delinquency to the PJ and forbearance on foreclosure for a short period of time to allow the PJ to intervene, correct the default, and even assume or assign control.

These and other issues are usually contained in an inter-creditor agreement, which must be negotiated among the lien holders. PJs should not assume that the other lenders understand the repayment risk of the PJ. PJs need to communicate this issue to the lenders, and negotiate for the rights the PJ needs to protect its interest.

Inter-creditor negotiations also might address longer-term control issues, including balloon debt, partnership buyouts, and other long-term strategies. This is important to a PJ. A newly constructed tax credit project has a HOME compliance period of 20 years, while the partners can be bought out in 15 years, and the senior debt might be structured to this term. This issue is explored in more detail in Chapter 6 of this guide.

Chapter 3: Commit to Project and Construct Units 100

Property Standards

The HOME Program has multiple requirements with regard to property standards and condition, and these generally exceed what is required for the LIHTC program. Therefore, the PJ should make sure the LIHTC developer understands these requirements, and that any adjustments to the plans and specifications are made accordingly.

Codes and Standards

At the conclusion of construction or rehabilitation, HOME-funded properties must comply with applicable codes and standards. The property codes that are applicable to HOME-LIHTC projects include:

4 Since the promulgation of the HOME Program regulations, these code issuing agencies have merged to form the International Code Council (ICC). The model codes used for the HOME Program are no longer being updated. In their stead, the ICC has issued the International Building Code. HUD will consider whether changes to the HOME regulations incorporating the International Building Code are appropriate. The HOME Program website provides updated information on all HOME requirements. (See http://www.hud.gov/homeprogram/. ) For more information about the International Building Code, see http://www.iccsafe.org.

While most of the codes and standards are established outside of the HOME Program, each PJ must develop written rehabilitation standards to apply to all HOME-funded rehabilitation work. These standards define the quality and functionality of a property upon completion of rehabilitation. They include the methods and materials to be used when performing rehabilitation activities, but can also include other elements preferred or required in rehabilitation, including standards for energy efficiency and useful life of structure and systems.

While the LIHTC program does not impose property standards on new construction or rehabilitation, some states impose property standards through the QAP (such as Energy Star). LIHTC requires ongoing inspections based on the HUD Uniform Property Conditions Standards at 24 CFR 5.703.

Accessibility Requirements

HOME-funded programs are subject to several Federal laws governing accessibility for persons with disabilities. Key among these are:

• Section 504 of the Rehabilitation Act of 1973 (24 CFR Part 8) ? Fair Housing Act, as amended (24 CFR Part 100).

Generally, these laws ensure that individuals with disabilities have access to programs and activities that receive Federal funding, and impose structural requirements for the design and construction of housing. LIHTC projects are subject to the Fair Housing Act requirements, but they are not subject to Section 504. PJs must be certain that HOME-LIHTC properties meet the requirements of both laws.

The technical specifications required by Section 504 apply the Uniform Federal Accessibility Standard (UFAS), which is generally a higher standard of accessibility than that imposed by the Fair Housing Act. Since UFAS does not typically apply to tax credit units, it is important for PJs to be sure that architect and construction contractors of the HOME-LIHTC project understand the specific UFAS standard for any units that are designated as accessible to meet the Section 504 requirements.

In addition to the design and construction standards, Section 504 requires that the PJ's program, when viewed in its entirety, be readily accessible to, and usable by, persons with disabilities. This requirement may have some operational implications for the property’s management (such as requirements for accommodations for persons with disabilities, and defining disability).

Lead-Based Paint Requirements

When the HOME-assisted project involves rehabilitation of a property that was constructed prior to1978, the rehabilitation is subject to the lead-based paint regulations at 24 CFR Part 35.5 The LIHTC program does not specifically impose lead-based paint rehabilitation standards. However, tax credit properties are subject to the HUD Uniform Property Conditions Standards (UPCS) and all tax credit properties (including pre-1978 properties) are subject to ongoing inspections and paint maintenance requirements.

A HOME-LIHTC project must meet the lead-based paint requirements of both programs. In general, the HOME lead-based paint requirements are more stringent than those imposed by LIHTC. These requirements vary, based on the amount of Federal rehabilitation assistance per unit, as summarized in Exhibit 3-2.

Exhibit 3-2: Summary of Federal Lead-Based Paint Requirements

Exhibit 3-2: Summary of Federal Lead-Based Paint Requirements

5 Some pre-1978 properties may be exempt under 24 CFR 35.110, including properties that are LBP-free or LBP-removed, zero bedroom units, and rehabilitation that will not disturb any painted surfaces.

Ongoing maintenance requirements also apply to HOME rental projects during the affordability period, and are discussed in Chapter 5.

Enforcement of Labor Standards during Construction

The HOME Program imposes certain labor standards during construction. None of these standards typically apply in an LIHTC-only project; therefore, the PJ must be sure that the LIHTC owner understands and complies with these requirements. The HOME labor-related requirements are summarized in the last section of this chapter. Among the requirements are Equal Employment Opportunity, Minority and Women Owned Business Enterprise outreach, Davis-Bacon labor standards for projects of 12 or more HOME-assisted units, and Section 3 requirements for awards over $200,000 and construction contracts over $100,000.

Inspections

Property inspections during construction and upon completion are important to document compliance with property standards, and conformance to approved plans and specifications, and to verify the basis of payments. When there are multiple funders involved, it is recommended that the involved parties coordinate the inspections. However, PJs need to rely on inspections done by persons who have a programmatic relationship with the PJ. Particularly because the HOME property standards are more stringent than the LIHTC property standards, the PJ cannot rely on the state allocating agency to inspect on the PJ’s behalf.

The following inspections are recommended for a HOME-LIHTC project:

• Progress inspections. During construction, and at least at every point in the contract when payment is requested by the contractor, the property should be inspected to verify that:
• Stated work is completed to justify payment.
• The contractor is complying with all applicable work, labor, and contracting provisions.
• Work complies with safe work practices and the interim controls or abatement requirements of the job, if lead-based paint rules apply.
• Final inspections. At the end of construction, a final inspection(s) is needed to:
• Verify completion of the scope.
• Determine the punch list of uncompleted items.
• Obtain certificates of occupancy.
• Certify compliance with applicable standards prior to occupancy.
• Approve release of retainage.

Close-Out and Completion

PJs should have well-established procedures for closing out projects; and the state allocating agency will also have well-established close-out procedures. The LIHTC owner will have to satisfy the close-out requirements of both agencies. Typical closeout procedures include collecting: all permits, inspection reports, warranties, as-built drawings and other documentation of completion; and final disbursement records, releases of liens, and cost certification or project audit, as required. Cost certification is required by the LIHTC program.

Under HOME rules, a project must be closed out within 120 days of the final disbursement. A project is not completed for purposes of closing out the project in the Integrated Disbursement and Information System (IDIS) until it is fully occupied by income-eligible tenants. Chapter 4 discusses the process of closing out the project upon occupancy.

PJs also should use this opportunity to check in with all other funders to ensure that full compliance with all requirements has been achieved. Disputes with other funders can delay final closing or cause financial hardships.

Summary of Federal Requirements

Many, but not all, of the requirements related to project commitment, construction, and completion have already been discussed in this chapter. Below is a summary chart of all of the Federal Requirements that apply to HOME projects. In general, these other Federal requirements do not apply to LIHTC projects. The PJ should inform and educate the LIHTC owner about these requirements, and provide sufficient monitoring to ensure compliance.

Federal Requirements for HOME Rental Projects

Federal Requirements for HOME Rental Projects

Federal Requirements for HOME Rental Projects

Federal Requirements for HOME Rental Projects