[Federal Register Volume 59, Number 71 (Wednesday, April 13, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-8620]
[[Page Unknown]]
[Federal Register: April 13, 1994]
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of the Assistant Secretary for Housing--Federal Housing
Commissioner
24 CFR Part 290
[Docket No. R-94-1709; FR-3549-P-01]
RIN 2502-AG18
Sale of HUD-Held Multifamily Mortgages
AGENCY: Office of the Assistant Secretary for Housing--Federal Housing
Commissioner, HUD.
ACTION: Proposed rule.
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SUMMARY: This proposed rule sets forth the basic policies and
procedures that govern the disposition of HUD-held multifamily project
mortgages.1 In general, the Department will sell both current
mortgages and delinquent mortgages. HUD will not sell delinquent
mortgages, however, if foreclosure is unavoidable, and the project
securing the mortgage is occupied by low-income tenants who are not
receiving housing assistance but would do so under section 203 of the
Housing and Community Development Amendments of 1978 if HUD foreclosed
upon the mortgage. In addition, mortgages on subsidized properties will
only be sold with Federal Housing Administration (FHA) mortgage
insurance or equivalent tenant protections; mortgages for unsubsidized
projects may be sold without FHA insurance.
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\1\ This rule, and the policies contained in this rule are
intended to satisfy HUD's obligations under the settlement agreement
in Walker v. Kemp, No. C 87 2628 (N.D. Cal.) with regard to the
Exhibit B mortgages.
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DATES: Comments are due June 13, 1994.
ADDRESSES: Interested persons are invited to submit comments regarding
this rule to the Rules Docket Clerk, Office of General Counsel, Room
10276, Department of Housing and Urban Development, 451 Seventh Street,
SW., Washington, DC 20410-0500. Communications should refer to the
above docket number and title. Facsimile (FAX) comments are not
acceptable. A copy of each communication submitted will be available
for public inspection and copying between 7:30 a.m. and 5:30 p.m.
weekdays at the above address.
FOR FURTHER INFORMATION CONTACT: Frank Malone, Director, Office of
Preservation and Property Disposition, Office of Housing, Room 6164,
Department of Housing and Urban Development, 451 Seventh Street, SW.,
Washington, DC 20410, telephone (202) 708-3555. Hearing or speech-
impaired individuals may call HUD's TDD number (202) 708-4594. (These
telephone numbers are not toll-free.)
SUPPLEMENTARY INFORMATION:
I. Background
A. Introduction
The Department of Housing and Urban Development's inventory of
project mortgages is large and growing. The Office of Management and
Budget acknowledged this development by designating multifamily
property and loan disposition as a High Risk Area. To reduce losses to
the FHA fund, to decrease its inventory of project mortgages, to
improve the servicing of these mortgages, and to improve the rental
services provided by properties securing its insured and HUD-held
mortgages, HUD is proposing to resume the sale of multifamily project
mortgages.
HUD's inventory of mortgages has grown significantly since mortgage
sales stopped in FY 1985. As of August 1993, HUD held over 2,400
project mortgages in inventory. (In comparison, HUD's inventory of
mortgages totaled 2300 at the end of FY 1991, 1600 at the end of FY
1989, and 1400 at the end of FY 1987.) In August of 1993, approximately
1,100 HUD-held multifamily residential mortgages with unpaid principal
balances (UPBs) of $1.5 billion were current and 1,200 with UPBs of
$5.6 billion were delinquent. Approximately 874 current mortgages (80
percent of current mortgages) and 310 delinquent mortgages (25 percent
of delinquent mortgages) were subsidized. Current mortgages included
nearly 400 mortgages assigned under Section 221(g)(4) of the National
Housing Act that were current at the time of assignment. Delinquent
mortgages included nearly 300 formerly coinsured mortgages. In
addition, the HUD-held inventory included 44 nursing home mortgages
with UPBs of about $170 million and 10 hospital mortgages with UPBs of
about $110 million.
In the FY 1992 FHA Audit Report, HUD increased its loss reserves to
$11.9 billion for its $43.6 billion of multifamily insurance in force.
One of the aims of HUD's mortgage sales program is to reduce these
projected losses by increasing the number of mortgages returned to
current status and increasing returns to the Federal Government through
mortgage sales.
B. General Policy
In general, the Department will only sell subsidized mortgages with
FHA mortgage insurance or equivalent tenant protections. The Department
may sell unsubsidized mortgages with or without mortgage insurance. In
addition, the Department will sell both current mortgages and
delinquent mortgages. The Department will not sell delinquent mortgages
that it believes cannot be worked out if the projects securing the
mortgages are occupied by low-income tenants who are not receiving
rental assistance but who would be eligible to receive rental
assistance under section 203 of the Housing and Community Development
Amendments of 1978 (HCDA of 1978) if the mortgages were foreclosed upon
by HUD. The Department will sell delinquent mortgages on such projects
that it believes can be worked out. While the Department would not
expect it to be needed, purchasers of such mortgages would retain the
option of foreclosure because the ability to foreclose facilitates
work-out activity.
In accordance with section 203(i)(2) of the HCDA of 1978, a
subsidized mortgage is defined by this rule as a mortgage on a project
which receives assistance under any of the following programs: (1) The
section 221(d)(3) Below Market Interest Rate loan program; (2) the
section 236 Interest Reduction Payment program, (3) a direct loan with
below market interest rates made under section 202 of the Housing Act
of 1959, section 401 and 404(b)(3) of the Housing Act of 1950, or
section 312 of the Housing Act of 1964; (4) the section 101 Rent
Supplement payments program; and (5) Housing assistance payments under
section 23 of the U.S. Housing Act of 1937 in effect before January 1,
1975, or section 8 of the U.S. Housing Act of 1937. Housing assistance
payments under the Section 8 Rental Certificate program (24 CFR part
882, subparts A, B, C and F), and the Section 8 Rental Voucher program
(24 CFR part 887) are excluded in determining whether a project is a
subsidized rental housing project.
Unsubsidized mortgages include mortgages on projects where rents
are partially or wholly subject to market determination rather than
regulation by HUD. Unsubsidized projects include those projects insured
under: (a) Section 207, Multifamily Rental Housing; (b) Section 213,
Cooperatives; (c) Section 220, Urban Renewal; (d) Section 221(d)(3),
Market Rate with Limited Dividend Mortgagors and without Rent
Supplement or project-based Section 8; (e) Section 221(d)(4), Market
Rate, Moderate Income Families; (f) Section 231, Elderly Housing with
Profit-motivated Mortgagors; (g) Section 232, Nursing Homes and
Intermediate Care Facilities with Profit-Motivated Mortgagors; (h)
Section 241, Supplemental Mortgages; (i) Section 242, Hospitals with
any profit motivated mortgagors and all nonprofit mortgagors with
mortgages for which an insurance commitment was issued on or after June
16, 1988; and (j) Section 608, Veteran Housing.
Generally, unsubsidized mortgages are not subject to prepayment
restrictions. However, there are some unsubsidized mortgages which
contain moderate prepayment restrictions. Some of these mortgages
contained prepayment restrictions primarily because their original non-
profit mortgagors received more favorable financing terms. HUD
permitted prepayment only with permission of the FHA Commissioner in an
effort to prevent for-profit mortgagors from using non-profit
mortgagors as agents to secure the more favorable financing terms. HUD
generally granted approval to prepay upon request if no fraud was
evident. Since the potential for fraud occurred at the time of
origination, by the time of assignment, the need for the prepayment
restriction no longer exists. Having approved prepayment liberally
while the mortgages were insured, HUD has no need to continue
prepayment restrictions following assignment when the rationale for the
restriction no longer applies.
Mortgages with moderate prepayment restrictions of this type were
insured under: (a) Section 221(d)(3) Market Rate with non-profit
mortgagors and with no Rent Supplement or Section 8 Assistance; (b)
Section 231, Housing for the Elderly with Non-profit Mortgagors (Public
and Private); (c) Section 232, Nursing Homes and Intermediate Care
Facilities with Non-profit Mortgagors; (d) Section 242, Hospitals with
Nonprofit Mortgagors, where a commitment was issued prior to June 16,
1988; and (e) Title XI, Group Practice Facilities.
Mortgages insured under section 207/223(f), Purchase/Refinancing of
Existing Multifamily Projects, also contain moderate prepayment
restrictions if the commitment was issued after October 8, 1980. For
these mortgages, during the five years following final endorsement for
insurance, prepayment is permitted only with permission of the FHA
Commissioner. The Department has used and continues to use this
prepayment restriction to prevent use of the FHA-insured mortgage as
bridge financing to facilitate condominium conversion.
Because mortgages with moderate prepayment restrictions are not
subsidized mortgages, this rule would authorize HUD to sell these
mortgages without FHA mortgage insurance.
Under this proposed rule, mortgages on formerly coinsured projects
without project-based Section 8 assistance could be sold without
insurance because the projects covered by the mortgages were not
subsidized and did not have prepayment restrictions (except for lock-
out periods permitted for certain bond-financed mortgages).
Sale with FHA mortgage insurance is an uncomplicated way to return
mortgage ownership and servicing to the private sector. HUD's policies
regarding the regulation and monitoring of insured mortgages are well
developed and well known in the housing industry. More importantly,
however, section 203(h)(1) of the HCDA of 1978 prohibits the Secretary
from selling any mortgage held by the Secretary on any subsidized
project unless the project will continue to operate in a manner which
provides rental housing on terms at least as advantageous to existing
and future tenants as the terms of the program under which the mortgage
was insured prior to the assignment of the mortgage to the Secretary.
Selling mortgages with FHA mortgage insurance ensures that existing and
future tenants will continue to enjoy the benefits of the original
subsidized housing program, while avoiding the need to create
alternative methods of providing the tenant protections that the
original subsidized housing program provided. Such alternative methods
would entail complicated financing and servicing mechanisms (as in the
case of a bare legal title sale) or the cooperation of the mortgagor
(as in the case of deed restrictions).
In addition, FHA mortgage insurance facilitates provision of
private capital. Private investors and servicers have expressed
interest in acquiring mortgages in HUD's portfolio. With mortgage
insurance to offset almost all of the risk, private lenders and
investors would be willing to purchase multifamily housing mortgages at
a higher price, while HUD collects mortgage insurance premiums to
protect the Government in the event of loss.
Prior to 1984, HUD enjoyed a low financial default rate on
mortgages sold with insurance. HUD sold 236 mortgages, with mortgage
balances totalling $409.6 million, with insurance under section 207
pursuant to section 223(c) in the period between 1967 and 1984. Of
these mortgages, 95 (with UPBs of $233.3 million) continue to be
insured, 128 are no longer insured as a consequence of repayments,
prepayments, or voluntary terminations of insurance. Only 13 were ever
re-assigned to HUD, triggering the payment of a claim, a default rate
of six percent.
While the sale of mortgages with insurance has numerous advantages,
it also has some disadvantages. Sale of mortgages with FHA mortgage
insurance requires HUD to budget a credit subsidy. Moreover, the sale
of mortgages with FHA mortgage insurance continues HUD's responsibility
to regulate the relationship between the mortgagee and the mortgagor.
Regulation leads to expenditure of government staff time and money that
could be devoted to other purposes.
Selling mortgages without FHA mortgage insurance is also consistent
with government-wide efforts to increase Federal collections, reduce
regulation in favor of competition, use Federal Government personnel
more efficiently, and return functions to the private sector.
Finally, selling mortgages without FHA mortgage insurance is
compatible with the objectives of the National Housing Act which
formulates the goal of ``a decent home and a suitable living
environment for every American family,'' since projects should continue
to provide decent and suitable housing without having a mortgage
insured by FHA.
Tenants in unsubsidized projects with current mortgages would not
be disadvantaged if their project mortgages are sold without FHA
mortgage insurance because, with some limitations, owners of
unsubsidized projects may prepay their mortgages without HUD approval
at any time. Similarly, these owners (with the approval of their
mortgagees) may voluntarily terminate their FHA mortgage insurance.
Under current conditions, prepayment and voluntary termination are
likely to occur when owners refinance existing mortgages to take
advantage of lower interest rates.
Since HUD regulation of these projects can be terminated at any
time, tenants in these projects would be provided rental housing on
terms no less advantageous than those under which the original mortgage
was insured prior to assignment, and they would be no more likely to
suffer displacement. In addition, low-income tenants in projects with
project-based section 8 assistance could continue to receive the
section 8 assistance under existing contracts, even if the mortgage is
no longer insured. This is because, subject to appropriations, it is
current HUD policy to grant extensions of project-based section 8
contracts without regard to the status of the mortgage. Under this
rule, HUD would require that purchasers of mortgages agree not to
induce any project owner to terminate a project-based section 8
assistance contract, and, in the event of foreclosure, to assume any
section 8 contract. Moreover, if an owner terminates the section 8
contract, it is current HUD policy, that, subject to appropriations,
all eligible tenants would receive section 8 certificates or vouchers.
Low-income tenants in projects without project-based section 8 could
apply for certificates or vouchers from their local public housing
authority.
Under this rule, HUD would only sell mortgages with FHA mortgage
insurance to HUD-approved mortgagees. However, this rule would allow
HUD to sell mortgages without FHA mortgage insurance without such a
restriction.
Mortgages sold with FHA mortgage insurance would be covered by the
Multifamily Mortgage Foreclosure Act, which permits HUD to require, as
a condition and term of the foreclosure sale, that the purchaser agree
to continue to operate the property in accordance with the terms of the
original FHA mortgage insurance program. Mortgages sold with FHA
insurance and subsequently foreclosed upon would also be subject to the
property management and disposition provisions of section 203 of the
HCDA of 1978 which provide for the preservation, in whole or part, of
HUD-owned projects for low- and moderate-income persons. To guard
against windfall profits by a mortgagee from the default of an insured
mortgage purchased at a discount, HUD would limit insurance proceeds.
C. Sale of Delinquent Mortgages
In addition to selling current (i.e., performing) mortgages, under
this rule HUD would sell some delinquent (i.e., nonperforming)
unsubsidized mortgages to investors who would assume the responsibility
for bringing the mortgages current, modifying them, refinancing the
property, or foreclosing the mortgage. Under the proposed rule, HUD
would not sell mortgages that it would normally foreclose upon; i.e.,
those mortgages with incurable defaults which are secured by projects
occupied by low-income tenants not currently receiving rental subsidies
but who would be eligible to receive rental assistance under section
203 of the HCDA of 1978 if the mortgages were foreclosed upon by HUD.
Loan restructuring is more desirable than foreclosure from both
HUD's and the tenants' points of view. In foreclosure, projects undergo
long periods of uncertainty, and may suffer from physical decline
because owners lack an economic incentive to invest in improvements,
and from management problems as owners focus attention on economically
viable activities.
At the present time, however, HUD lacks sufficient staff capacity
to restructure a large number of loans. By selling delinquent loans,
HUD would transfer restructuring responsibility to private purchasers
who could swiftly and aggressively restore projects to economic health
and stability. Many more tenants would benefit from swift resolution of
loan delinquencies than from foreclosure, and for this reason, HUD
proposes to sell nonperforming loans.
There are three broad groups of delinquent mortgages suitable for
sale: (1) Formerly coinsured mortgages, (2) mortgages on non-
residential property, such as nursing homes, and (3) other unsubsidized
mortgages. For formerly coinsured mortgages, it was never intended that
HUD would become the holder of the mortgage or the owner of the project
in the event of default. Under the coinsurance program, coinsuring
lenders originally were responsible for foreclosing defaulted project
mortgages and acquiring and disposing of the underlying properties.
However, HUD agreed to convert coinsured mortgages to full insurance
where the coinsuring lender issued GNMA mortgage-backed securities,
subsequently defaulted on its obligations, and was taken over by GNMA.
HUD's agreement to convert coinsured loans backed by GNMA mortgage
securities to fully insured loans accounts for the formerly coinsured
loans that are now in the HUD-held inventory.
Low-income tenants in formerly coinsured projects with HUD-held
mortgages are now potentially eligible for assistance should HUD
foreclose the mortgage or acquire and sell the property. However, most
projects with coinsured mortgages were built for market-rate occupancy.
As with formerly insured mortgages, the Department would not sell those
delinquent coinsured mortgages that it believes cannot avoid
foreclose--i.e., those that have large unresolvable delinquencies, if
those properties are occupied by low-income tenants not currently
receiving rental subsidies who would do so under section 203 of the
HCDA of 1978 if HUD foreclosed upon the mortgage.
Non-residential properties, such as nursing homes, do not have
landlord-tenant relationships and do not qualify for subsidy protection
under Section 203. Loans on these properties are particularly suitable
for a sale, because workout and renegotiation of these mortgages
requires a range of specialized skills and knowledge not widely
possessed by HUD staff.
Finally, while some unsubsidized mortgages will continue to be
foreclosed and the property sold by HUD, many unsubsidized mortgages
will be sold in periodic sales in order more quickly and effectively to
reinstate, refinance, or modify the mortgages and return the projects
to stable operating condition. As noted above, the projects covered by
unsubsidized mortgages to be sold would be occupied by tenants already
paying market rate rental. Since projects would continue to be governed
by market conditions following private mortgage restructuring, mortgage
sales would be unlikely to result in involuntary tenant displacement.
D. Sale of Subsidized Mortgages to State Agencies
In addition to selling mortgages to private investors and FHA-
approved mortgagees, HUD will consider selling subsidized HUD-held
mortgages to interested State and local governments on a negotiated
basis. Section 203(h)(3) of the HCDA of 1978 authorizes negotiated
sales to State or local governments, or a group of investors which
includes an agency of a State or local government provided that: (1)
The terms of the sale include an agreement by the State or local
government, or agency of same to act as mortgagee or owner of a
beneficial interest in the mortgage, and ensure that the project will
maintain occupancy by the tenant group originally intended to be served
by the subsidized housing program; and (2) the sales price is the best
price that the Secretary can obtain from an agency of a State or local
government, while maintaining occupancy for the tenant group originally
intended to be served by the subsidized housing program.
HUD is particularly interested in public comment from State and
local governments as to what criteria HUD should use in determining
whether to sell to State and local governments rather than private
investors.
II. Other Matters
A. Executive Order 12866
This rule was reviewed by the Office of Management and Budget (OMB)
under Executive Order 12866, Regulatory Planning and Review. Any
changes made to the rule as a result of that review are clearly
identified in the docket file, which is available for public inspection
in the office of the Department's Rules Docket Clerk, room 10276, 451
Seventh Street SW., Washington DC.
B. Environmental Impact
In accordance with 40 CFR 1508.4 of the regulations of the Council
on Environmental Quality and 24 CFR 50.20(k) of the HUD regulations,
the policies and procedures contained in this rule relate only to HUD
administrative procedures and, therefore, are categorically excluded
from the requirements of the National Environmental Policy Act.
C. Executive Order 12612, Federalism
The General Counsel, as the Designated Official under section 6(a)
of Executive order 12612, Federalism, has determined that the policies
contained in this rule will not have substantial direct effects on
states or their political subdivisions, or the relationship between the
federal government and the states, or on the distribution of power and
responsibilities among the various levels of government. As a result,
the rule is not subject to review under the order. Specifically, the
requirements of this rule are directed to HUD, and do not impinge upon
the relationship between Federal government and State and local
governments.
D. Executive Order 12606, the Family
The General Counsel, as the Designated Official under Executive
Order 12606, The Family, has determined that this rule does not have
potential for significant impact on family formation, maintenance, and
general well-being, and, thus, is not subject to review under the
order. No significant change in existing HUD policies or programs will
result from promulgation of this rule, as those policies and programs
relate to family concerns.
E. Regulatory Flexibility Act
The Secretary, in accordance with the Regulatory Flexibility Act (5
U.S.C. 605(b)) has reviewed and approved this rule, and in so doing
certifies that this rule will not have a significant economic impact on
a substantial number of small entities. This rule will not affect the
ability of small entities, relative to larger entities, to bid for and
acquire HUD-held mortgages that HUD determines to sell.
F. Regulatory Agenda
This rule was not listed in the Department's Semiannual Agenda of
Regulations published on October 25, 1993 (58 FR 56402) under Executive
Order 12291 and the Regulatory Flexibility Act, and therefore was
submitted to the Committee on Banking, Housing, and Urban Affairs of
the Senate and the Committee on Banking, Finance and Urban Affairs of
the House of Representatives under section 7(o) of the Department of
Housing and Urban Development Act.
List of Subjects in 24 CFR Part 290
Mortgage insurance, Law and moderate-income housing.
Accordingly, 24 CFR part 290 would be amended to read as follows:
PART 290--MANAGEMENT AND DISPOSITION OF HUD-OWNED MULTIFAMILY
PROJECTS AND CERTAIN MULTIFAMILY PROJECTS SUBJECT TO HUD-HELD
MORTGAGES; SALE OF HUD-HELD MORTGAGES
1. The authority citation for part 290 would continue to read as
follows:
Authority: 12 U.S.C. 1701z-11, 1701z-12, 1713, 1715b, 1715z-1b;
42 U.S.C. 3535(d).
2. Section 290.1 would be revised to read as follows:
Sec. 290.1 Applicability.
This part applies to HUD-owned multifamily housing projects and to
rental housing projects that are subject to mortgages held by HUD.
Specific provisions, as noted in the regulatory text, apply only to
``rental housing projects'' as defined in Sec. 290.3, including a HUD-
owned rental housing project.
3. In Sec. 290.3, a definition for ``subsidized mortgage'' and
``unsubsidized mortgage'' would be added in alphabetical order, and
paragraph (5) of the definition of ``subsidized rental housing
project'' would be revised to read as follows:
Sec. 290.3 Definitions.
* * * * *
Subsidized mortgage means a mortgage on a subsidized rental housing
project.
Subsidized rental housing project * * *
* * * * *
(5) Housing assistance payments under section 23 of the United
States Housing Act of 1937 in effect before January 1, 1975, or section
8 of the United States Housing Act of 1937, if:
(i) For purposes of subparts A, B, and C of this part, more than 50
percent of the units in the project are receiving such assistance; or
(ii) For purposes of subpart D of this part, any of the units in
the project are receiving such assistance.
Housing assistance payments under the section 8 Rental Certificate
program, 24 CFR part 882, subparts A, B, C, and F, and the section 8
Rental Voucher program, 24 CFR part 887, are excluded in determining
whether a project is a subsidized rental housing project.
Unsubsidized mortgage means any HUD-held mortgage which is not a
subsidized mortgage.
* * * * *
4. A new subpart D would be added to part 290 to read as follows:
Subpart D--Sale of HUD-Held Mortgages
290.200 Purpose
290.201 Sale of Subsidized HUD-held Mortgages
290.202 Sale of Unsubsidized HUD-held Mortgages
Subpart D--Sale of HUD-Held Mortgages
Sec. 290.200 Purpose.
The purpose of this subpart is to set forth HUD's policy regarding
the sale of subsidized and unsubsidized HUD-held mortgages.
Sec. 290.201 Sale of Subsidized HUD-Held Mortgages.
HUD's policy for selling subsidized HUD-held mortgages is as
follows:
(a) HUD will sell current mortgages with FHA mortgage insurance on
a competitive basis to FHA-approved mortgagees; or
(b) HUD will sell current mortgages on a negotiated basis to State
or local governments, or a group of investors which includes an agency
of a State or local government if:
(1) The terms of the sale include an agreement by the State or
local government, or agency of same to act as mortgagee or owner of a
beneficial interest in the mortgage, and ensure that the project will
maintain occupancy by the tenant group originally intended to be served
by the subsidized housing program; and
(2) The sales price is the best price that the Secretary can obtain
from an agency of a State or local government, while maintaining
occupancy for the tenant group originally intended to be served by the
subsidized housing program.
(c) HUD will sell current mortgages without FHA mortgage insurance
if HUD can offer protections equivalent to an insured sale.
(d) HUD will sell delinquent mortgages only if as part of the sales
transaction those mortgages are restructured and either FHA mortgage
insurance or equivalent protections are provided.
Sec. 290.202 Sale of Unsubsidized HUD-Held Mortgages.
HUD's policy for selling unsubsidized HUD-held mortgages is as
follows:
(a) HUD will sell current unsubsidized mortgages with or without
FHA mortgage insurance.
(b) HUD will sell delinquent unsubsidized mortgages without FHA
mortgage insurance.
(c) HUD will not sell delinquent mortgages if it believes that
foreclosure is unavoidable, and the project securing the mortgage is
occupied by low-income tenants who are not receiving housing assistance
but would do so if HUD foreclosed upon the mortgage.
Dated: March 16, 1994.
Jeanne K. Engel,
General Deputy Assistant Secretary for Housing--Federal Housing
Commissioner.
[FR Doc. 94-8620 Filed 4-12-94; 8:45 am]
BILLING CODE 4210-27-P
