Comment suggests clarification in the utilization of HOME administrative funds when the mortgage being foreclosed was a HOME loan submitted by Carol Seaman, Pinellas County Community Development

Agency : HOUSING AND URBAN DEVELOPMENT DEPARTMENT Title : HOME Investment Partnerships Program; Amendments to Homeownership Affordability Requirements Subject Category : Grants: Home Investment Partnerships Program; homeownership affordability requirements; amendments Docket ID : 2501-AD06 CFR Citation : 24 CFR 92 Published : November 22, 2004 Comments Due : January 21, 2005 Phase : RULES -------------------------------------------------------------------------------- Your comment has been sent. To verify that this agency has received your comment, please contact the agency directly. If you wish to retain a copy of your comment, print out a copy of this document for your files. Please note your REGULATIONS.GOV number. Regulations.gov #: EREG - 1 Submitted Jan 11, 2005 Author : Ms. Carol Seaman Organization : Pinellas County Community Development Mailing Address : 600 Cleveland St., Suite 800 Clearwater, FL 33755-4159 US Attached Files : Comment : The prohibition against using HOME funds to acquire a unit that has a HOME mortgage at a foreclosure sale is a problem. There may be a need for rehabilitation or possibly other fees or costs associated with the foreclosure action. At a minimum there will be costs associated with changing the locks and transferring the property to another eligible homebuyer. If there is a need to make repairs before the property is transferred to a new buyer, there will be a need to obtain property insurance during this period. Efficient portfolio management must allow the use of additional funds to protect the initial investment. These costs would be added to the mortgage amount for the new homebuyer. If the regulation's intent is to permit the pj to use HOME administrative funds in this instance and then reimburse them when the property is sold, it needs to clarify that this is permissable when the mortgage being foreclosed was a HOME loan. Pinellas County Community Development