Comment submitted by Bernard P. Gawley, Ziegler Financing Corporation

1. 242.33 Covenant for malpractice, fire and other hazard insurance. There should be language included to ensure that appropriate amounts of insurance funds are funded? State pools should be acceptable Offshore insurance accounts should be acceptable if approved by HUD. Risk retention groups and captive insurance companies should be acceptable if approved by HUD. The regs should address whether of not the insuracne carriers meet minimum rating standards? 2. 242.21 and 242.45 Refund of Fees and Prepayment of Inspection Fee ? The Regs should address whether the portion of the inspection fee that is related to pre-commitment work or early start be refundable even if the conditions described in 242.21 are met as the government has expended resources prior to the initial closing at the request of the hospital3. 242.91(c) Mortgage Term .. The discussion is confusing regarding the term length of a section 223(a)(7). It appears from the reading that in certain cases the term could be 35 years if the current mortgage has 23 years remaining plus the additional 12 years. Ziegler Financing Corporation