Comment No. 1 - In Section 1710.405(b)(1)(vii) it is not clear when comparing the information in the background section as to whether the interest rate to be charged by the borrowers to the consumers is one percent or Treasury plus one percent. Please clarify in one or both places. I feel a one percent markup over the Treasury-based rates is adequate.
Comment No. 2 - I would like to suggest that RUS rewrite 7 CFR 1721.1(a). It currently reads as follows:
a) Purpose and amount. With the exception of minor projects, insured loan funds will be advanced only for projects which are included in an RUS approved borrower's construction work plan (CWP) or approved amendment and in an approved loan, as amended. Loan fund advances can be requested in an amount representing actual costs incurred.
I would suggest that it be changed to read as:
a) Purpose and amount. With the exception of minor projects, loan funds will be advanced only for projects which are included in a RUS approved borrower’s construction work plan (CWP), EE Program work plan (EEWP), or approved amendment, that have also received written Environmental Clearance and/or Approval from RUS prior to the start of construction, and follow RUS’ contract and bidding procedures as set forth in 7 CFR 1726 if applicable. Load funds advances can be requested in an amount up to the actual cost incurred less any contribution in aid of construction.
In my opinion the regulation needs to be modified to remove the word “insured “ as RUS has different loan programs not all of which are considered “insured” i.e. the Guaranteed Loan Program. Thus if a regulation change is already necessary this would be a great time to make more substantial changes that could decrease some extra paperwork for both the borrowers and RUS employees.
Comment on FR Doc # 2012-17784
This is comment on Proposed Rule
Energy Efficiency and Conservation Loan Program
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