Correspondence Logs - Cruz, U.S. Department of Housing and Urban Development Correspondence (2013-2017)

:lh OLFICE OF CONGRESSIONAL AND INIFRGOVERNMPNIAL RFA FIONS FEB 03 2017 i U.S. DEPARTMENTOF HOUSING AND URBAN DEVELOPMENT re WASHINGTON,DC 20410-1000 a The Honorable DeanHeller United States Senator 400 South Virginia Street, Suite 738 Reno, NV 89501-2125 Dear Senator Heller: Thank you for your inquiry on behalf of the Nevada Housing Division aboutthe state of Nevada’s interest in assuming responsibility for the Western Nevada HOME Consortrum program. The following informationis from ‘the Department of Housing and Urban Development’s Office of Community Planning and Development. The Departmentis currently conducting a review of this matter. A response will be sent to you soon. Thank youfor your interest in the Department’s programs. Sincers a Aaron Santa Anna Acting General Deputy Assistant Secretary Office of Congressional and Intergovernmental Relations wrw.hud.gov espanol.hud.gov

L.S. DEPARTMENT OF HOUSING AND LRBAN DEVELOPMENT WASHINGTON DC 20410 1000 OFTICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RFE ATIONS The Honoiable Dean Heller United States Senator 400 South Virginia Steet, Suite 738 Reno, NV 89501-2125 Dear Senato: Heller: This 15 1m further response to yourletter on behalf of the Nevada Housing Division about the transfer of the Western Nevada HOMEConsortiumprogram to the state of Nevada The fotlowing information 1s from the Department of Housing and Urban Development's (HUD) Otfice of Community Planning and Development. Tn its January 2, 2017. email to youroffice, the state of Nevada requested assistance in oblaining HUD’» feedback on a draft cooperative agreement. which would transfer the monitoring and oversight duties of the Western Nevada HOME Consortiumto the state of Nevada. Thestate of Nevada was concernedthat without HUD’s feedback onthe cooperative agreement, the transfer of the consortium’s HOMEprogramto the state of Nevada could not move forward. and the HOMEprogram income generated by the consortium’s HOMEactivities would continue to accrue without formal oversight. The Department has completed its review of the draft cooperative agreement and provided feedback to the state of Nevada The consortium signed the agreement onJuly 20, 2017, and forwarded if to the state of Nevada for signature. Once the cooperative agreement 1s fully executed, HUD will provide gindance onthe tansfer of the HOMEprogram mcome from the consortium to the state of Nevada. Thank jou for your interest in the Department's progiams If I can beof further assistance, please let me know. Sincerely, / , oF “ ai re fe fe Ap nce — ory ~ yo “ Seth D. Appleton. ActingAssistant Secretary for Congressional and Inte: governmental Relation sw hhud.gos espanol.hud.gov

DEAN HELLER R E C E IV E D coMMITTEEs. NEVADA (202) 224-6244 8y Toray Executive Secretanat 19-44 pm 12417 FINANCE BANKING HOUSING AND URBAN AFFAIRS, ‘Wnited etates ornate COMMERCE,SCIENCE, AND. WASHINGTON,DC 20510 TRANSPORTATION VETERANS’ AFFAIRS SPECIAL COMMITTEE ON AGING January 12, 2017 The Honorable Julian Castro Secretary U.S. Department of Housing and Urban Development 451 7th Street S.W. Washington, DC 20410 Dear Secretary Castro, neers semen eetwe - I write m support of grant applications submitted by the state ofNevada for the Youth t Homelessness Demonstration Program Grant. The collaborative efforts demonstrated by the applicants are clear cases of our respective communities coming together to address, prevent and end youth homelessness. Awarding this grant to a Nevada applicant will prove how communities can successfully implement and achieve comprehensive systemsofcare for homeless youth. In recent years, Nevada has experienced a growing challenge with homeless youth and a lack of resources to address the issue. Population growthin the state, especially growth related to new employerslike Tesla and Resorts World, has placed a strain on housing resources throughout the Reno-Sparks and Las Vegas metropolitan areas. Over the years, our communities have developed a strong network of homeless services agencies for adults, but very few resources have beenavailable for the homeless youth population. I strongly support our Nevada applicants and I thank you for your consideration. Should you have any further questions regarding my support, please do not héS,tate to contact me. ai Sincerely, t DEAN HELLER United States Senator a eae ae

MEATon, Hd i U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT MN . 3 , * WASHINGTON DC 20410-1000 ot 12, i,‘ayoe OFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONS FEB 03 2017 The Honorable Dean Heiler United States Senate Washington, DC 20510-2806 Dear Senator Heller: Thank youforyour letter in support of an application submitted by the state of Nevada for the Youth Homelessness Demonstration Project grant competition. The following informationis from the Department of Housing and Urban Development’s (HUD) Office of Community Planning and Development. On August 22, 2016, the Department made approximately $33 million available, as described in the Fiscal Year 2016 Youth Homelessness Demonstration Program Notice of Funding Availability (NOFA). HUD’s Office of Special Needs Assistance Programs reviewed all applications in accordance with the fair and uniform selection criteria and process described in the NOFA. OnJanuary 13, 2017, HUD announcedthe ten communities selected under this NOFA. Unfortunately, this was a very competitive process and the application submitted bythe state of Nevadadid not score high enough to be selected for the award. Debriefing documentswill be sent to the applicants to advise of the details regarding their score. Thank youfor your interest in the Department’s programs. Please let me know if I can be of furtherassistance. Sincerely,Barbell Aaron Santa Anna Acting General Deputy Assistant Secretary Office of Congressional and Intergovernmental Relations www.hud.gov espanol.hud.gov

Lunted States Senate WASHINGTON DC 20510 October 12, 2017 The Honorable Ben Catson Secretary US Department of Housing and Urban Development 451 7" Street, SW Washington, DC 20410 To Leadets in the Mortgage Industry Asleaders in the mortgage industry, we ask that you do everything in your powerto assist victims and survivors ofthe senseless mass shooting which occurred on October |. 2017, in Las Vegas While victims and survivors face a long road to recovery in terms ofhealing their physical and psychological scars, they mayalso encounter substantial financial burdens that compoundtheir tremendous stress With that in mind, we write to you today to ask that your organizations do whateverthey canto case the burdensthat maybe faced by victims, survivors, and their families at this difficult tume or imthe future Importantly, should the issue arise, we wouldask that you not mitiate or finalize anylegal foreclosure proceedings that would leadto a victim or their family’s eviction during their recovery. If victims and suivivors have difficulty with future mortgage or other loan payments, we ask that you would work with those individuals to olfer tailored solutions. which could include forbearance plans and loan modifications, to help ensure that their financial wellbeing is taken care of Finally, weaskthat you streamline documentation requests and paperwork burdens for any impacted borrowers and dedicate additional staffto process any requests from victims andtheirfamilies. Individuals recovering fiomthe events of October 1™should not have to worry about evictions, late fees. negative credit reports. or any other financial burdens that may exacerbate the tremendous stress caused bythis senseless tragedy We appreciate your attention to these matters and your support for the wider Las Vegas community ma),ll Catherine Cortez Masto DeanTeller United States Senator United States Senator

Wnited States Senate R E C E IV E D tedtat bc a By Metady Brown at 11 36 am, 10/2017 October 12, 2017 The Honorable Ben Carson Secretary U.S. Departmentof Housing and Urban Development 451 7" Street, SW Washington, DC 20410 To Leaders in the Mortgage Industry: —~ Asleaders ii the mortgageindustry, we askThatyoudo everything in your powerto assist victims and survivors of the senseless mass shooting which occurred on October 1, 2017, in Las Vegas. While victims andsurvivors face a long road to recovery in terms ofhealing their physical and psychological scars, they may also encounter substantial financial burdens that compoundtheir tremendousstress. With that in mind, we write to you today to ask that your organizations do whatever they can to ease the burdens that may be faced by victims, survivors, andtheir families at this difficult timeorin the future. Importantly, should the issue arise, we would ask that you notinitiate or finalize any legal foreclosure proceedings that would leadto a victim or their family’s eviction during their recovery. If victims and survivors havedifficulty with future mortgage or other loan payments, weask that you would work with those individuals to offer tailored solutions, which could include forbearance plans and loan modifications, to help ensure that their financial wellbeing is taken care of Finally, weask that you streamline documentation requests and paperwork burdens for any impacted borrowers and dedicate additional staff to process any requests from victims andtheir families. Individuals recovering from the events of October 1* should not have to worry about evictions,late fees, negative credit reports, or any other financial burdens that may exacerbate the tremendous _ -Stress caused bythis senseless tragedy. We appreciate your attention tothese mattersand your support for the wider Las Vegas community. Catherine Cortez Masto DeanHeller United States Senator United States Senator

c D7|HELLER G etaeteR gh|¥ —_ ww (& 125 Cannon House OFFICE BUILDING 202-225-6155 Congress of the United States Bd0- Kase House of Representatives CG - 2< / Washingten, BC 20515-2802 January 13, 2010 Mr.Bernard Fulton Deputy Assistant Secretary for Congressional and Intergovemmental Relations U.S. Department of Housing and Urban Development 45) 7th Street SW, Room 10148 Washington, D.C. 20410-0001 = 3 3 mh ee m- . wee as -—-- “RE:“Nick Séfrano,Sales Manager mS “ly Greater Nevada Mortgage Services ag 4070 Silver Sage Drive am U Carson City, NV 89701 Ao \ Phone: (775) 326-6720 Email: [email protected] Dear Mr. Fulton: \ dlavide J have enclosedcorrespondenceI received from myconstituent, Mr. Nick Serrano, Sales Manager for Thé Greater Nevada Mortgage Services, requesting a status report on their application and approval process to become a Ginnie Maeprovider. I would appreciate any assistance you can provide so I maybe able to respond to my constituent appropriately. If you have questions regardingthis inquiry, please contact: Katie Pace, Outreach Coordinator Congressman Dean Heller 400 South Virginia Street, Suite 502, Reno, NV 89501 Phone: 775.686.5760; Fax: 775.686 5711; Email: [email protected] Thank you for your prompt and courteousassistance. Sincerely, Tidolby DEAN HELLER . : Member of Congress-* « : . le DH/kp Enclosure _ if —79¢ G =~ QOLO~ ASF CG 00! 7O~ksg menomemnen C #t LZ ee wee

~~ GREATER 4070 Silver Sage Drive — NY NEVADA Carson City, NV 89701 Mortgage Services (775) 888-6999 « (800) 526-6999 © gnms.com December8, 2009 The Honorable DeanHeller 400 S.Virginia St., Suite 502 Reno, NV 89501 Dear Representative Heller: | am writing to you on behalf of Greater Nevada Mortgage Services, a subsidiary of Greater Nevada Credit Union. Our company offers affordable home loansto our communities in Nevada andhhas recently _ become the third largest lender in terms of market share for northern Nevada. This is duetoourabilityto offer Nevadansaffordable, local, and stable mortgage lend: an effort to expand ourproduct Jine due jemto-thedemand frrourserviceswesubmittedBiapplication GianiéMaeinordérto support the growing need for FHA, VA, and USDA governmentfinancing. Our approved application would allow us to deliver these productsat affordable rates as well as service home loanslocally for ourclients. Greater Nevada Mortgages Services is seeking your support in helping to expedite the approval process with Ginnie Mae Ourapplication was originally submitted on August 13", 2009 Overthe next several weeks, there was consistent communication regarding outstanding needs to complete our application. On October I, we received correspondencethat no further documentation was needed and that our application would goin line for review by the necessary parties within Ginnie Mae. We were advised that the approval process wouldtake an additional 6 weeks to complete. On November 12", our company requested an update on thestatus of our application with Ginnie Mae and wereceived the same blanket statementthat we had been given six weeks prior. This was disconcerting, so we proceededto place additional calls to Ginnie Mae on November 12", November 20". and December 1* Thesecails all went to voicemail and none have been retumed Greater Nevada MortgageServices is cager to expandourlending in Nevada, Our growth has been rooted in ourclients’ desire to keep their money local with an institution they cantrust Gaining Ginnie Maeapprovalwill allowsus to help more Nevadansfeel secure with their mortgage needs and increase our ability to help with the extended First Time Home Buyer Tax Credit. It would be greatly appreciated if you could help us gain conerete information regarding our application with Ginnie Mae as well as assist in expediting the anticipated approval. Should you have any questions, please do not hesitate to contact ~ —— me. Sincerely, mn Nick Serrano L Sales Manager Greater Nevada Mortgage Services 4070 Silver Sage Drive Carson City, NV 89701 775-326-6720 [email protected] Be Part of Something Greater Member @ Mortgage Bankers IMBAl Assaclation of America tENoEr

AF) (een ae U.S, DEPARTMENT OF HOUSING AND URBAN DEN ELOPMENT WASHINGTON,DC 20410-1000 ASSISTANT SECRE FARY FOR CONGRESSIONAL AND INTERGOVERNMENTAL RET ATIONS APR 02 2010 The Honorable Dean Heller U.S. House of Representatives Washington, DC 20515-2802 Dear Representative Heller: Thank you for yourletter ofJanuary 13, 2010, on behalf of your constituent, Nick Serrano, of Greater Nevada Mortgage Services, tegarding the status oftheir Issuer application with Ginnie Mae. Ginnie Maeplays a critical role in housing finance. The corporation guarantees mortgage- backed secunties (MBS)that are backed by the Federal Housing Administration (FHA), Veterans Affairs (VA), USDA Rural Development (RD), and HUD’sOffice of Public and Indian Housing (PIH). These secunties are only issued by approved institutions that meet Ginnie Mae’sstrict guidelines. In the eventthat a lender cannot makethe monthly principal and interest pass-through payment to mvestors, Ginnie Mae makes that payment. This guaranty heips bring liquidity to the market to help more Americansfulfill their dreamsofsustainable affordable housing. Since Ginnie Mae’s responsibilities are triggered when an Issuer cannot make timely investor payments, potential Issuers undergo a rigorous and lengthy application process before they are admitted into Ginnie Mae’s program.It is Ginnie Mae's responsibility to manage an increasing population of Issuers in a prudent manner. Since the beginning of January 2009, Ginnie Mae has received more than 170 new Issuer applications; this is more than the current numberof active Ginnie Mae Issuers. These applicants are required to submit an independentaudit, meet Ginnie Mae's increased net worth requirements, and undergo a thoroughanalysis of their FHA performancedata. Oncethis process 1s completed, the application is then reviewed by Ginnie Mae executives. The overall process is designed to ensure that the applicant possesses demonstrated expenence, managementcapability, and sound financial, business and managementpractices. Ginnie Mae must conduct appropriate due diligence when reviewing applications to ensure that approved Issuers are good stewards ofthe taxpayers’interests and the U S. Government’s full faith and credit guaranty. Ginnie Mae understands Greater Nevada Mortgage Services’ concemis about the length of the review process, however, the Department wants to assure you and Greater Nevada Mortgage Services that the application 1s receiving the appropriate level of attention Ginmie Maerecently contacted the applicant requesting additional information, and anticipates reaching a dectsion within the next month. www.hud.gov espanol.hud.gov

Thope this mtormaton Is helpful in responding to your consutuent Please let me know if Tcanbe ofturther assistance Sincerely, [ln A Koren Peter A. Kovar Assistant Secretary for Congressional and huergovernmental Relations

~ fay DEAN HELLER i Ca conwirtees NEVADA ENERGY ANDO NATURAL RESOURCES (70212-624 COMMERCE SCIENCE, AND TRANSPORTATION Wnited States Senate manne HOUSING AND URBAN AFFAIRS. WASHINGTON,DC 20510 SPECIAL COMMITTEE ON AGING VETERANS’AFFAIRS June 26, 2013 Mr. Bernard Fulton ' Deputy Assistant Secretary for Congressional Relations U.S. Department of Housing and UrbanAffairs 451 Seventh Street SW, Room 10148 ' Washington, DC 20410-0001 RE: Kb){6) (eye) To Whom {t May Concern, Kb){6) Lhave received the enclosed correspondence from my constituent ‘ PFEXE. concerningdiscriminatory practices by seniorliving communities. Kb){6) Please review the enclosed concems and provide a response to Should you need any further information,please feel free to contact my staff. Thank youfor your prompt and courteousassistance. Sincerely,th DEAN HELLER U.S. Senator

teh be GeOS kcal oe ULL MS Was INGTots Ge 20S 10 WAM AMIS NT SECRETARY LOR CONGKES hole 1 AND INTERGOVTRNMENTAL REL TION AUG 1 2 2013 Kb){6) _ othr BO Senctor Dea deer hos cs. edta | ontG cous ty a SiO] ov opmenttoreply © your leuet of Jui 24, 20a, ohnecH2 sou n la, pre cormmunity wes DB A SD+ senor Livin, Tuy Le pe.t ands clin al co. Us my. 2 ew sd 2 vill novia, you witha final respon.e upon ‘onisleuciaortic tevic ¥ Thana you for put ters Inte OL ke Ms pivlaa ts. Lot he aT Eee phivgl. Lb cos. Arde Ash tiays ctlary. 36 Congressional ‘uo Imergo ounianc) « leuons whtdoe

a a y U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPM 2 wl * WASHINGTON DO 20410 1000 Es ot ASSISTANT SECRETARY LOR CONGRLSSION MI AND INIERGOS ERNMENT AL REL STIONS AUG 1 2 2013 Kb){6) Dear Mr. Senator Dean Heller has asked the Department of Housing and Urban Devetopmentto reply to yourletter of June 24, 2013, concerning alleged discriminatorypractices by a 55+ seniorliving community. The Departmentis currently conducting a review of this matter and will provide you with a final response upon completion of the review. Thank youfor your interest in the Department's programs. Sincerely, Elliot M. Mincber; Acting AsststantSecretary for Cofigressional andIntergoyérnmental Relations wwwhudgov espanolhud.gov

4 U.S. DEPARTMENT OF HOLSING AND URBAN DEVELOPMENT ij a WASHINGTON DC 20410 1000 “i OPTICE OL CONGRESSIONAL AND INTE RGONL RNMENTAL RELATIONS The Honorable Dean Heller SEP 18 2013 United States Senator 324 Hart Senate Office Building Washington. DC 20510 Dear Senator Heller: Kb){6) Thank youfor yout letter dated June 26, 2013, on behalf of your constituent, Mr. Mr. indicatedthat he 1s having difficulty in securing an apartment in a Sand older semorliving community He 1s seeking your assistance in determining tf he and his wife may have been discriminated against because ofher age. The Department’s Office of Fair Housing and Equal Opportunity (FHEO) administratively enforces the Age Discrmmnation Act, which prohibits discrimination on the basis of age in federally funded programs. Mr. letter contains someinformation that may indicate a possible violation of the Act. The Department's FHEO Regional Office in San Francisco, California handles claims of discrimination from the State of Nevada. That Office has responsibility for determining Jurisdiction and, where appropriate, processing and investigating fair housing complaints Mr. [2G correspondence has been referred to that Office, they will contact himto obtain additional information, if necessary. If Mr. as any questions or needs to provide additional information, the Region IX FHEOOffice contact informationis as follows: Ms. Anné Quesada Director, Fair Housing and Equal Opportunity U.S. Department of Housing and Urban Development 600 Harrison Street, 3™Floor San Franciseo, CA 94107 Telephone: 415-489-6536; (Toll Free) 1-800-347-3739 Facsimile: 415-489-6560; TTY/TDD; 415-489-6564 Email Complaints_Office_09@hud gov Thopethe information provided15 helpful in responding to your constituent’ Please let me know if I can beoffurtherassistance. € Elhot M. Mingberg Acting Assistant Secretary$9fCongressional and Intergovernmentak Relations Enclosure wir hud.gov espanol.hud.gov

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGLON DC 20410-2000 ONICE OF 1 AIR HOUSING AND FQUAL OPPORTUNITY Kb){6) Dear Mr,(©) Senator Dean Heller referred your email dated June 24, 2013,to the U.S. Department of Housing and Urban Development concerning your request for assistance addressing your housing situation. In yourletter, you request assistance in securing an apartmentin a 55 andolder senior hving community. You are having difficulty because your wife is younger and youfeel you may have been discriminated against because of her age. Your correspondence has been forwarded to HUDRegion IX Office of Fair Housing and Equal Opportunity (FHEO), San Francisco, California Thatoffice has responsibility for determiningjurisdiction over complaints in Las Vegas Please be assured that the issue you have raised is very importantto us. FHEO administratively enforces federal statutes, executive orders and regulations designed to afford all persons an equal opportunity to live in housing oftheir choice and to participate in HUD-assisted programsand activities without regard to race, color, national origin, sex, religion, familial status (families with children under 18), disability, or age. The FHEO Region IX Office will review your correspondence and contact you directly in the next 15 days to notify you of the next steps You may contact the FHEO Region IX Office at anytimeat the following address and phone number: Ms. Anne Quesada, FHEO Region IX Director U.S. Department of Housing and Urban Development 600 Harrison Street 3nd Floor San Francisco, CA 94107-1300 Telephone 415-4896536 1-800-347-3739 Facsimile 415-489-6560 TTY/TDD: 415-489-6564 Email: Complaints Office 09@hud gov [hopethe information provided 1s helpful. Sincerely, “+fctti Nettie M. Putnam Correspondence Specialist sww.hud.gov espanol.hud.gov

DEAN HELLER NEVAGA ic Ugh £2021 274-6774 Waited States Senate WASHINGTON, PC 20570, June 5, 2014 US DepartmentofHousing and Urban Development 451 7th St S.W Washington, DC 20410 6437 Buttercup Creek Street Murth Las Vegas, New sda 42084 Te Whom It May Concern, ‘coMMITTEES ENERGY AND RATUPAL RESOURCES COMMERCE, SCIENCE, AND TRANSPORTATION BANKING HOUSING AND USBAN AFFAIRS, SPECIAL COMM! “TEE ON AGING VETERANS AFFAIAS I have received the enclosed correspondence from my|2 concerning his neighbors, who are renters through HUD. Thank you for reviewing the enclosed concerns and providing a response to the constituent, Should you need any further information,please feel free to contact mystaff. Thank youfor your promp! and courteous assistance Sincerely, C DF AN HELLER US Senator

: 5 LS. DEPARTMENT OF HOLSING AND URBAN DEVELOPMENT s inhi . . WASHINGION DC 20410 500K OFFICE OF PLBLIC SND INDIAN HOUSING JUL 2S ok Deat Mr Senator Dean Heller has asked the Department of Housing and Urban Development (HUD)toteplyto yourfetter of June 2014, concerning the problem with your neighbors The following information 1s ftom HUD*s Office of Public and Indian Housing (PTH). PIH staff contacted the Southern Nevada Regional Housing Authority (SNRHA) and requested that it investigate the inquiry The SNRHAstates that they have conducted an extensive investigation mtothe matter and have respondedto your complaints However,the SNRHA and HUD cannotprovide the results ofthe investigation to you due to privacy concerns Although the SNRHAreceives funding from HUD, it is governed by the locally- appointed Boatd of Commusstoners under state law and, as such, HUD1s not involved tnits daily operations or decisions Your complaints fall under the purviewof a public housing authority operational issue Thus, if you disagree with an action taken or decision made by the SNRHA. you must make your complaint or grievance to them directly for resolution in accordance with their locally-set policies and procedures, meluding local and state laws if you need additional assistance, please contact Delorts Sawyer, Section 8 Director at SNRHA. Ms Sawyer can be reached at 702-922-6964, thopethis information1s helptul, Sincerely, f f » fi fs \ Lindsey 5S Reames Acting Deputy Assistant Secietary for Field Operations wahud.gor espanol.hud.gov

Congress of the Guited States Washington, BE 20515 October 6, 2016 The Honorable Julian Castro Secretary U.S. Department of Housing and Urban Development 451 7" Street Southwest Washington, DC 20410 Dear Secretary Castro: On June 23, 2016, West Virginia was devastated by catastrophic flooding that claimed the lives of 23 people. Twelve West Virginia counties were declared federal disaster areas as a result of the flood, In someareas, as much as 10 inches of rain fell in a 24 hour period. Forecasters have described the event as a thousand year flood. Morethan three monthslater, five counties in our state remain under a state of emergency. While a numberof federal government agencies, including the Federal Emergency Management Agency (FEMA), haveprovided significant assistance to West Virginia communities impacted by the flood,it is clear that significant unmet needs remain. On September 13, 2016, West Virginia Governor Earl Ray Tomblin wrote to President Obamaand identified $310 miflion in unmetneeds resulting from the June flood that could be eligible for assistance from the Community Development Block Grant-Disaster Recovery program. Over 5,100 homes and businesses suffered a loss verified by FEMA and nearly 90 percent were not covered by flood insurance. Additionally, many ofthe areas impacted by this flood werealready facing significant economic challenges making the cost of rebuilding homes and infrastructureall the more difficult to bear On September 29, 2016, President Obamasigned H R. 5325, the Continuing Appropriations and Military Construction, Veterans Affairs, and Related Agencies Appropriations Act, 2017, and Zika Response and Preparedness Act.' This legislation includes $500 millionfor the Community Development Block Grant—Disaster Recovery program. Bipartisan congressional leaders and appropriators expressed clearlegislative intent that West Virginia receive a fair portion of disaster recovery fundsincluded in thatbill to aid ourstate in rebuilding from the catastrophic floods.’ Westrongly support WestVirginia's request for CDBG-DRfunds appropriated last month, and we believethat this is an important down payment for our recovery ' Pub. L. 114-223. pRUNTED ON RERYE EO PAPER

Weunderstand that additional appropriations will be necessary in order to meetthe true disaster recovery needs in West Virginia and in otherstates. We request that you include West Virginia's additional unmet needsin any disaster supplemental appropriations proposalthat the Administration submits to Congress. While the recent $500 million allocation of Community Development Block Grant—Disaster Recovery funding will help jumpstart the recovery for West Virginia families and small businesses impacted by the June flood, we look forward to working with you and the President to ensure that we have the resources we need to rebuild safe, strong, sustainable communities. Thank youfor your consideration. Sincerely, Shelley Moore Capito Joe Manchin DI United States Senator United States Senato McKinley, P.E. of Congress MemberfofCongress Alex X. Mooney an Memberof Congress 2 162 Cong. Rec, $5969 (daily ed. Sept. 22, 2016)(Remarks of Senate Majority Leader Mitch McConnell)(“‘It containsa sufficient down paymenton floodrelief for many States, including. . West Virginia... [.J”); 162 Cong. Rec. $6105 (daily ed Sept. 27, 2016Remarks of Senate Appropriations Committee Chairman Thad Cochran)(“The bill also includes $500 miilion to help Louisiana, West Virginia, and other states recover from devastating floods.”)}, Id. (Remarks of Senate Transportation, Housing and Urban Development Appropriations Subcommittee Member Shelley Moore Capito)(“The legislation we will vote on today takes an importantslep to address flood recovery in disaster-stricken portions of West Virginia and certainty for our friends in Lousiana.. . [.}"; 162 Cong. Rec. 56166 (daily ed. Sept 28, 2016) (Remarks of Senate Demooratic Leader Harry Reid)(“I think West Virginia, which has an emergency declaration of $316 million — that should be taken care of.”); 162 Cong, Rec $6182 (daily ed Sept. 28, 2016)(Remarks of SenateAppropriations Committee Vice-Chairman Barbara Mikulsk: (“I also wantto say thatit does contain disasterrelief for flooded communities like Louisiana and West WVirainia 7,

ee, ten til: | ak US. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 4oe WASHINGTON,DC 20410 1000 ASSISTANT SECRETARY FOR CONGRESSIONAL AND INTERGOVERNMENTALRELATIONS ONG Nov 2 3 2016 The Honorable Evan H.Jenkins U.S. House of Representatives Washington, DC 20515-0001 Dear Representative Jenkins: On behalf of Secretary Julian Castro, thank you for yourletter requesting assistance through Community Development Block Grantdisaster recovery (CDBG-DR)fundsasa result of the recent floods. As you are aware, President Obamasigned the Continuing Appropriations Act, 2017 into law under Public Law 114-223 on September 29, 2016. The following information is from the Department of Housing and Urban Development's Office of Community Planning and Development. On October 13, 2016, Secretary Castro announced the allocation of $17,000,000to the State of West Virginia. In orderto assist dividuals and communities in the most umpacted and distressed areas ofthe State, the State of West Virginia must submit a disaster recovery Action Plan. On November 16, 2016, the Department published “The Allocation, Common Application, Wawers, and Alternative Requirementsfor CDBG-DR Grantees ~ Continuing Appropriations Act, 2017” Notice at: hitps://www.hudexchange.info/news/hud-publishes-allocations-common-application- watves-and-alternative-requirements-for-cdhg-dr-grantees-continuing-appropriations-act-2017/. TheState will have 90-days to submut its Action Plan. All activities in the Action Plan must - met oneof three national objectives of the CDBG program. This meansthatthe activity must principally benefit low- and moderate-incomepersons,aid in the elimination of slums or blight, or meet other community developmentneedshaving a particular urgency. Thank you for yourinterest in the Department's programs. Please let me knowif I can be of furtherassistance. Sincerely, aL Moritsugu Assistant Secretary for Congressional and Intergovernmental Relations www.hud.gov espanol.hud.gov

Congress of the Gnited States Washington, BC 20515 October6, 2016 The Honorable Julian Castro Secretary U.S. Department of Housing and Urban Development 451 7” Street Southwest Washington, DC 20410 Dear Secretary Castro: On June 23, 2016, West Virginia was devastated by catastrophic floodingthat claimedthe lives of23 people. Twelve West Virginia counties were declared federal disaster areas as a result of the flood. In someareas, as much as 10 inches ofrain fell in a 24 hour period. Forecasters have described the event as a thousand yearflood. More than three monthslater, five counties in our state remain under a state of emergency. While a numberof federal governmentagencies, including the Federal Emergency Management Agency (FEMA),have provided significant assistance to West Virginia communities impacted by the flood,it is clear that significant unmet needs remain. On September 13, 2016, West Virginia Governor Earl Ray Tomblin wrote to President Obamaandidentified $310 million in unmet needs resulting from the June flood that could beeligible for assistance from the Community Development Block Grant-Disaster Recovery program. Over 5,100 homes and businesses suffered a loss verified by FEMA and nearly 90 percent were not covered by flood insurance. Additionally, many ofthe areas impacted by this flood were already facing significant economic challenges makingthe cost of rebuilding homes and infrastructure all the moredifficult to bear. On September 29, 2016, President Obamasigned H.R. 5325, the Continuing Appropriations and Military Construction, Veterans Affairs. and Related Agencies Appropriations Act, 2017, and Zika Response and Preparedness Act.' This legislation includes $500 million for the Community Development Block Grant—Disaster Recovery program. Bipartisan congressional leaders and appropriators expressedclearlegislative intent that West Virginia receive a fair portion ofdisaster recovery funds includedin thatbill to aid ourstate in rebuilding from the catastrophic floods.” Westrongly support West Virginia’s request for CDBG-DRfunds appropriated last month, and webelieve that this is an important down paymentfor our recovery. Pub. L. 114-223. PRINTED ON RECYCLED PAPER

Weunderstand that additional appropriations will be necessary in order to meetthe true disaster recovery needs in West Virginia and in other states. We requestthat you include West Virginia’s additional unmet needs in anydisaster supplemental appropriations proposal that the Administration submits to Congress. While the recent $500 million allocation of Community DevelopmentBlock Grant~Disaster Recovery funding will help jumpstart the recovery for West Virginia families and small businesses impacted by the Juneflood, we look forward to working with you and the President to ensure that we have the resources we needto rebuild safe, strong, sustainable communities. Thank youfor your consideration. Sincerely, Shelley Moore Capito Joe Manchin III United States Senator United States Senat Memberfof Congress Alex X. Mooney bm Member of Congress ? 162 Cong. Rec, $5969 (daily ed. Sept. 22, 2016)(Remarks of Senate Majority Leader Mitch McConnell)(“‘It contains a sufficient down paymentonfloodrelief for manyStates, cluding. . West Virginia ...[.]"); 162 Cong. Rec. $6105 (daily ed Sept. 27, 2016)(Remarks of Senate Appropriations Committee Chairman Thad Cochran)(“The biil also includes $500 million to help Louisiana, West Virginia, and other states recover from devastating floods.”); Id. (Remarks of Senate Transportation, Housing and Urban Development Appropriations Subcommittee Member Shelley Moore Capito)(“The legislation we wil} vote on today takes an imporiant step to address flood recovery in disaster-stricken portions of West Virginia and certainly for our friends in Louisiana. . . [.}”; 162 Cong. Rec $6166 (daily ed. Sept. 28, 2016) (Remarks of Senate Democratic Leader Harry Reid)(“I think West Virginia, which has an emergency declaration of $310 million — that should be taken care of.”); 162 Cong. Rec. $6182 (datly ed Sept. 28, 2016)(Remarks of Senate Appropriations Committee Vice-Chairman BarbaraMikulski(“1 also wantto say that it does contain disasterrelief for flooded communities like Louisiana and West Viroinia ry

IVATEIL I NIKIN oT Wom aes vue a | Con Pn! th wld at titarha t ' ss 1 vr atin te vase Ciriani rrr ad ip Mariel Spied eee ma Ontiat ar }cperstitans, on bole Miodnrnpay, HOLST ans Vio nw ane Mareh 17, 2017 US Department of Housing aad Urban Development 451 7th Sucet SW Washington, D.C, 20416 Dear Ms. Dunn: Lnelosedplease finda letter fromthe Lincoln County Comunission in West Virginia regaiding an issue that falls underthe junisciction of your agency. ‘Lhe Commission ts secking a waiverfrom the U.S. Depaitmentof |lousing and Urban Developmentfot the Lower Mud River Phase | Water Extension Project, Small Cities Block Giant Program. Project Number 15SCBG0003. It is my understanding that the Lincoln County Commissionis secking the waiver to avoida onc- yeat delay in the project, which wouldadverselyaffect atca residents living without access to safe municipal dtinking water. I would appreciate yourattention to the Lincoln County Commission’s request and look forward to your response. Please do not hesitate to contact me should you have any questions. Sincetely, a i¢dan (van Ny an (os Evan Jenkins ( Membet of Congress ORIG aICGEON Lomi icine prople ef tlie tai Cong tan Ditnebot 6 tMionii hese the ae test ppartuin to lie ter ond prospermue ive by covine Con mmuseating, prife Cag on tgee lke thon noaprete sonal marr iiep tiranar APM ESCO LAL te

February 21, 2017 US Congressman Evan Jenkins 1609 Longworth House Office Building Washington, DC 20515 Re Small Cites Block Grant Program Lincoln County Commission Lower MudRiver Phase 1 Water Extension Project Project Number 15SCBG0003 Dear Congressman Tam writing this letter on behalf of the Lincoln County Commission to ask for your consideration and help in trying to obtain a waiver from HUDinregard to the construction ofthe above-referenced water project. I am enclosing a copyofthe letter from Rick Roberts, Project Manager with E.L. Robinson Engineering, identifying certain issues and concernsrelated to the water project. Specifically. HUD expresses concern over the numerous creek crossing which are necessary mn order to complete the water project. However, our intent 1s to span these creeks through the use of direct drilling, which will result in zero impact to the stream bottom and banks. This is the method that we have used in multiple areas throughout the county over the past 16 years, when we have used Small Cites Block Grant monies to extend potable water to the citizens of Lincoln County. All of these projects resulted m zero impact. The Commissionrespectfully asks that you consider approaching those involved with this project, including the HUD representatives, all in order to help us obtain a waiver, so that we may avoid an approximate one year delay. Any extended delay will cause undue hardship on the people of this area, who have dealt for years with poor quality and quantity of potable water, many of whomare elderly, disabled and suffering from multiple health problems. Your consideration and help in resolving this matter 1s sincerely appreciated. Sincerely, Charles N. Vance, President Lincoln County Commission CNV/mm Enclosure

E.L. ROBINSON 1 LOMO ‘ o 9047767873 Bib ay Nal & Fad F, 304 776 6426 5088 Washington St. West na Charleston, WV 25313, February 17, 2017 Kelly A. Workman Manager, Project Development Community DevelopmentDivision West Virginia DevelopmentOffice 1900 Kanawha Boulevard East Charleston, WV 25305-0311 Re: Small Cities Block Grant Program Lincoln County Commission Lower Mud River Phase | WaterExtension Project Project Number: 15SCBG0003 Dear Ms. Workman: As you know,the Lincoln County Commission has been awarded $1,500,000 from the Small Cities Black Grant Program for the Lower Mud Phase } Water Extension Project. The totai cost of the project is $4,579,000 with the remainderof the funds being provided by the Lincoln County Commission, US Army Corps of Engineers and USPA-Rural Development. The Lower Mud RiverPhase| Project will serve approximately 94 potential residential and small commercial customers. The residents in the area complain of water quality and quantity problems. Complaints include allegations that the well water contains iron, corrodes pipes andfixtures, stains cloths, has a strong sulfur odorand tastes bad. Manyresidentsutilize home treatmentunits in an effort to improve the quality of water, The County Commission has recetved several reports that welis in the area get low or go dry during certain timesof the year. The base project consists of the construction of approximately 54,670 linear feet of 8-inch and smaller diameter water main, one 105,000 gallons storage tank, one pressure regulating station, 30fire hydrants, valves, individual customerservices and otherrelated appurtenances. Due to budget concerns, four (4) additional areas are excluded from the base project but are included as additive alternates should construction bids be lower than expected.(n all, approximately 18 potential customers In the Lower Mud River Road (County Route1) and Big Buffalo Creek Road areas could potentially be added to the project. The extensions to serve this area total approximately 13,360linearfeet of 8-inch and smaller diameter water main, 8 fire hydrants, vaives, individual customer services and other related appurtenances, it has recently been brought to our attention that waterline construction activities within the floodway is now a concern of HUD and that construction within the floodway may be prohibited. We have reviewed the FEMA Floodway Mapping for the project area and determined thatfive {5} crossings Equal Cpportunity Employer

of Mud Riverwill result in temporary construction disturbance within the floadway. Given that the waterlines must be continuausto transport waterfrom the beginning of the project to the end, any “gap”left In the line as a result of the elimination of a stream crossing would have the effect of rendering the system non-operational. Given the need for the project, this is certainly not in the best Interests of the residences in the project area, Each of the stream crossings are of the Mud River. The flow way (top of bank to top of bank)is to be crossed using the directional drill method. This will allow the pipeline to be installed by “drilling” it underthe stream and will result in zero impactto the stream bottom and banks. The remaininglines in the floodwaywill be installed by direct burial method (trenching). The lines instatled by trenchingwill, immediately following installation, will be backfilled to the original ground contours, seeded and mulched. Sift fence will be installed as needed to prevent future scouring of the floodway or changein flow hydrodynamics. As all graund surfaces along the route of the pipeline will be either undisturbed (directional drilling) or returned to their original contours (trenching), the existing flow hydrodynamics will not be permanentlyaffected or altered. Because the existing flaw hydrodynamicswill not be affected or altered, no additional hydrologic and hydraulic study was undertaken. No changes to the stream or groundin the floodway should adequately demonstrate that the addition of the pipe to the existing conditions will not create any negative effect in the floodway. Since this project will not create any negative effects in the floodway, we respectfully request a waiver of the HUD requirementthat no construction take place within the floodwayso that this much neededproject can proceed to construction in support of our request, we have attached substantial additional documentation. If you have any questions, do not hesitate to let us know. Sincerely, Rick Roberts, P.E Project Manager E. L. Robinson Engineering Co. CC: w/attachments Lincoln County Commission Lincoln Public Service District jual Opportunity Empioyer

- WEST VIRGINIA DEVELOPMENTOFFICE Wem. eeogee 3900 Kanawha Bovievard East » Charleston, WV 25305 0311 (304} $58 2234 - (800) 982 3386 - WVDO org February 15, 2017 The Honorable Charles Vance President Lincoln County Commission PO Box 497 8000 Court Avenue Hamlin, West Virginia 26523 Dear Commissioner Vance RE; COBG-Small Cities Block Grant Program Lincoln County Commission Lower Mud River Phase | Water Extension Project Project Number: 15SCBG0003 ($1,500,000) The purpose of this letter is to request additional information concerning the above- referenced project, and to request an analysis of anticipated construction within Federal Emergency ManagememAgency (FEMA) Fiood Insurance Study (FIS) floodway(s) This project is funded by the US Department of Housing and Urban Development's (HUD) Community Development Block Grant - Small Cites Block Grant program (CDBG-Smali Citles) Most recently, the HUD Regionlif Office, located in Philadelptua, Pennsylvania, requested information to determine whether underground utility lines to be constructed within a FEMA designated FIS floodway, would impact baseflood elevations To review, the State of West Virginia awarded a $1,500,000 CDBG grant to the Lincoin County Commission for the Lower Mud River Phase | Water Extension prayect on March 8, 2016 The total cost of the $45 million projectts fully funded by a $354,000 loan and a $1 98 million grant from the US Departmentof Agriculture, Rural Development and a $495,000 grant from the US Army Corp of Engineers In addition, the Lincoln County Commission has dedicated $175,000to this project As initially proposed, ths project would provide potable water and fire protection service for 147 families, representing 370 individuals, in Lincoln County This project would serve the areas of Lower Mud River Laurel Creek, Straight Fork, Buffalo Creek, Littte Buffalo Creek and surrounding areas It is noted that residents currently rely on privately owned wells for their water supply Residents have complained the wells produce water that contains iron corredes pipes and fixtures, smells of sulfur, and has an unpleasant taste The quantity of is poor and waterlevels get low at certain time of year The Lincoln County Health Department has certified health and

sanitation problems exist In the project area with bacterial contamination of wells These conditions hinderboth residentiai and cammercial growth in the area In compliance with 24 CFR 570 483(b)(1)(1}, the project area was determined by the Lincoln County Commission to provide area-wide benefit to low-and-maderate income persons Eligibility was determined by census data The numberof low-to-moderate income personsin the area was determined to be 59 0 percent of the population It 1s noted within the appilcation that the poverty rate in Lincoln Caunty was 27 0 percent, compared to West Virginia’s poverty rate of 18 percent and the national poverty rate of 15 percent The WVDO accepted the Lincoln County Commission's environmental! review and tssued a Notice of Authority to Use Grant Funds on October 3.2016 Our records indicate that funds in the amount of $21,374 have been expended to date The project is expected to proceedto bid stagein early Fall 2017 The HUD request for information related to stream crossings followed recent discussion of HUD’s prohibition of development within a FEMA designated floodway To demonstrate the potential impact that this project, and the impact that similar projects involving underground utility lines would have on baseflood elevations, the WVDO requested clarification from the project engineer, Mr Rick Roberts, of EL Robinson Engineering, Inc A list of questions received by the WVDO from the HUD Region tll office, was presented to Mr Roberts These questions are summarized asfollows * Narrative demonstrating that the location of pipe will not alter or affect existing flow hydradynamics * For pipes going underground,typical cross section and planned construction specs «Any hydrologic and hydraulic study undertaken or reviewed to demonstrate that the addition of the pipe to the eaisting conditionswill not create any negative effect in the floodway «© Narrative demonstrative measures that will be taken to avoid future scouring of river bed or changein flow hydrodynamics Discussion with Mr Roberts indicates that all underground sewerline stream crossings will be directionally drilled and will not impact the original contours so as not to changethe flow characteristics of the stream, including the water quality and the 100-yearfloodplain elevations or velocities Information contained in the plans and specifications for this proyect that require ail existing ground conditions to be restored to preconstruction conditions, as well as all applicable permits are requested The precise cost and location of the utility Ime stream crossings tn the floodway should be identified The HUD RegionIII Office has advised that the State of West Virginia request a waiver on behalf of the Lincoin County Commission The Region Ill Office has further advised that this waiver request, and the desired approval Is expected to require at least four months, and may delay the Lower Mud River Phase | Water Extension project The WVDO requested ail pertinent information needed to prepare a waiverrequest that would, upon HUD approval, allow the project to proceed as designed If other options are available, such as the use of other funding for this work, the WVDO would request permission from HUD to seek other funding sources forthis specific work [tis

noted that the underground stream crossings may represent a small portion of the overall project, but they are nevertheless critical to its viability It» understood that the WVDO will be unable to issue an Authorization to Bid to the Lincoln County Commission until this matter 1s resolved \{1s also understood that the only alternatives to construction within the floodwayis to not allow such construction, or ta allow these portions of the project to be funded by other sources. The project area is bisected by certain streams and construction must occur within the floodway to develop the system that will provide safe andreliable water In consideration of these factors, the WVDO will obtain any information required by HUD to request a waiver on behalf of the Lincoln Caunty Commission The WVDOis requesting that the Region [! Planning and Development Council and EL Robinson Engineering assist in this effort Your assistance in this matter 1s greatly appreciated If you have questions or need additional information, please call me at 304-558-2234 CDBG Program Manager cc Todd Goddard, WVDO Jim Marshall, WYBO. Rick Roberts, EL Rabinson Engineering, inc Chris Chies, Region Il PDC

ta OFFICL OF CONGRESSIONAL AND. INTERGON ERNMENTAL REL VHIONS. L.S. DEPARTMENT OF HOLSING AND URBAN DEVELOPMENT WASHINGTON DC 26410 1000 The Honorable Evan H.Jenkins Committee on Appropriations U S. House of Representatives Washington, DC 20510-4803 Dear Representatiye Jenkins Thank youfor yourlettet regarding the Lincoln County Commission's request for a waiver fromregulations at 24 CFR Part 55 for the Lower MudRivei Phase I Water Extension Project, Small Cities Block Grant Program. Project Number 15SCBG0003. The following information 1s fromthe Department of Housing and Urban Development's (HUD)Office of Community Planning and Development. The Department’s Floodplain Managementregulationsstate at 24 CFR 55.1(c)(1) that no HUDfinancial assistance or mortgage msurance maybe used for “anyaction other than a functionally dependentise or floodplain function restoration activity, located in a floodway” unless the activity is otherwise covered by am exception in 24 CFR 55.12(c). A “Regulatory Floodway”as defined by Federal Emeigency Management Agency. 1s the channelof a river or other watercourse and the adjacent land areas that mustbe reserved in order to discharge the base flood without cumulatively increasing the water surface elevation mole thana designated height. Floodways are areas wherefill or other developmenttslikely to divert flow and contribute to increased water depths during a flood and mayalso be subject to high velocities, which can cause severe damage to structures and high risks for occupants and emergencyresponders. HUD’s regulationsare particularly conservative regarding floodw ays, because they aie targeted towardsresidential ptoperties. As a result, Part 55 prohibits the Departmentfrom funding infrastructure projects that pass though floodways althoughthese projects would be permitted by other agencies For sevetal months, HUD has been working with the state of West Virginia to identify legal methods to fund West Virginia’s important infrastructure work. Although the Department has never waived Part 55, HUD’s Office of Environment and Energy 1s prepared to design a waiver process that would allow communities in West Virginia to use Departmental funds oninfrastructure projects. HUD hasdiscussed this process and the requirements with the West Virginia Development Office to make the waiver process run as smoothly as possible The Department received a partial waiver request from the West Virginia Development Office on behalfof the Lincoln County Commussion on March 24, 2017, Once a complete waiver request 1s received, HUD will review. The Department may giant a waiverif there 1s good cause and no adverse effects on the floodplain. www,hud.gor espanol.hud.gov

i) Thank youfor your interest in the Department's programs. Please let me knowif I can be of further assistance. Sincerely. portnblbo— Aaron Santa Anna Acung General Deputy Assistant Secretary for Congressional and Intergovernmental Relations

ee EVAN H. JENKINS Tein Distmict, West VinGnua 1609 Loncwoetn House Orrice Bunce + ‘WASHINGTON, DC 20516, (202) 225-3452 COMIMITTEE ON APPROPRIATIONS: (845 Fretn Avenue Surre 314 everfenkins house.gov Cungress of the United States Morongo House of Representatives Brousy,2580) Washington, BO 20515-4903 ee 601 Feoemal Smmecr, Suite 1003 BLucrie.o, WV 2670% (304) 325-6800 May17, 2017 Secretary Ben Carson ; US.DepartmentofHousing and Urban Development RE C EIVED Washington, DC 20410 By Melody Brown at 2 53 pm,5/23/17 Acting Administrator Robert J. Fenton, Jr. Federal Emergency Management Agency 500 C Street S.W. . Washington, DC 20472 RE:June 2016 West Virginia Flooding (4273-DR-WV) Dear Secretary Carson and Acting Administrator Fenton: I appreciate the assistance and support that HUD and FEMA provided in the aftermath of the June 2016 floods in West Virginia. On June 23, 2016,a series of thunderstorms concentrated in West Virginia resulted in historic rainfall. Some counties experienced ten inches of rain within twenty-four hours. This event culminated in a thousand-year flood, causing widespread damage to homes, businesses, and infrastructure in the state. The flooding, which resulted in the loss of twenty-three lives, proved to be one ofthe deadliest natural disasters in the nation last year. Former Govermor Earl Ray Tomblin issued a letter detailing a state request for federal funding through the Community Development Block Grant Disaster Relief Program (CDBG- DR), recognizing the unique challenges that West Virginia faced in rebuilding. Mountainous topography, depressed incomelevels, and the lack of flood insurancefor close to ninety percent ofthe affected residents and businesses are major obstacles to the recovery effort. a The House and Senate Appropriations Committees added significant funding for HUD’s CDBG-DR program to assistwith recovery efforts for West Virginiaand otherstates that recently experienced major natural disasters. Throughout the fiscal year 2017 process, Congress has provided in aggregate over $2.7 billion for CDBG-DR.! These funds are to support recovery and rebuilding efforts for damages incurred by severe weather events in 2015, 2016, and 2017. To date, West Virginia has received over $104 million in CDBG-DR funding for flood recovery efforts. This federal support has been absolutely critical to helping our residents repair 1 HLR. 5325, ContinuingAppropriations andMilitary Construction, Veterans Affairs, and Related Agencies Appropriations Act, 2017 (P.L. 114-223); H.R. 2028, Further Continuing and Security Assistance Appropriations Act (P.L. 114-254); and H.R. 244, ConsolidatedAppropriations Act of2017 (PL. 115-31) OFFICE MISSION “To ensure the peopleof the Third Congressional District of West Virginia have the greatestopportunity to tive free and prosperouslives by serving, communicating, protecting snd representing them in a professional and caring manner. PAINTED ON RECYCLED PAPER

their homes and communities. However, there are outstanding needs that remain. The storms and flooding devastated entire counties in my state. With the numberofschools, homes, and businesses impacted,it was clear that action in Congress was necessary. That is why the most recent appropriations package passed by Congress included an additional $400 million for HUD to address unfulfilled disaster recovery needs. 1 wantto reiterate that we are grateful for the support we have received from HUD and FEMA tothis point, I wouldalso like to highlight the concerns we have aboutthe remaining shortfall between the West Virginia state government’s determination of unmet need and the amount ofunmet need allocated by HUD. While J recognize that there will always be differences in the determinations made bythe state agencies and the federal agencies ofjurisdiction,I believe that we ought to pursue the most comprehensive review possible. It has recently cometo myattention that HUD may beconsidering West Virginia CDBG- DRallocations using data provided by FEMA in early December2016.Ifthisis the case, 1 would request FEMA send an-updated datasetto HUD in order to guarantee that HUD hasthe latest data at its disposal when determining such an allocation. It may be possible that more recent data could justify an increase in CDBG-DRfunds for West Virginia’s housing or public assistance needs resulting from the June 2016 floods. It has been mytoppriority to ensure that West Virginia has the resourcesit needs to rebuild, I commend you on your leadership and look forwardto continuing to work together on our recovery efforts. Thank you for your consideration andassistance. I am truly appreciative of you, your organizations, and your outstandingstaff. Sincere}:

US. Department ot HomelandSecmity FEMA RegionHi One Independence Mall Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA May25, 2017 The Honorable Evan H. Jenkins U.S. House of Representative 1609 Longworth House Office Building Washington, DC 20515 DearRepresentative Jenkins: Thank you for your May 17, 2017, letter to the U.S. Department of Homeland Secutity’s Federal Emergency Management Agency (FEMA), regarding the June 2016 West Virginia Flood (DR-4273- WV). The letter describes the funding WV hasreceived through the U.S. Department of Housing, and Urban Development’s (HUD) Community Development Block Grant DisasterRelief Program (CDBG-DR)and highlight your concernthat the remaining shortfalls between the West Virginia State Government’s determination of unmet needs and the amount of unmet need allocated by HUD. You requested all partners work to pursue the most comprehensive review processto ensure the most up-to-date datasets are being considered and asked that FEMA send an up-to-date dataset to HUDinorderto guarantee that HUD hasthe latest data at its disposal when determining, allocations. FEMA,throughits West Virginia Recovery Office, coordinates with West Virginia’s Division of Homeland Security and Emergency Management (WVDHSEM)and the West Virginia Department of Commerce (WVDCOC)ontheir data needs, including those related to the CDBG-DRrequest. In response to yourletter, we contacted the WVDOC- the State entity which uses the FEMA dataset as part of the CDBG-DRjustification to HUD — to ascertain their need for an updated datasetrelated to this request. We will continue to work closely with WVHSEM and WVDOCto ensure that they have updated FEMA programdata, At HUD’s request, FEMAalso provides I[UD with this dataset to be used as part of their CDBG-DR determination. HUD then combinesthis dataset with their owndata, data from the Small Business Administration, msurance and other sources to determine unmet housing needs, FEMApreviously provided this dataset to HUD for DR-4273-WV on December 9, 2016. This past weck,at the request of ITUD,an updated version ofthe dataset was created andis in the process of being delivered. i hope this informationis helpful. If you have any questions, please have a memberof your staff contact FEMA’s Congressional ffairs Division at (202) 646-4500. Acting Regtonal Administrator www.fema.goy

Mas Lf 201/ Sectetaty Ben Cason US Depaitment of Housing aad Liban Developmen 451 7th Street S W Washington DC 20410 Acting Administrator Robett J. Penton. hh Fedeial Limergency Management Agency 500 C Street S.W Washington, DC 20472 RE June 2016 West Virgima Flooding (4273-DR-WV) DearSecictary Carson and Acting Administrator] enton: J appreciate the assistance and support that 11UD and kIkMA providedinthe aftermath of the June 2016 floods in West Virgima. On June 23. 2016, a series of thunderstorms concentiated in West Virginia resulted in historic ramfall Some counties expeuenced ten inchesof rain within twenty-four hours. [his event culminated in a thousand-ycar flood. causing widespread damage to homes, businesses, and infrastructure in the state. [he flooding, which resulted 1n the loss of twenty-thice lives, provedto be onc ofthe deadliest natural disasters in the nation last yeal lorme: Goveinor Earl Ray Tomblinissueda letter detailing a state request for federal funding though the Community Development Block Grant Disaster RehefProgram (CDBG- DR). recognizing the unique challenges that West Virginia faced in rebuilding Mountainous topography, depressed incomelevels. and the lack of flood insurance for close to minety percent ofthe affected residents and businesses aic major obstacles to the recoveryeffort. The House and Senaie Appropriations Committees added significant funding for IUDs CDBG-DRprogramto assist with recovery efforts for West Virginia and othe: states that recently experienced majornatural disasters. Throughoutthe liscal year 2017 process, Congress has provided in aggregate over $2.7 billion for CDBG-DR | These funds are to support recovery andrebuilding elfoits for damages cum red by severe weather events in 2015. 2016, and 2017. To date, West Virginia has received over $104 million in CDBG-DRfundingforflood recovery efforts. [his federal support has been absolutely critical to helping our residents repair "HR $325, € ontinimg Appropriations and Military Consiruction, Veterans Affaus and Related Agencies Appropriations ict, 2017 (PL 114-223), HR 2028, Further Continuing and Securuy Assistance Appropriations Act (PL. 114-254), and 11 R 244, Conseafidated Appi opriations Act of 2017 (PE 115-31) rehire ded boron og Poot Tint 3 rodatad Porpaah 1 mil Wow bo u homer gt Poh bey het mon

then homes and communitics Howevet. there are outstanding needsthat remain ‘Lhe storms and flooding devastated entice counties in my state With the number ofschools. homes, and businesses impacted. it was cleai that action in Congiess was necessary That is why the most recent appropriations package passed by Congress included an additional $400 million for HUD lo address untullilleddisaster recovery needs lwant to ierterate that we are grateful for the suppoil we have received fiom HUD and ILMAto this point 1 would also fike to highlight the conccins wehave about the semaine shortfall between the West Vuginia state government's determination of uninet need andthe amount of unmet need allocated by UD While Jiccogiive that there will always be differences in the determinations made by the state agencies and the federal agencies of jurisdiction £ believe that we ought to pursue the most compichensive review possible It has recently come to myattention that HUD maybe considering West Viurginta CDBG- DRallocations using data provided by PEMA imearly December 2016 IL this is the case. | would request | LMA send an updated dataset to HUD tnorder to guarantee that HUDhas the latest dataat 1ts disposal when determining suchan allocation Tt maybe possible that mote recent data could justify an increase in CDBG-DRfunds for West Virginia’s housing o1 public assistance needsresulting fromthe June 2016 floods. It has been mytop priority to ensure that West Virgimahas the resoureesit needs to rebuild T commend youon your leadership and look fot ward to continuing to work together on ourrecovery efforts Thank you for yout consideration andassistance. | ain truly appreciative of you. your organizations, and your outstandingstaff Sinceiely, vy . X 2 we Repa an Jenkins

CO WM e Ons BEBOP sesticr! C VALLE HMI ete am oy hn unt Grigg eg ni ihe Hien {brie uo rise ot Ta Ue setts boa Wheadrangiig, AO ee te wt dime 29, 2017 liacey Dunn, Congressional Liaison Office of Congressional and Intergoveumnental Relations U.S, Department of Housing and Urban Development 4517" Street SW Washington, DC 20410 Dea Ms, Dunn: I wite to inquite about the status of HOME funding fora projectin the City of Huntington, West Vuginia (City). It has recently come to myattention that the City has incurred unnecessarydelays in accessing funds foreligible plojects andactivities, due fo concerns ovet a previous agicement betweenthe City and the U.S Department of Housing and Urban Development (IUD). Attached, please find conespondence fiom MayorStephen Willams which furtherdetails the issues that the City has raised with obtainmg HOME funds. It is my understanding that these funds ate being unnecessarily blocked fiom use for other projects that fall under HUD”s jurisdiction. J would gicatly appreciate a timely sesponse to myinquity. Please contact me or myoffice at (202) 225-3452ifthere is any additional information you need (iCn. Fvan LL. Jenkins Member of Congress OFC A416S10M Fonte the people ot te Laid Canal ional Or lactol We? Miranihave thi arcate Copp ortunity te dive free al pre puter hyve by veg Cor maga crtins prot dina ind a pae cating deter ee rare tomate rn un act Peer Cet tradi

NARRATIVE SUMMARY ABOUT THE ISSUE OF FROZEN HOME FUNDS BASEDONIDIS ACTIVITY NO. 1250 — THE HUNTINGTON GARDENS PROJECT, CITY OF HUNTINGTON, WESTVIRGINIA BACKGROUNDINFORMATION — The City of Huntington is the Participating Jurisdiction (PJ) and the Representative Memberof the Cabell-Huntington-Wayne Housing Consortium. The City, in conjunction with residents, the Huntington Housing Authority and the Housing Development Corporation decided to revitalize the Fairfield West Neighborhood by developing new affordable housing stock in the community. This was also as a result of the need to replace the existing Northcott Court Public Housing Community with new scattered site affordable housing. The City entered into a CHDO Agreement with the Housing Development Corp. (HDC) for a multi-phase housing development program. The project wasinitially set-up in IDIS as Activity No. 1250 on August 22, 2012 in the amount of $382,393.32. There was a four year time period to expend the funds, which expired on August 21, 2016. The scope of work for Phase Onewasstated as: HDCwill be using these funds to prepare a Redevelopment Plan to assist in the re-housing of residents from the Northcott Court Public Housing Community into the Fairfield West Neighborhood. In addition, HDC will use these funds to start implementing the Redevelopment Plan by acquiring properties identified in the plan. The following properties will be acquired include but are not limited to: 1661 Doulton Avenue, 4837 Lith Avenue, 1822 Charleston Avenue. Construction involves development of a 40-unit elderlyfactlity and two (2) scattered site residential two-familyunits. Whentheactivity was in its “pre-development stage” after the Redevelopment Plan was completed and adopted, the City discussed with HUD-Headquarters how bestto set up the follawing phasesfor the developmentof affordable housing. The City was advised by HUD-Headquarters to group together the future phases of Huntington Gardensinto oneactivity (No. 1250) to avoid any potential IDIS activity flags. This allowed the CHDO some flexibility to implement the overall affordable housing development. The Redevelopment Plan andinitial property acquisitions for the new affordable housing development sites were completed within the allowable time frame, and all the funds were drawn downin IDIS. The HDC then prepared and submitted a LIHTC Application to the WV Housing Development Fund (WVHDF}for a 40 unit affordable housing project to be built in the

Fairfield West Neighborhood on the acquired housing site. Unfortunately, the application was not funded. On October 1, 2013, the City and the HDC entered into the First Amendment to the original CHDO Agreement in the amount of $311,704.11 to develop a two story, two- family duplex located at 1837 Eleventh Avenue in the Fairfield West Neighborhood. This duplex was completed andall the funds were drawn down within the allowable time frame. The City and HDC entered into a Second Amendmentto the CHDO Agreement on June 1, 2014 in the amount of $347,171.56 to construct a second two story, two-family duplex in the Fairfield West Neighborhood. The duplex was built on 1822 Charleston Avenue andall the funds were drawn down within the allowable time frame. On July 10, 2015 a new CHDO Agreementwas entered into between the City and HDC in the amount of $843,265.00 for the development and construction of a 40 unit affordable rental apartment complex located at 1661 Dalton Avenue in the Fairfield West Neighborhood. These funds were to be used in conjunction with the LINTC funds andprivate funds. The City and HDC entered into the First Amendment to the CHDO Agreementfor 1661 Dalton Avenue on March 29, 2016 in the amount of $654,959.00 to coverthe increased construction costs for the development of the 40 unit affordable rental apartment complex. The building was built and the City issued a certificate of occupancyin December2016. THE ISSUE WITH HUD - The City learned that its HOME funds were frozen in IDIS in September 2016. The City did not realize that continuing to use IDIS Activity No. 1250 would block (freeze) the system. The IDIS Activity was set-up on August 22, 2012 andall the funds had to be drawn down by August 21, 2016, four years after the initial set-up date. The IDIS accessto the funds was blocked on August 23, 2016. After numerous discussions with the HUD-Pittsburgh Office, the City was advised to prepare a letter requesting a time extension for IDIS Activity No. 1250. The City sent a letter to the CPD Director of the HUD-Pittsburgh Office on October 24, 2016, which was then forwarded to HUD- Headquarters. The City has not received approval of that request from HUD- Headquarters, and instead it appears that HUD-Headquarters wants to disallow all the developmentcosts for the Fairfield Gardens Project. The final draw down of funds was made on August 18, 2016 for a total drawn down amountof $2,185,397.72. Through the efforis of the HUD-Pittsburgh Office, the HOME funds were unblocked by HUD-Headquarters on February 6, 2017, for one dayto allow the City to draw down the

balance of the HOME funds in the IDIS Account for Activity 1250 in the amount of $910,793.69 which was reallocated to a new IDIS activity number. The City did draw down the balance of the funds in Activity 1250, but was instructed not to enter the accomplishments and close out the project in DIS, which the City could have done at that time. HUD-Headquarters has requested numerous back-up documentation on this project and the HDC. The City of Huntington has complied and addressed each request from HUD-Headquarters. All the City’s HOME funds are blocked, and the City cannot draw down any HOMEfunds for its other approved activities. This has caused delays and hardships on the homebuyers whoare eligible to receive HOME funds through the City's Homebuyer Assistance Program, but cannot close on their home because the City cannot access the funds for their loan closing. HUD-Headquarters is not cooperating, and has not respondedin a reasonable amountoftime to the City. The City is requesting its Congressional Delegation to intervene on its behalf so the HOMEfunds can be unblocked, the Fairfield Gardens Activity can be closed out successfully in IDIS, and the City can continueto assist its other sub-recipients. It is not fair that the other sub-recipient projects and the homebuyers are on hold because the City cannot access HOMEfunds.

OFFICE, (CD 2183 Ravaurn House OFrice BULOING Wasiineton, DC 20518-2206 FRED UPTON my DisTRIcT, MICHIGAN (202} 225-3761 ENERGY AND COMMERCE Fax: (202) 225-4986 SUBCOMMITTEES: HOME swencuorenence"Congress af the United States Tosa ENERGY AND AIR QUALITY . KALAMAZOO, Mi 49007, House of Representatives Fae(26a)a02088 800 Cenrre, Sure 106 800 StSTREET Sr. JOsErH, Ml 49086 (288) 982-1986 November28, 2007 Fase (269) 982-0237 werw housa.goviupton E Mau: [email protected] Mr, Louis Berra Field Office Director U.S. Housing and Urban Development 50 Louis Street Grand Rapids, MI. 49503 Dear Mr. Berra: Thisletter is in reference to Harbor Light Metals, LLC in Benton Harbor, Michigan. This minority owned business is seeking to be included in a Federal HUB Zone. Jn order for Harbor Light Metals to receive this designation, they must be located in a censustractthatis eligible for the Low Income Housing Tax Credit Program, whichis under the jurisdiction of your agency. I have included letter from the U.S. Small Business Administration and Harbor Light Metals. The companyis located in the City of Benton Harbor, one of the most economically distressed communuties1n the country. Itis my desire to be responsiveto all inquiries from the people of the Sixth Congressional District. I would greatly appreciate your consideration,findings, and views conceming this issue. I look forward to hearing from youat your earliest convenience. Thave toured this facility personally, and believe the company is poised for significant growth in both sales and employment with the right incentives in place. Please contact myDistrict Representative, Al Pscholka, at (269) 982-1986 if you have questions. Thank you for your assistance. Very truly yours, 44 Fred Upton Member of Congress FSU:ap

U.S. SMALL BUSINESS ADMINISTRATION WASHINGTON, D.C. 20416 & z% ‘ 1953 (uBR November 16, 2007 The Honorable Fred Upton Member, US House of Representatives 800 Centre, Suite 106 St. Joseph, MI 49085 Dear Congressman Upton: Thank you for your recentletter on behalf ofMr. Robert Taylor, Business Development Managerfor Harbor Light Metals, LLC This facility is located at 900 Alreco Drive, Benton Harbor, MI, which is an address just outside the borderofthe U.S. Smali Business Administration's (SBA) HUBZone parcel located in Niles-Benton Harbor. Mr, Taylor is requesting that Benton Harbor’s location be classified as a HUBZoneparcel so the firm might benefit from the HUBZone Program’s goal of stimulating job creation and capital investment in economically distressed communities. Public Law 108-135 (The HUBZone Act of 1997) directs the SBA to rely upon definitions provided by other Federal agencies to determine whichareas qualify as HUBZones. In the case ofBenton Harbor,it is located in the metropolitan county of Ghaummes; By statute, properties in metropolitan counties can only be designated for the HUBZone Program if the parcels (census tracts) are first determined by the U.S. Department of Housing and Urban Development (HUD)to be eligible for the Low Income Housing Tax Credit Program (LIHTCP). Berrien County contains cight such tracts, census tracts ‘26021000300’, ‘26021000400", ‘26021000500’, ‘26021 000600", 26021002100’, ‘26021002200’, ‘26021002300’ and ‘26021020500’. The census tract in question, ‘26021002500,’ covering the address 900 Alreco Drive, does not appear on HUD’slist of qualified census tracts stemming from the decennial census of either 1990 or 2000. The SBA,therefore, does not have the authority to move beyond the provisions of PL 105-135 to extend or to create a HUBZoneareain metropolitan countics unless that location1s first found to be eligible for the LIHTCP.

The Honorable Fred Upton Page Two Benton Harboris located in a metropolitan county and therefore does not qualify under the set of criteria below: Thedefinition for a qualified county is any county that, based on the most recent data available from the U.S. Census Bureau,is not located in a metropolitan statistical area and in which the median household income1s less than 80 percentof the median household incomefor the entire non-metropolitan area of a state and/or any non- metropolitan county that, based on the most recent data available from the Bureau of LaborStatistics (BLS), has an unemploymentrate thatis not less than 140 percent of : the state average unemploymentrate or the national average unemploymentrate. a. Information on decennial census data used to determine the household income 1s available on the web at http://www census.gov/main/www/cen2000.btm) | b. Information in the local employment data used to determine the | unemployment elementis available on the web at http/Awww.bls.gov/tau/home.htm#data : Lf you have additional questions, please contact the Office of Congressional and Legislative Affairs at (202) 205-6700. Thank you for your support of the small business community. Sincerely, Sine Michael McHale Director HUBZone Program

Ligh Harbor ight tals, LLC Harbor Light Metals, LLC Aluminum Scrap Metal Processors P.O, Box 703 Benton Harbor, Michigan 49023 October 15, 2007 Congressman Fred Upton 6" Congressional District 800 Ship Street, Suite 106 St. Joseph, MI, 49085 Re: HUB Zone Designation Dear Congressman Upton: HarborLight Metals (HLM), is a companylocatedin the City of Benton Harbor, formed June 8, 2005 by Dorie Reid Sr., and Dorie Reid II (African-Americans) as a Manufacturing source to support sales generated by their brokering activities and for the purpose of providing Aluminum Scrap Metal Recycling Melting services to the Metals Industry. The company was established after determining that there were excellent business opportunities for a Minority Owned Smelting Companyto fill a void in the Recycling of Aluminum Scrap Metals. We are seeking your assistance with resolving HUB Zone ineligibility with the SBA. HLM doesn’t qualify for HUB Zone designation because we have been placed in a censustract that’s ineligible for HUB Zone designation, despite being located in the City of Benton Harbor, a HUB Zone. Harbor Light Metals LLC currently provides recycling services to the Automotive Industry and their Tier 1 Suppliers. Harbor Light Metals Plant Facilities is located at; 900 Alreco Rd, Benton Harbor Michigan. The facilities consist af (2) two buildings totaling 226,000 sq. ft. on 14.39 acres of land. The basic machinery includes (2) two Rotary Furnaces, (1) one Reverb Furnace, and (1) Pulverizing Shredder, Semi Tractors, Semi Trailers, and Several units of Rolling Stack Equipment.

The Company’s recycling services are produced. marketed, and sold nati ide. ¢ 1 ; ly sol jonwit servicing industries that are concerned with producing ecolo; ical sustain 5 . pl ig gically sustaining products With HUB Zonedesignation, Harbor Light Metals LLC intends to ex its’ busi \ > ‘pandits’ business t include the Aerospace and US Defense (Suppliers) in the near future. Recycled Aluminumtranscends the marketplace with over 90% recaptured and recycled into products within automotive, acrospace, consumerdurables andarchitectural applications. There are currently 23 employees (seventy percent (70%) reside in the Ci ‘ u of Benton Harbor) with current projected growth, HLM will, at minimum, create an Dedtion 20 jobs. The opportunities that the HUB Zone provides will allow HLMto create additional jobs opportunities with current growth. Harbor Light Metals, LLC currently management team have over 75 combined years of experience in Secondary Smelting Processes, including; plant and production operations, raw material purchases, sales and executive management. This management team gives Harbor Light Metals comprehensive working knowledge of virtually every aspect of Secondary Aluminum Smelting. Sales for the company was $1,988,000 for the fiscal year ended December30, 2006 ( six months of manufacturing), and sales are projected to over $9,000,000.00 for fiscal 2007, pending added production capacity and increased work force of an additional 20 employees. If there are any further questions or concerns please feel free to contact me or Robert Taylor, Business Development Managerat 269.926.4567, Thank You. <_Sincerely, Harbor Light Metals, LLC Business Development Manager Ce: Al Pscholka Dorie Reid, President Dorie Reid If, Vice President

Page 4 of 4 RESOLUTION: FINE Attached file is scanned image in PDF format. This file can be read by Adobe Acrobat Reader. The reader can be downloaded from the following URL: http: //www.adobe.com/ Rose Meyer MSHDAExecutive Office 517-373-6022 Fax No: 517-373-7657 12/4/2007

ISH} SMMcy f ft ut] 3 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ‘ i i WASHINGTON, DC 20410-1000 “au, a ves . . OFFICE OF CONGRESSIONAL AND INI ERGOVERNMENTAL RELATIONS JAN 14 2008 The Honorable Fred Upton Member, United States House of Representatives 800 Centre, Suite 106 800 Ship Street Saint Joseph, MI 49085-2182 Dear Representative Upton: Thank youfor yourletter of November 28, 2007, requesting that Census Tract 0025 in Bemen County be designated a Qualified Census Tract (QCT),allowing businessesin this tract to receive priorities for federal contracts under the HUBZone program. Qualified Census Tracts (QCTs)are defined in Section 42 of the Internal Revenue Code for the purposesof the Low-Income Housing Tax Credit program (LIHTC). The purpose of QCTsis to provide additional tax credits to developers who locate low-income rental units in low-income or high poverty areas. To be eligible for designation as a QCT,a census tract must have at least 50 percentofits households with incomes below 60 percent of the Area Median Gross Income (AMGDorhave a poverty rate of at least 25 percent. QCTsare re-designated as new census data becomeavailable. Using the most recenttract-level data available, which is from the 2000 decennial census, Tract 0025 in Berrien County had 35 9 percentofits households below 60 percent of AMGIanda poverty rate of 19.9 percent. Thus,the tract does not qualify for QCT eligibility undereither of the twocriteria. Dueto the limited authonty granted to HUD under the LIHTC statute, the Department cannot take action to grant QCTstatusto this tract. The Department would like to re-emphasizethat 1n order to qualify for the HUBZone program,a tract must be a designated QCT,not simply ehgible for the LIHTC program. Indeed,all tracts in the U S.are eligible for the tax credit program; however, only those designated by HUD as a QCTare eligible for additional subsidy under the LIHTC program, andfor the HUBZone program. Thope you find this information to be helpful. Please let me know if I can beof further assistance. Sincerely, Mark A.Studdert General Deputy Assistant Secretary for Congressional and Intergovernmental Relations www.hud.gov espanol.hud.gov

> a Nov-05-20°3 0144 PM Rep Fred Uptor (MI-O6} 269-982-0237 2/3 FRED UPTON fm Bistact, MionGAN OFFICN: 1 2163 Ravounn Mount Orvce Bur.DING Waguinaron, 06 20818-22068 (202) 228-4701 COMMITTEE ON : ENUAay AND COMMARGR Faw (202) 228-6966 Cuasninan HOME Congress of the United States "VHTaNme Wouse of Representatives / aye1260)305-208 October 28, 2013 Seo08xSemcey ‘Sr, JOSEPH, MI 49088 (269) 682-1988 Fax: (205) 682-0237 brpvtuptan.house.gav Mr, Bernard Fulton Deputy Assistant Secretary for Congressional Relations U.S, Department of Housing and Urban Development 451 Seventh Street, SW, Room 10120 Washington, DC 20410-1000 Dear Mr. Fulton, Thisletter is in reference to concerns brought to my attention by Superior Property Management {SPM)of St. Joseph, Michigan. Superior Property Managementreceived communication from representatives of [CF International (ICF), explaining that SPM had been selected for review as part of the U.S. Department of Housing and Urban Development, Quality Control for Rental Assistance Subsidy Determinations Study (HUDQCStudy). Thave been advised that SPM has every intention to continue to be cornpliant with all federal tules and regulations to which prapecty management organizations must adhere. However, SPM has raised concems that adhering to the request for information from ICF would put SPM in direct violation of privacy standards upheld by HUD,and demanded by the tenants oftheir properties. ICFprovided SPM letter from Dr. Kurt Usowski, Deputy Assistance Secretary, HUD Office of Policy Development and Research, The letter indicates that HUDQCfield interviewers will need to review tenantfiles, photocopy documents, and conduct off-site interviews with households selected during the study. The letter goes on to explain that field interviewers may be granted full access the documents which constitute Enterprise Income Verification (EIV) data, and that field interviewers do not need to review and sign the Rutes ofBehavior for EV. The letter explains that in their role as data collectors, field interviewers are performing their review as an extension ofHUD headquarters and are granted the right to full access of EIV data. Based on information received by myoffice,it is my understanding that all SPM employees musi be certified to gather data for the EIV system. [ have also been informed thatin the past, on-site auditors from HUD have been required to adhere to all ELV guidelines. For the HUDQCstudy, will ICF employees be adhering to all EIV guidelines regarding privacy ofpersonal information? In particular, please explain how [CF employees will be adhering to the same directives required of SPM,as outlined in the attached documents from HUD,provided 12 58 03 2013-11-05 Eastern

Ape Nov-05-2013 0144 PM Rep Fred Upton (M:-06) 269-982-0237 373 to SPM.In addition, please explain how the EIV guidelines allow for ICF employees to photocopy and maintain sensitive documents from tenantfiles. Toensure the proper handling of sensitive client information, how have ICF employees been trained to handle this information? What safeguards are in place to ensure the privacy of the information accessed and obtained by ICF employees as they conduct this survey on behalfof HUD? How have ICF employees been vetted for accessto this private information? Finally, what is the purpose ofthe HUDQC study? What benefit will this study provide to HUD, and HUD’sdelivery of services to constituents? Please know that I ask these questions to ensure the privacy of my constituents, while also ensuring the integrity of the important programs andservices administered by HUD, Thank you in advance for your assistance in being responsive to the concerns of constituents and organizations from Michigan’s 6" Congressional District. ] look forward to hearing from youat your earliest convenience. If you desire additional information,please feel free to contact Mr, Clay McCausland vie phone, (269) 982-1986, or email, clay.mccausland@mail_house.gov. Sincerely, Lal: Fred Upton Member of Congress FSU:cem 2 §8 03 2013-11-05 Eastern

7 : LS, DEPARTMENT OF HOUSING (ND LRBAN DEVELOPMENT a thi . : WASHINGTON DC 20410 LOQ0 : : ASSISTANT SECRETARY FOR CONGRESSION AL AND INTE RGON ERNMENT AL REL TIONS The Honorable Fred Upton US House of Representatives Washington, DC 20515-0001 Dear Representative Upton: Thank you for yourletter, concerning the selection of Superior Property Management in the Department of Housing and Urban Development’s (HUD) Fiscal Year (FY) 2013 Quality Control for Rental Assistance Subsidy Determination Study (HUDQC Study) being conducted by [CF International (ICF). The following information 1s from HUD"s Office of Policy and Development Research. The HUDQCStudy provides national estimates of the extent, severity, costs and sources of tent errors in tenant subsidies for Public and Indian Housing (PIH) that admmmuistered Public Housing and Section 8 and Office of Housing Owner-admunistered programs, both separately and in combination. The study doesnot involve an audit of individual Public Housing Authorities (PHAS)or projects, nor does it monitor the implementation of housing programs. Its singular focus 15 to idenufy households for which an error was made inthe calculation ofthe amountof the houschold’s rent subsidy and to provide nationally representative findings related to these errors During the conductof the HUDQCstudy, ICF’s staff adhere to a senes ofdata collection handiing procedures to maintainthe security of the confidential tenant informationthat 1s collected. Enterprise Income Verification (EIV) is mcluded m the informationthat 1s collected Prior to beginingtheir duties on the study, all ICF’s staff are required to sign anofticial confidentiality and non-disclosure document certifying they will protect the confidentiality of these data (both on paper and electronically) at all umes. Violations of this confidentiality and non-disclosure document are reported to HUD and would result in reprimand — although nocase of privacy violation has ever been reported since the inceptionof the annual HUDQCStudies 20 years ago. In addition to these measures, the data collection processes used in the HUDQC Studies are approved by the ICF’s Insututional Review Board (IRB) that reviews research projects to ensure the protection of human subjects. For the study, {CF’s staff collect data on a sample of 2,400 households. from 60 primary sampling units and 600 projects in the entire United States including documents which constitute EIV data. At the project site. ICF’s field interviewers photocopy EIV forms for sampled households and use FedEx to send these materials securely to headquarters in Maryland. Each FedEx package ts assigned a unique tracking numberand the ICFs headquarters staff ensure its receipt. While at study headquarters, all confidential material (tncluding EIV) 1s located in a controlled-access survey room, which 1s focated ina secure buildmg. All ETV printouts are securely shredded once data collection has concluded, ~ px. www.hud.2ov espanol.hud.pov

At the proyect site ICF’s field interviewers also enter data into an encrypted and password protected laptop computer. Data are transferred to study headquarters by mdividualfield interviewers via an encrypted Secure File Transfer Protocol (SFTP) process. Electronic data are stored on secure servers that are consistent with National Institute of Standards and Technology (NIST) moderate guidelines. Access to the data is limited to staff working on the HUDQC Study. In response to your question about the benefits of the HUDQCStudy, please note that the study 1s required by law. To further institutionalize federal agencyefforts to eliminate improper payments, President George W. Bush signed the Improper Payments Information Act (IPIA) of 2002 (Public Law 107-300) into law on November 26, 2002. The central purpose of the IPIA ts to enhance the accuracy and integrity of federal payments. To achievethis objective, the IPIA provides an initial framework for federal agencies to identify the causes of, and solutions to improper payments In turn, guidanceissued by the Office of Management and Budget (OMB) in May of 2003 (Memorandum 03-13) requires agencies to: (1) review every federal program, activity, and dollar to assess risk of significant mproper payments; (11) develop a statistically valid estimate to measure the extent of improper paymentsin risk-susceptible federal programs, (1) mitiate process and internal control improvementsto enhance the accuracy and integmty of payments; and (iv) report and assess progress on an annualbasis. A more recent OMB guidance, issued as Part [1] to OMB Circular A-123, Appendix C (M-10-13), reinforces the need for federal agencies to reduce improper payments and establish reporting requirements Most recently, President Obamasigned the Improper Payment Elimination and Recovery Act (IPERA) of 2010 (Public Law 111-204)into law on July 22. 2010, which further amended the IPIA by providing guidance to improve agency efforts to reduce and recover improper payments. T hope youfind this informationhelpful. Please let me know tf I can be offurther assistance. Simcerely, ms GQ Dominique M. McCoy General Deputy Assistant Secretary for Congressional and Intergovernmental Relations

s Now-19-2014 0255 OM Rep “red Upton (Mi-Gé) 269-982-0237 23 The Privacy Act of 1974 prohibits the faderal governmentfrom releasing any information trom personal files of individuals without the express written permission of the person involved. Disciosure of personal raconds to 8 Congreseman acting on behalf of a constituent is prohibited, unless the Individual to whom the record pertains has consented, Please print. Name:HOIG] Date of Birth: 02/03/1973, Street Address: 414 River Street Apt # Click here to enter text City: Allegan State: Michigan Zip Code: 49010 b}E, Home phone: Pre) Felt phonel?) ICY Email Address; wo) Social Security Numb Other numbers identifying your case: Pha case number {0)6) Caliber sccount number) Federal agency involved; HUD,prior ticket number 428727, haven't received a new ticket number yer, Pleaseprovide a briefdescription ofthe problem and attach addittonalsheets, ifnecessary: When Caliber took over the loan, I had difficulty getting thei to respond, or know anything about my 203K Loan, I filed a complaint, and eventually was contacted (never by Caliber) but by Renovation Ready, who had been subcontracted to handle our loan. My contract was set to end 8/8/14. This was already an extension because ofthe weather, the change in mortgage holders, and miscommunication to our 203k Consultant. [ talked with Michelle Rood at Hud, re: ticket number 428727 — ans she told me | would be contacted by Lucas Byers at Caliber by Wednesday. I was not, I called her beck Thursday and left a message, I was contacted by Larry Manchester with Renovation ready. This was in June. We submitted a draw request, and a second one. I received them In August, butat this point the contract had expired. My contractor wasn’t willing to continue withaut payment, but he had net provided us with Lein waivers and receipts as requested. We told him to bring those and | would sign and give him the check. While he was coming to my hometa do this, he had a stroke. So now I have this check, I have subcontractors that need to be pald, threats ofLeins on my home, my consultant1s weekly calling and emailing Larry at Renovation Ready and getting no response, Finally he reaches someone and leams Larry is no longer thera, anid they couldn'tfind our contracts. After another week, he heard beck, that they were no Jonger handling Calibar's accounts. So we went back to trying to contact Callber. The Conultantleft a message with Omar Elashi who 1s supposed to be our contact at Caliber ~ 469-242-1077, email [email protected], | have sent an email a week, also forwarding the previous weeks emails. 1 have done this for three weeks now. | am sending them to Lucas Byers, Omar Elashi, Kristin Pickering, and Jennifer Roma who wereall “contacts” given to me by Larry Manchester when he worked for renovation ready. In the mean time, ow’ consultant has contacted Legal, he has contacted Flagstar because they originated my foan trying to get a contact at Caliber. We are asking for them (which | also emailed Jennifer Roma about on August 27, 2014) fo reissue the last draw to just me, ar me and a 3party so that [ can get these subcontractors paid. We had a gentleman who was willing to step in for our 14 20 05 2014-11-19 Eastern

Nav-19-2014 0255 PM Rep Fred Upton (MI-06) 269-982-0237 3/3 contractor and finish what he had left, but because the bank didn’t answer, he is ne fonger interested because he doesn’t think he will get paid. Our one year anniversary in aur home ls next Wednesday. Caliber has now wasted over 6 months ofour time, We can’t get anyone in to finish the work because the Bank wonjt answer us. Iam paying interest on this money thatis supposed to be setaside for renovations and cen’t get i‘can't got a person to talk to me. Please Help me get my homefinished, I thought [ bought my dream home,I eoulda’t wait to spend my first Christmas in a beautiful remodeled home. I am now approaching my second Christmas with no heat upstairs, a partially installed furnace, no updated electric,trash stacked all over my hard from a barn teardown, dead grass patches, old old windows that were supposed to be replaced, poor plumbing that was to be replaced, honestly — no one job has been completed. It has become a nightmare! [ enteredinto this loan because I wanted an older,homewith clasa and charm, but it needed updates, Now [ have still beautiful home with charm, butI freeze at night, I can’t make a cup of coffee and blow dry my hair at the sametime,its just 30 depressing. Thank you for yourtime, \ |, the undersigned, hereby authorize the release of ail pertinent information to and by Congressman Upton orany authorized memberofhis steff to maka an inquiry on my behalt, | Signature: (b)(6) Dete: Lined. . 1 4 20 05 2014-11-19 Eastern

Oh ASSISTANT SECRIT ARS LOR CONGRLSSION41 AND INEERGOSFRNMEN EAL RET ATIONS +. US. DEPARIMENL OF HOUSING AND URBAN DEVELOPMENT | WASHINGTON DC 20410LUGO The Honotable Fied Upton Member, United States DEC 09 a House of Representatives 720 MainStreet St Joseph. MI 49085-1317 Dear Representatise Upton Thank you for yourletter of November 19. 2014. on behalf of your consutuent, Ms who 15 experiencing problems with her 203(k) flown The following information is irom the Department of Housing and Urban Development’s (HUD)Office of Housing The Depatment is currently conducting a review of this matter Upon completionof the leview, a (mal response will be provided Thope this information ts helpful [fT can be of further assistance, please let me know Sincerely, Lika Ll Moritsugu Assistant Secretary for Congressional andIntergovernmental Relations wan hud.gus espanolhud.gov

“th "y U.S. DEPARTMENT OF HOL SING AND URBAN DEVELOPMENT it . WASHINGTON DC 20410-1000 ASSISTANT SECRETARY FOR CONGRESSIONAL AND INTE RGOVERNMENTAL RELATIONS The Honorable Fred Upton Member, United States JAN 99 2015 House of Representatives 720 Main Street Saint Joseph, MI 49085-1317 Dear Representative Upton. Thank you for your letter on behalf of your constituent. Ms. aboutproblems she experienced in the process of rehabilitating a property thatis insured by the Federal Housing Administration (FHA) under Section 203(k) ofthe National Housing Act. The property is located at 414 RiverStreet in Allegan, Michigan. The following informationis from the DepartmentofHousing and Urban Deselopment’s (HUD) Office of Housing. In order to perform a thorough review, EIUID has recalled the original F HA case binder from the mortgage lender, Caliber Home Loans, Incorporated, and ads ised them ofthis complaint. HUDhas also requested that the 203(k) consultant, Mr. Timothy M. Riley, to conduct a thorough review ofthis case, including a re-inspection ofthe property to provide the Department with a full report. HUD’s staff will contact Ms oncethey have received and reviewed the FHA case binder, and the responses from both the lender and the 203(k) consultant. IfMs requires additional information or wishes to discuss this matter further, she may contact Mr Charles Newman, Construction Analyst. in HUD’s Philadelphia Homeownership Centerat 1-215-861-7521 i hope that this information is helpful in responding to your constituent. [f | can be of further assistance, please let me know. Sincerely. Erika L. Moritsugu Assistant Secretary for Congressional and Intergovernmental Relations www hud.gov espanolbud.gov

Congress of the Anited States Wiashingtan, BC 20510 March14, 2016 ‘The Honorable Julian Castro Secretary Departmentof Housing and Urban Development 451 7" Street, S.W. Washington, D.C. 20447 DearSecretary Castro: Wewrite in strong support ofthe Promise Zone application submittedforthe City ofFlint in partnership with the United Way ofGenesee County. As you know, the Promise ZoneInitiative is designed to drive economic growth, create jobs, and increase safety and public health in disadvantaged communities. For decades, the City ofFlint has faced significant challenges that have negatively impacted the quality of life for City residents. These challenges stem primarily from years of substantial job loss in the region. The tecent public health ciisis in Flint, caused by dangerous levels of lead in the City’s drinking water, has undoubtedly compounded previous challenges and will have a far reaching effect for years. The full scope and damageofthis public healthcrisis may not be knownforsometime to come, Despite steep challenges, the City of Flint — in collaboration with local and Federal stakeholders — has demonstrated a resilient ability to create positive changeinthe region. In 2010, the City of Flint used a HUD Sustainable Communities Challenge Grant to begin work onits long-terin Imagine Flint Master Plan. This Master Plan has received widespread support, including over $1 miilion collars in private funds and the extraordinary community engagement ofover 5,000 focal 1esidents, The City of Flint’s Promise Zone application builds on the successfil Imagine Flint Master Plan, with goals of promoting health and access to health care, building community infrastructure, improving educational apportunities, reducing violent crime, increasing economic activity and creatingjobs. Importantly,this applicationwill continue and expand a robust, data-driven, and collaborative framework that includes a broad and diverse group of stakcholders. Initiatives currently undemway include the Building Neighborhood Capacity Programfo increase capacity forgrassroots organizations, Suong Cities Strong Communities brownfield redevelopment at (wo fo1merauto plants in the city, and the Byrne Criminal Justice Initiative where four partner institutions ave actively using a data driver approachto enhance public safety.

We believe this application presents a unique opportunity to deliver critical support to a community with great need and a demonstrated willingness from private and public pariners to implement our shared vision for a better Flint. A Promise Zone designation will allow the City of Flint to leverage Federal resources moteeffectively and provide stakeholders with additional support for coordination, accountability and oversight, We urge youto give this application your utmost consideration. Sincerely, Clam Zea Debbie’ enow U.S.Senator USS. Senator . e ee aniel Kildee Memberof Congtess eek? Len Sander Levi Fred Upton Member6 Congress Member ofCongress GorbiceXp _ Candice Miller Tim Walberg cy Member of Congress Memberof Con; (rth Dan Benishek Bill Huizenga Member af Congress Memberof Con;

(LALdub,- Mike Bishop Memberof Congress . ‘faved alaeaw Memberof Congress CytWRa Dave Trott Memberof Congress NebiedNy Debbie DingellNye Member of Congress Pefeboons John Moolenaar Memberof Congress

s ty oa 8 attr o, ”AH US. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Ih lh WASHINGTON DC 20410 1000 AMIN anoe ot U8 9, OFFICE OF CONGRESSIONAL AND INTFRGOVERNMENTAL RELATIONS JUL 2 § 2018 The Honorable Fred Upton U.S. Houseof Representatives Washington, DC 20515 Dear Representative Upton: Onbehalf of Secretary Julian Castro, thank you for yourletter in support of the City of Flint in partnership with the United Way of Genesee County. The following information 1s from the Departmentof Housing and Urban Development’s (HUD)Office of Field Policy Management. On June 6, 2016, the Administration announcedthe third and final round of Promise Zone communities. For the Third Round Promise Zane competition, HUD received 64 urban applications from 29 states and the Commonwealth of Pucrto Rico. Representatives from across the federal government spent countless hours reviewing and evaluating applications. It was a very cifficult decision because wereceived so many strong applications with compellingstrategies. Unfortunately, the City ofFlint in partnership with the United Way of Genesee County was not designated a Promise Zonein the final round of the competition. The Department looks forward to partnermg in other ways and I am pleased to inform you that the City of Flint nm partnership with the United Way ofGenesee County was nameda Finalist. Thepurposeof selecting Promise ZonesFinalists is to recognize communities whose applications teflect high-quality strategies underthe criteria set forth im the Application Guide, but are not selected as oneofthefive third round designees. HUD Regional Offices will contact Finalists in the near future to discuss next steps in the process. HUD plans to work with Finalist communtties to help advancepriority projects idenufied in their Promise Zone applications. In addition, the particypating federal agencies will communicate regularly with Finalists about programs and innovative solutions that match local needs and strategies. However, no preference points or other Promise Zone designation benefits will be given to Finalists. The Departmentappreciates your support of the Promise Zone Initiative and commends the fine work and collaboration that has resulted in the City of Flint wn partnership with the United Way of Genesee County being named a Finalist Please let me know if I can be of further assistance. Sincerely, De eG Erika L. Moritsugu Ssistant Secretary for Congressional and Intergovernmental Relations wwwhud.gov espanol,hud.goy

Congress of the United States Washington, DC 205135 November 15 2016 DearSecretaries. Administrators, Directors and Commissioners Farlier this year, President Obama's Chief ofStaffstated that the Administration will “do audacious ecutive action throughout the course ofthe rest ofthe year“! As youare aware. suchaction often mvolves the exercise of substantial policymaking discretion and could have far-reaching impacts on the American people and economy. Considering these potential consequences, we write lo caution you against finalizing pending tules or regulations in the Administration’s last days. Byrefraining from acting with unduchaste, you will ensure that agency staff mayfully assess the costs and benefits of rules, making it less likely that unintended consequences will harm consumers and businesses.” Morcover, such forbearance is necessaty to afford the recently elected Administration and Congress the opportunity to review and give direction concerning pending rulemakings.? Should youignore this counsel. please be aware that we will work with ourcolleagues to ensure that Congress scrutimizes your actions — and, if appropriate, overturns them — pursuant to the Congressional Review Act 4 ex “ Sincerely, AVS Kevin McCartthy oN Tlouse Majority [ cae 5 Services 1David Cook White House chief of staff promises ‘audacious erecutice action’, CHRIST] \N SCIENCF MONITOR (Jan 13, 2016) hitpis ww cxmonitor_com/USA/Politics/mouitor_breaktast/2016/0113/White House chiet of staff promises audacious-executive-action (emphasis added) ? Other aspects of the rulemaking process are diminished when administrations issue “midnight” rules, lowering the quality of the fnal product The Office of Information and Regulatory Affairs (OIRA) has hmited opportunityto review ‘midnight’ rules, “and neither agency nor OIRA personnel have sufficiently strong incentives or latitude to conduct searching analyses of whether the rules should or should not be issued or modified H Cons ON 1HE JUDICIARY MIDNIGHT RULFS RETITT Act or 2016 H Rep No 114 782, pt 1 at 2 2016) + Ondanuary 20 2009, President Obama’s Chiefof Staff requested that the headsof executive departments and agencies refrain fiom finalizing new rules winting that “[)]t 1s important that [the Pyesident’s] appointees and designees have the opportunity to review and approve any neworpending regulations’ We respectfully submit that the sentiment animating President Ohbama’s guidance18 as applicable today as it was almost cight years ago, and that democratic accountability requires that all agencies even so-called independent agencies — temporarily refram from finalizing rules HUTS C §§ GOI ef seq

Michael Conaway lJal Rogers Chairman Chaitman House Committee on Agriculture House Commutice|on Appiopnations ac Thornberry Whew ace_ Chairman Chairman House Committee on Aimed Services House Committee on the Budget red Upton Chairman Chanman House Committee on Education and House Committee on Fnergy and Commerce the Workforce Q2 ue Charlie Dent oyee Chairman Chairman House Committee on Ethics House Committee on Foreign Affairs Wed med CrdMth Michael McCaul Candice Miller Chairman Chairman te on Homeland Security House Committee on House Administration ISA Neola Bob Goodlatte Rob Bishop Chapman Chairman “ Hoplse ( itfee on tho udicialy House Commuttce on Natural Resources / 7 tux 4 nl son Chaftet7 Chairman Chanman House Committee on Oversight and House Permanent Government Reform Select Committee on Intelligence

Chairman House Committee on Rules Steve Chabot Chairman House Committee on Small Business hairman House Committee on Veterans” Affairs CC All Federal Fxccutive and Independent Agencies Lamar Smith a @ Chairman House Committee on Science, Space and Technology tl Shuster Chauman Committee on Transportation and Infrastruswe, Sw evin Brad) Chairman Ilouse Committee o& Ways and Meas ~

FRED UPTON De OFFIC F uo orDr a ot Maino \ AVES Pays Heo Cora beri me —__ ey Worn eics BC 20815 7208 comnnrTee on lM eean32 4986 ENERGY AND COMMERCE / " Lf ANAL. IDVE CH ta S5OE Me nA rN Congress of the Cited States eT Wouse of Representatives peasaes lass womens 141 April 5, 2017 © hoa obs1968 Fos 12h) 982 6737 Sp ouponhs ov Stanley Hardy IV Congressional Liaison US Department of Housing and Urban Development 451 7th Street Southwest, Room 10120 Washington, DC 20410-0001 DearStanley, This ictter 1s in reference to Hape Network Mr. KO}O) CFO,contacted my office regarding the U S. Department of Housing and Urban Developement For your convement reference, and in accordance with the Privacy Act of 1974, I have enclosed a copy oflus privacy release form Becauseofthe desire of my office to be responsiveto all inquines, your consideration, findings and views concerning the enclosed will be greatly appreciated | look forwardto hearing from you at your carhest convenience. Thank you for your assistance. Verytruly yours. Fred Upton Member of Congress FSU:mf

Rich Fabrini Page 2 Apnil 3, 2017 Dear Congressman Upton, I give you permission to look into my difficulties with the U.S. Department of Housing and Urban Development LT understand that Jiys formis bemg used in compliance with the Privacy Act of 1974 \ oO —_ fh, Signature A l/ f ahs Le . NAME Oye) eye) CInef Financial Officer ADDRESS Hope Network 3075 Orchard Vista Drive Southeast Grand Rapids, MI 49546 muons. 616 2YP-—SMl. 2P-C/OP(PE cMAIL LFABE RMI © HOPE NET WU PK. ORG BRIEF DESCRIPTION OF THF PROBLEM(please print) [LEASE SEA ArTAcHep

HOPE NETWORK REQUESTED ASSISTANCE WITH AFFORDABLE HOUSING OPERATION Lilac Lane,Inc., Non-Profit Housing Corporation, d/b/a Village of Kalamazoo Apartments (VOK), is a 165- unit affordable property at 4411Lilac Lane, Kalamazoo,Michigan.! The 7-building complex wasbuilt in the early 1970s. Hope Network, a Michigan nonprofit, is the sole memberof VOK, whichit acquired in 1995 pursuanta LIHPRHA Capital Grant Agreement Thereis Project-based Section 8 subsidy for 33 units (20% of the units) and there was an interest reduction subsidy before the mortgage matured in 2014. Originally, when the current HUD agreements were executed in 1995it was anticipated that the Section 8 units would be expanded to cover up to 60% of the units, but that never occurred. The result has been substantial financial challenges. Hope has jong been subsidizing operations, and VOK owes Hope Network $608,181 as of October 31, 2016. Without additional Section 8 assistance as originally requested, the property has struggled since 1996, it continues to struggle even without a mortgage. It lost maney 12 of the last 14 years, and capital reserve deposits wereinitially too low to sustain long-term viability. Operating costs have increased 44% fram 2002 to 2015, from $734,262 to $1,056,182, as the property has aged. Net cashflow, including releases from capital reserves, has deteriorated steadily. Recentfires in 2013 (tenant caused) and 2014 (contractor caused} resulted in further challenges Additional financial information is shown as an addendum to this summary The property is now 44 years old and needssignificant rehabilitation and repairs. Estimates range from $7,500,000 to $9,000,000 Furnaces and A/C units are 20+ years old, as are roofs, while other elements are original. A $7,500,000 loan would cost $26,101/month ($313,212/year), which worksout to $158 perunit per month. A $9,000,000 loan would cost $39,151/month ($469,812/year), which is $200 per unit per month.2 Without additional Section 8 or other assistance,increasing the debt will put the financia! burden on the tenants. These tenants already struggle, and the cost of renovationswill result in higher rents — and could eventually price the umts out of the market. 1f a viable financial plan for the asset cannotbe putin place soon, the asset will financially collapse, the residents will be displaced and the seven buildings will be abandoned. Hope Network has been working with the Detroit office of HUD to find a resolution, but none has been identified. Hope Networkis seeking specia! consideration from the National Office of HUD to find a solution to these financial issues. Such special consideration could include one or more ofthe following: {1) additional project-based Section 8 subsidy wouldbe ideal, or (2) special support to enablesignificant debt to be placed on the property without putting excessive stress on the operating expensesor cash flow (e.g., a balloon note with no debt service costs), or (3) relief from the current LIHPHRA affordability restrictions, like the ability to use the incomelimits controlled by any tax credit refinancing, i.e 60% of medium income, or removal of otherrestrictions (4) We Request theuseof Residual Receipts returned to HUD from other Hope Network developments be used for capital improvements or considered a form of rental assistance, or (5) We request Flat Rents plus permission to market to a mixed incomegroup, or {6) a capital grant, or any otherrelief that may be available. Hope Network appreciatesefforts to help resolve this unfortunatesituation. 1 The former FHA # (HUD Project#) ts 047-44046-LOC-SUP ? Both loans assume a 35-year term at 3 87% interest and nothing down

HOPE NETWORK REQUESTED ASSISTANCE WITH AFFORDABLE HOUSING OPERATION ADDITIONAL FINANCIAL INFORMATION The original LIHPRHA Capital Grant Agreement provided Grant funds of $2,632,596 for repairs and rehabilitation. VOK agreed to comply with LIHPRHA,24 CFR Parts 84 and 248, and a Use Agreement,interalia The Use Agreement imposesaffordability restrictions and runs for the remaining useful life of the property, whichis at Jeast until 2046 — 50 years after the LIHPRHA grant.> 134 units are for households making less than 50% of the area median income (AMI), 20 units are for low income households(less than 80% AMI), and 9 units are for moderate income households (80-95% AMI). Rents for tenants without Section 8 are on a scale: the target is 30% of adjusted annual income, but never less than base rent and never more than market VOK requested additional Section 8 as part of LIHPHRA deal but that request was dened - HUD only agreed to honor the existing Section 8 contract. All affordability restrictions would have expired in 2014 when the mortgage matured, but for the LIHPHRA use agreement Nowthe property must remain affordableforits remaining useful life, but there is no subsidy to coverthe difference between what tenants can afford and operationalcosts. Net cash flow, including releases from capital reserves, has deteriorated rapidly and has been significantly short of the cash flow required to adequately maintain the property. - — — Op. Cash ' | Total Revenue Cost of Operations Flow w/o RIR Operating ~ Releases Cash Flow Releases’ \ [Ave 96 00 584,897 498,770 1,531 18132, | 4,111 Ave 01-05 782,295 694,926 (30,069) 34,4469 4,380 Avg 06-10 895,469 | 826,465 {125 415} 81,645 | (43,769) Avg. 10 15 1,026,231 987,274 (133,159) 54,097 (79,062) Forfurther information please contact: oyey oye) Hope Network Chief Financia! Officer [email protected] 616-248-5281 4 Had the original mortgage there been no LIHPHRAgrant agreement * Op Cash Flow is the net between revenue andcost of operations, plus principal payments and deposits to reserve account:

US. DEPARTMENT OF HOL SING 4ND LRBAN DEVELOPMENT WASHINGTON DC 20410 1000 “til ASSISTANT SECRETARY FOR CONGRESSIONAL ANDINTERGOS ERNMERTAL RELATIONS The Honorable Fred Upton Member, United States House of Representatives 350 E. Michigan Avenue, Suite 130 Kalamazoo, MI 49007-3800 Dear Representative Upton: Thank youfor your letter on behalf of your constituent. kOxe) who expressed concernsabout the financial situation at Village of Kalamazoolocated in Kalamazoo, Michigan. The following informationis from the Department of Housing and Urban Development's (HUD) Office of Housing. HUD’s staff in the Detrout Satellite Otfice was contacted aboutthe property, and indicated that a conference calf was held with Village of Kalamazoo on April 12, 2017. During the conferencecall. it was agreed that Mr. and his group would submit an amendmentrequest to the Low-Income Housing Preservation Home Recovery Act (LIHPHRA) Use Agreementthat covers the property. Mr. Fabbrini’s amendment requests will include a change in Income Limits and Rent Restrictions from Very Low Income Tenants (50 percent AMI) to Lower Income Tenants andto allowthe new ownerto receive annual distributions To date, those requests have not been completed or received bythe Detroit Satellite Office. The only business agreements that the Department has with the property are a Section 8 Housing Assistance Payment Contract that subsidizes 33-untts and an active Use Agreementthat expires in December 2045. Thope this information 1s helpful in responding to your constituent. If I can be of further assistance, please let me know Sincerely, Aaron Santa Anna Acting General Deputy Assistant Secretary for Congressional and Intergovernmental Relations wien hud.gos espanol.hud.gov

De OFFICE Ui 2183 Raveurn House Gerice Bucone WASHINGTON, DC 20515-2206 4202) 225-3761 Fax (202) 225-4986 FRED UPTON 6TH DistmcT, MICHIGAN COMMITTEE ON ENERGY AND COMMERCE CHAIRMAN MICHIGAN HOME QFF.CES. og 350 E MIctIGaN AVENUE Congress of the Gnited States Soe ase Katamacao, Ml 49007 House of Representatives vad1269)052808 . * 720 MAIN StREET April 19, 2017 5 JoneMesos Fax (269) 987-0237 httpupton house gov Mr. Michael Polsineili Acting Field Office Director U.S. Department Of Housing and Urban Development McNamara Federal Building 477 Michigan Avenue Detroit, MI 48226-2523 Dear Michael, This letter is in reference to Susan Doroh on behalfof Superior Property Management. Ms. Doroh contacted my office regarding her difficulties with the Department ofHousing and Urban Development. For your convementreference, and in accordance with the Privacy Act of 1974, I have enclosed a copy ofher privacy release form. Becauseofthe desire of myoffice to be responsiveto all inquiries, your consideration, findings and views concerning the enclosed will be greatly appreciated. | look forward to hearing from youat yourearliest convenience. Thank you for your assistance. Verytruly yours, Fred Upton Member of Congress FSU:ch

Congressional Inquiryfor Susan Doroh /Superior Property Management CONTENTS Case Information 1 Correspondence 6 Rent Comp Studies 22 Comparables 43 Utilities 51 Refinancing Process 55

DC OFFICE: $2183 RAYBURN HOUSE OFFICE BUILDING FRED UPTON WASHINGTON,DC 20515-7306 ” (202) 225-576: et DISTRICT, MICHIGAN FAX:(202) 295-4986 MICHIGAN HOMEOFFICES. COMMITTEE ON ENERGY AND COMMERCE o 350 EAST MICHIGAN AVENUE CHAIRMAN SUITE 130 KALAMAZOO, MI 49007 (269} 385-0039 FAX: (269) 385-2888 Q 720 MAIN STREET ST. JOSEPH, Mi49085 (269) 982-1986 FAX: (269) 982-0237 hitp./upion.house.gov Dear Congressman Upton, I give you permission to look into mydifficulties with the DEPARTMENT oF Housing AND URBAN DEVELOPMENT (Deud)— WASHING TON, 0.¢- lunderstand that this form is being used in compliance with the Privacy Act of 1974. Signature: Muar’ NAME: IN pan Piers “TownHouses { SuregionPeoreen Manncemenst 5 Susan ‘Doron. ADDRESSPRopeeTy! " oWwAG! * Suvepoe 407 Anwriteene Ave FByGy ST. JOSEPH, ME cos” EMAIL:| FBV) PHONE:309- 493-1330 SOCIAL SECURITY # DATEOF BIRTH BRIEF DESCRIPTION OF THE PROBLEM(pleascprint): The DePAarTMenT oc House ¢ URpan Devewwement, WaAsHwerod D.C, AND THE fivpeaser (Vameidee Peoreer Aovsods) ENGAGED By THE DEPALT MENT of Wousiig ¢ Uteanw DevéioPmert INT Dpto DRASTICALLY Repuce THE Séeron 8 2ENTS AT INDIAN Hrs Town Houses +N DowsGiace, HT to levers St GHTLY Lowet Hien AgPeoves al ADOT. - 10 yenes poo, The Rest ComPAdaBierry Sruvies PLE PACED BY DAUD Awd VAL BeGE CoNThinl SIGNIfiCANT Ef@oes. “THEIR PRoPesen Bento ALE ND SUFFICIGUT To PAY THE ELTING MORTaKGE DAYMEN £DPELETAS ELPENSES. v ( 10 INTEND to CokeeT” hee ERROLS, Gfmore spaceis needed, please use back ofpage.)

April 14, 2017 To: Congressman Fred Upton Re: Indian Hills Townhouses 400 Cleveland Street Dowagiac, MI 49047 40 Unit Townhouse praperty with Section 8 Rental Assistance FHA Number: 047-11040 Property ID : 800010237 HAP Contract #: MI33L00019 in Novemberof 2016, an Appraisal Report was received from Valbridge Properties, an appraisal firm engaged by the Departmentof Housing and Urban Developmentfor Indian Hills Townhouses. This report, intended to determine appropriate rent levels for indian Hills Townhouses contained numerous significant errors. The rents determined in this report will not support the operationsfor this property which provides decent, safe and sanitary housing for middle to low income families in Dowagiac, Michigan. The Ownersof Indian Hills Townhouses appealed this report highlighting inaccuracies. The Ownersreceived a response to the appeal from the Department of Housing and Urban Developmentin Washington D.C. The responseto this appeal did recognize someofthe errors in the report and made a few adjustments. However, their response contained additional errors and opinions. No representative from a HUDoffice physically visited Indian Hills Townhouses orany of the area comparables usedin this report. Many of the adjustments made on the Rent CompStudy (RCS) report that determined their rents were based on “personal” opinions and photosfrom the internet used for marketing purposes, rather than onfacts. Qur appeal included current photographs of the comparable properties which demonstrated the true condition of these properties which was not representedin the internet marketing photos. Wealso submitted additional information drawing attention to the oversights in the HUD response. HUD responded denying us further appeal. This is not acceptable. Errors must be corrected. The federal employees of the Departmentof Housing and Urban Developmentshould be working WITH the Ownersof these federal housing properiies for the commongoalof providing affordable, safe housing. Respectfull: eWilko, General Partner indian Hills Townhouses — = 207 Hawthorne Avenue = St 16506, M405 AT ime 269 983-7330 f269-983-5678 a — eS

APRIL 14, 2017 (INDIAN HILLS TOWNHOUSES DOWAGIAC, MI HUD PROJECT 047-11040 HAP CONTRACT MI33L000019 BASIS OF APPEAL Structures:- Line # 6 on Rent Comparability Grid indian Hilis is a “townhouse” property which includes one, two and three bedroom townhomes. Recap does nat consider the one bedroom a townhome.....but it is a townhome. An adjustmentfor a townhomestyle unit should not be based on the numberof bedrooms. A330 adjustmentis reasonable for each of the one, two and three bedroom units. Condition: - Line # 8 on Rent Comparabttity Grid Recap’s response is not acceptable. Theinitial appraisal report by Valbridge clearly discloses that the PAE (Valbridge} did not physically see the comparable properties, but rather gathered information and photos from the website. [It would have been impossible to rate the condition of the comparables as they reported in the Valbridge report if they hadvisited the sites. Photos taken and submitted with the appealare a true representation. The Engineering Report, dated November 2016, engaged by RECAPforthis process had noted only two physical condition remarks: Cracks in sidewalks $1,040 Cracks in asphalt $3,250 The HUD initial response to our Appeal did recognize someofthe errorsinvolving the condition of the comparable properties, however, their “opinions” on conditions based on internet photosis not accurate, Square Footage:- Line #13 on Rent Comparability Grid Webelieve that the square footage difference should be calculated consistently across the board to eliminate any discretion. The per square foot price that has been accepted in previous Rent Comp Reportsis $.22 per square foot. This would eliminate any need for personal opinions as to how many squarefeetis to be considered and whenit should not be considered. Extra Storage: - Line # 25 on Rent Comparability Grid The HUD DC responsetotheinitial repeal erroneously stated that the basement area was not heated.

There is a heat duct with registers in this basement area. We have experienced residents using this area for family rooms, hobby rooms, play area, etc. We disagree with Recap’s “opinion”that thereis only a “limited value that can be placed onthis area”. Based on the demand weare familiar with from applicants for these townhouse units versus our apartmentunits in this same neighborhood,this area Is valuable to the residents. KG) Heat; exe) oling|”” Cooking; Hot Water Theutility adjustments figures used in the HUD-DC Rent Comparability Grids are incorrect. e Utilities: - Line: The purpose ofthis rent comp studyis to determine the total costofliving at the subject property (Indian Hills Townhouses) versus one of the comparable apartmentunits, You mustuse the costs for the utilities based on the type used at the comparableproperty. For instance, at Hamilton Square Apartments, the rent is $425. However,in addition to rent, the resident has to also pay for their own electric for heating, cooking and hot water. The costs forthis electric has to be addedto their monthly rent to compareit to the Townhousesthat have the heating costs included in the rent. General The HUD appealrespanse received March 2, 2017, contained Rent Comparability Grids prepared by Minnie Monroe-Baldwinat the Departmentof Housing and Urban Developmentoffice in Washington B.C. These rent grids prepared by Minnie Monroe-Baldwin, HUD Office, D.C., contains two properties, Hillcrest Apartments and Village West Apartments, as comparables that were not included in the previousoriginal rent comparability study prepared by the Valbridge Appraisers, the subject of this appeal. The fact that these properties are included when they were notincluded onthe original report is questionable as is the source of the informationfor these properties.It is highly unlikely that the HUD staff in D.C. was able to actually visit this site in order to properly evaluate the conditions/locations, etc. Wheredid the HUD DCstaff obtain information on this property? Additionally, on the Rent Comparabiltry Grids for these two properties, there is a columntitled “Owners Comments”with adjustmentfiguresin these columns. The Owners never saw these properties on any previous Rent Comparability Grid sheets provided for Indian Hills Townhouses.

We helieve these rent compstudies prepared by Valbridge and the HUDstaff in D.C. are an extreme example of sloppy, inaccurate work. Wefeel this whole process, especially dealing with a HUD office staff extremely inaccessible in Washington DC, needs someattentionin order to preserve this housing assistance program thatis Intended to provide decentsafe and sanitary housing units to moderate and low incomefamilies. The Ownership entity of this property is a “limited dividend” entity with a very small arnount of income provided to the owners on an annualbasis. The rents that HUD is proposing for this property, based on their “rent comp grids” would reducetherents to 2 point that will not support its current mortgage. Subsequently, Ownership may have to take this property out of the HUD program,displacing those that need this decent safe andsanitary housing. It is uncertain as to whatwill happento this project as a result of usfiling this report. We would hope that HUD would continue to provide the rental assistance for the 24 families currently receiving Section 8 assistance at Indian Hills until this contract issue is resolved.

CORRESPONDENCE 6

tere, ‘i * eager f purse sag, |: "ey U.S. DEPARTMENT OF HOUSING AND URBANDEVELOPMENT WASHINGTON, DC 20410-8000 OFFICE OF HOUSING MAR Ost Susan Dorob, CP.M indian Hills Townhouses 207 Hawthome Avenue St Joseph, MI 49085 Project Name: Indian Hills Townhouses FHA Number: L_©)6)_] Property ID: 800010237 HAP Contract # MI33L000019 Dear Ms. Doroh: - This letter is a response to your appeal of our decision dated February 8, 2017 conceming the subject property. After carefully reviewing the information submitted in support of your appeal, the Office ofRecapitalization (Recap) has concluded the following: APPEAL POINTS: The owner is appealing the determination that the subject fails to qualify as a successful Lite. The appeal points specifically touch on numerous areas inchiding both the market rent determination and underwritten operating expense projections. The owner appeals the following Rent Grid Adjustments: a Line 6 Structure/Stories (building type townhouse vs. walk-up) b. Line 8 Condition/Steet Appeal c. Line 9 Neighborhood a. Line 13 Unit Interior Square Footage €. Line 25 Extra Storage £ Line 33 Heat g. Line 35 Cooking Lh Line 36 Hot Water

RENT DETERMINATIONS: The current HAP rents and various market rent opinions ate presented in the chart below. Note that the owner’s appeal is based on information contained in the independent third party appraisal. The Recap approved market rent determination already considered some of the points in the owner’s appeal aud conchided market rents that are higher than the appraiser. #HAP Current Owner PAE Owner 1 BR Type Units HAP RCS Appraisal PAE Recap | Appeal Effective 4/1/2014 Tal-14 Nov-16 Dec-16 Jan-17 Feb-17 1 BR Flat 7 $682 $665 $495 $525 $535: $671 2BRTH tt $789 $795 $600 $640 $645 $773 3BRTH 6 $889 $870 $715 $785 $790 $897 Total 24 . Per Month $18,787 $18,620 $14,355 $15,425 $15,580 $18,582 Annual GPR. $225,444 $223,440 $172,260 $185,100 $186,960 $222,984 % OF Current 99,11% 76 41% 82.10% 82.93% 98.91% ANALYSIS: a. Structure/Stories: The owner contends‘thatthe value oftownhouse constructioncompared ta walk-upis worth $60. Response: Recap agrees that in this market there is additional value to a townhouse construction compared to a walk-up apartment. A $60 adjustment is too muchfor this property in this market. The 3 One-. Bedroom comparables in the subject’s town ofDowagiac have effective street rents of $425 to $450. The 3 Two-Bedroom rentals in Dowagiac have effective street rents ranging from $450 to $525. The suggestion of a $60 added value simply for building type in this market is not supported and has not been seen in similar markets throughout the M2M portfolio. The One-Bedroom type unit at the subjectis notstrictly a townhouse type construction though it is similar in that there are two entrances and no apartment above or below. Recap initially approved market rents that were adjusted at $15 for the One- Bedroom unit type and $25 for the Two and Three-Bedroom units. These

amounts are in line with adjustments made at similar properties made in similar markets. Recap believes these adjustments are appropriate and should not be revised. b. Condition/Street Appeal: The owner believes that the subject should be considered “above average”rather than average and disagreed with someofthe other condition/appeal ratings made by the independent third party appraiser. Also, the patio/balcony feature and laundry hook-ups for indian Hills Apartments are disputed. Respouse: Indian Hills Apartments is owned and managed by the same principals as the subject. The information on the patio/balcony and laundry hook-upsis accepted and adjustments are made on the appeal rent grids for this comparable in the amounts of +$5 and $15,respectively. The PAE/Recap methodology for the Condition/Street appeal rating is to determine how the competition stacks up compared to the subject. Does the comparable show superior or inferior or about the same appeal? If superior or inferior, there may be extremes that warrant more adjustmentthan usual; however, if the chosen compsare reasonably good ones, the extremes should be tare. In this case, Recap applied a 5% ofeffective rent adjustmentto the comparable as there were no extreme inferior or superior comps. The PAE/Recap opinions agree with the appeal that Comp #2 Hamilton Squareis inferior to the subject. The PAE/Recap rated Comp #3 Berrien Woods and #4 West Wood as both Superior to the subject, but the appeal believesall three are equally above average. A differenceof opinion between the PAE/Recap andthe appeal exists for Comp #1 Indian Hilis Apartments and #5 Parkside where the PAE/Recaprated these two as similar to the subject with adjustment necessary, but the appeal feels Comp #1 is slightly inferior and #5 is more inferior. The photos and comments submitted with the appeal were reviewed. The Capital Needs Assessment and appraisal photos were also reviewed. The Condition andstreet appeal evaluation is probably the most subjective category in the rent comparability grid. The appeal states that the appraiser did not mspect all of the comparables and used on-line marketing photos in their evaluation. Recap relies heavily on the opinion of the PAE who makessite visits to all comparables and often, as is the case here, has a difference of opinion from the appraiser. After takingall the available information noted above into consideration. the initial Recap determinations all appear appropriate with one exception. The submitted photographic evidence of Comp #5 Parkside Terrace indicates that the condition and street appeal are most definitely inferior to the

subject. The appeal rent grid shows an adjustment of 5% of this comp’s effective rent in the Condition/Sireet Appeal line. c. Neighborhood: The owner submits that the no adjustment is needed for neighborhood. Response: . The PAE and Recap agreed with the appraiser thar a ($5) adjustment was appropriate for comps located in Niles and ($5) for those located in Buchanan. The appraiser did not supply much back upfor the adjustmentsreferring simply to employment centers and commercial amenities. . It is difficult to argue with locals that state that Dowagiachas a thriving downtown, a state college, aregional hospital and several thriving manufacturers. . Buchanan has a slightly smaller population and Niles has twice the population, The Rent Comp Study submitted by the ownerindicated no adjustrnent needed for neighborhoodofthe Niles and Buchanan comps. . Neighborhood is a rather subjective category. An adjustment of $5 to $10 is minor. Recap recommends going with the owner for this category as they presented local knowledgein their documentation. The ($5) to ($10) adjustments are deleted in the appeal rent grids. d Unit Interior Square Footage: The owner submitted a chart of adjustments for variance m. square footagethat is similar. though not exactly the sameas the Recap rent grids. The appeal does not explain the slight differences. Response: . The method employed by the PAE is widely accepted in the industry. The method used by the appraiser is widely accepted in the industry. Both results are very similar. . Recap accepted the PAE’s calculations and eliminated any adjustmentfor less than 25 SF difference as this is likely to be imperceptibie to the renter. This is consistent with past M2M market reat determinations. . All three calculations (Appeal, Appraiser and PAE) are very similar with only a couple of dollars variance. There is no valid reason to revise the calculations in the initially approved Recap rent grids. e. Extra Storage: The owner proposes adjustments to comps that have no basementstorage by $65 for the | Bedroom unit, $40 for the 2 Bedroom unit and $45 for the 3 Bedroom unit. (The 1 BR units havethe largest SF.) ye

Response: The basements are unfinished with concrete perimeter wails, without heat, and contain the washer dryer hook-ups and mechanical equipment. Residents do use them for storage. The third party independent appraiser applied $10 to $20 adjustments for lack of an unfinished basement and $5-$10 for compsthat offered extra storage but no basement. The PAE believed that the basements held slightly greater value in the market and adjusted from $15 to $30. Recap adjusted $20 for the 1 BR, $30 for the 2 BR and $35 for the 3BR unit. The owner’s support for the higher adjustments is based on the Rent Comp Study which lookedat the prices for off-site storage in the market area. The RCS used $0.20/SFfor the value. Recap disagrees with this method, because the applicants for the subject’s apartments are in the market for housing, not storage. The unfinished space is not valuable as an additional bedroom or family room. Uponreview, the square footage of each basement space should be considered, not just the apartment bedroom count. The 1 Bedroom units have 633 SF of basement, the 2 BR units have 414 SF and the 3 BR units have 454 SF. However, there may be more demand by a larger family for storage space than a single or two person family. Keeping in mindthatthe effective street rents in Dowagiac and Buchanan were only $425 to $450 for a one bedroom apartment, it is reasonable to think that there is only a limited amountofvalue that can be placed on the unfinished basement, regardless of size. After considering these factors, Recap recommends keeping the adjustments at the level approved by Recap imitially that is, $20 for the 1 BR, $30 for the 2 BR and $35 for the 3 BR unit. f. Heat: The owner provided the Utility Allowance schedule (MSHDA — Region C) effective 1/1/2017. The appeal seems to indicate that if the comp has electric heat, the utility allowance for electric heat should be applied rather than the allowance for natural gas which is the energy source at the subject. Response: The natural gas allowance has decreased from $22, $41, and $44 for the 1, 2, and 3 Bedroom units, respectively, to $20, $38 and $41, In therentgrids. the comp is adjusted to be comparable to the subject. If the resident pays their own electric heat at the comp, but we are adjusting as if the comp was similar to the subject that includes natural gas heat as part of the rent, then the adjustment must be for the lower natural gas value, not the higher electric energy cost. Weare trying to determine the correct market rent for the subject, not a hypothetical rent for the comparable. The appraiser, PAE and Recap were consistent in maintaining the adjustmentfor natural gas for all comps. Ww

. Therent grids are revised with the current(slightly lower) allowance for natural gas. \ g. Cooking: The owner provided the Utility Allowance schedule (MSHDA — Region C) effective 1/1/2017. The appeal seems to indicate that the electric energy allowance should be used at some of the comps. Response: . The natural gas allowance for cooking has not changed. . See the explanation above under heat for why the electric allowance is not applicable. h. Hot Water: The owner provided the Utility Allowance schedule (MSHDA — Region C) | effective 1/1/2017. Response: . The natural gas allowance for hot water has decreased from $6, $10, and $13 for the 1 BR, 2BR, and 3 BR units, respectively, to $5, $9, and $12. : See the explanation above under heat for whythe electric allowanceis not | applicable. i, Other: The appeal states that Hamilton Square does not have 3 BR units and should not be used as a comp on the 3 BR rent grid. The appeal includes updated info on the 2 BR rent for West Winds. Response: . The PAE did not use Hamilton Square in the 3 BR rent grid but rather selected one of the 3 BR comparables (Village West) offered in the owner’s Rent Comp Study. . West Winds was not selected for use in the 2 BR rent grid. Village West from the owner's RCS was used instead. ' RECOMMENDED FINAL MARKET RENT DETERMINATION: After reviewingall the information in the appeal packages, verifying/analyzing the data, and taking into consideration applicable M2M program guidance, an mcrease of $10 to $15 per unit compared to the initial market rent determinationis justified. The main reasons for the increase include corrected amenity data on Indian Hills Apartments, a revision of $5 - $10 in the Neighborhood category at sorae ofthe comps, and a revised Cond:tion/Street Appeal assessment of Comp #5 Parkside from Similar to Inferior. A number of items in the appeal were already considered by Recap in the initial determination and that is why the Recap approved market rents were higher than those of the third party independent appraiser, however, the appeal was based solely on the appraiser’s rent grids.

Revised rent grids were prepared for the appeal that indicate in yellow highlights the line items that were considered in the appeal and any recommendedadjustments. Byscrolling over the little ted marks in the footnote columms, comments will appear supporting orrevising the initial Recap determination. The recommended final market rent determination is shown in the chart below: #HAP Current Owner PAE Owner Final BR Type Units HAP RCS Appraisal PAE Recap Appeal Determination Effective W/2014. Juki4| Nov-l6 Dec-16. | Jan-17 Feb-17 Feb-17 1 BR Flat 7 $682 3665 $495 $525 $535 $671 | $545 2BRTH i $789 $795 $600 $640 $645 3773 $655 3BRTH 6 $389 $870 $715 $785 $790 $897 $805 Total 24 Per Month $18,787 $18,620 $14,355 $15,425 $15,580 $18,582 $15,850 Annual GPR $225,444 $223,440 $172,260 $185,100 $186,960 | $222,984 $190,200 % of Current 99.11% 76.41% 82.10% 82.93% 98.91% 84.37% LITE DETERMINATION: After applying the proposcd final market rent determination, the subject contimuesto fail as a successful Lite. The change in Debt Service Coverage is revised from 0.49 to 0.55. Attached are a set ofrent grids that incorporate revisions discussed above. The appeal process is now complete. It is still Recap’s recommendation that a full Mark-to- Market restructure should be completed. However, if you chose to not convert to a full Recap will issue the Watchlist Contract to be effective onMay 1, 2017. Recap is in the process of requesting founding for a Section 8 Watchlist HAP Contractreflecting the above rents, which will be forwarded to you once funding is received. This contract will be effective May 01, 2015 and requires a three- year term, allowing OCAF adjustments after the Ist and 2nd year. Upon receipt ofthe HAP Contract, it should be executed and received by the HUD Project Manager within 10 business days. “You also are required to submit to theHUD Project Manager a new rent schedule reflecting the approved rents and gross rent changecertifications for tenants in the project. Gross rent change certifications do NOTrequire recertification of tenant incomeor expenses and do not affect annual recertification schedules. You may contact your HUD Project Manager for further information. If you do not execute the Section 8 HAP Contract, HUD will be unable to honor your requusitions and will have no choice but to assume that you intend to opt out of the Program. In order to begin procedures to provide Section 8 tenant-based assistance to the tenants ofthis property, you will be given a short-term renewal at market rents in order to comply with the one- year Notice requirements to tenants or to provide sufficient time to process tenant-based vouchers. 5

If your decision is to opt out, we strongly urge you to contact Latrice Lyons, your HUD Account Executive, at the Detroit HUD Office immediately. | } If you have any questions about this transaction, please contact Sula Miller. She maybe reached at 202-402-8383. Sincerely, iA oo h— i. : Vesa ihh ~.'‘Minnie Monroe-Baldwin M2MBranch Chief Office ofRecapitalization ce: Sue Pogozelski, CreditVest' Kelly Flatley, CreditVest / Lattice Lyons, Account Executive, DetroitHUD Office ~ Susie Sapilewski, Project Supervisor, Detroit HUD Office ~ , a w

207 Hawthorne Avenue St.Joseph, MI 42085. re 269-983-7330 f: 269-923-5673. aS asRES ae em March 17, 2017 Minnie Monroe-Baldwin Office of Recapitalization Department of Housing and Urban Development After reviewing and researching the response to our appealof the rents for the referenced property, we respectfully submit that we believe some of the categories need additional consideration. The response from Ms. Monroe-Baldwin to our appeal states “Note that the owner’s appeal is basedon information contained in the independentthirdparty appraisof’ (Nicollet Partners (formerly KGS Consulting). This is a correct statement by Ms. Baldwin, howeverthis is due to the fact that HUD required that this property {as well as the other seven similar properties in our portfolio) engage an independentthird party appraisal to conduct rent comp study every five years in order to renew their Section 8 contracts. The contracts were then renewed the next 4 years in betweenthe rent compstudies using the HUD provided OCAF. The properties were responsible for paying $2,300- $2,500 out of project funds for these rent comp studies. Please provide an explanation as to why these reports from a third party appraiser were required by HUD,but are not acceptable as reference with this appeal. The currentlevel of rents at Indian Hills Townhouses were established and approved by HUD, via HUD required RCS engaged by the Owner, with HUD approved OCAFfactors applied. (See RCS HISTORY attachment} Comparable: The Rent Comparable Grids for the one and two bedroom units included with HUD’s response from Minnie Monroe-Baldwin to our appealincluded HificrestApartments (Comp #7) which wasnot included as a comparablein the Appraisal Report or Rent Comparabie Grids prepared by Valbridge Property Advisors. The Valbridge Appraisal Report actually states on Page 36 “Please note, we are aware of HilfcrestApartments located in Dowagiac. Containing one and two-bedraom apartment units, we attempted to survey this complex. Unfortunately, management was unwilling to divulge ony information. As such, it is not used in the analysis below.” Additionally, Village West {Comp #8} on the Rent Comp Grids for the three bedroom units prepared for HUD‘s responseto ourinitial appeal, was not included in the Valbridge Property Advisors report as well. 6

Consideririg this statement in the Valbridge Appraisal Report, we are concerned as to where the information came fromm Hillcrest and and ifthe HUD appraiseractually visited these properties to obtain factual information for Hillcrest Apartments or Village West. Also, on these Rent Comparable Grid for Hillcrest and Village West, there is a column that says “Owner Adjustment”. These properties were not on the criginal Rent Grid that we received from Valbridge, therefore the Owner had no opportunity to review or suggest adjustments in the initial appeal, so it is unclear as to the facts involving these comparables.It is concerning that the Owners were not provided any information on additional compsused in the HUD RCS that were not included in the Credit Vest RCS. (See COMPARABLE — HUD RENT COMP GRID} Structure: Recapstates that a $15 for one bedroom and a $25for two and three bedroom adjustmentfor the Townhouse style is appropriate in this market. Why would the style ofthe buildings in a property be based on room size? Considering thatin all previous rent comps required for contract renewal for the townhousestyle properties in our portfolio accepted no less than $30 - $60, the minimum ofthis adjustmentover the last several! year at $30.00 should be acceptedforthis report. Condition: The REAC reports included with this submission are clear evidence that the condition of this property warrants being considered for additional adjustments by increasing the adjustments made on the properties rated as inferior, or adjusting Indian Hills Townhousesto equalthe rating given to the Berrien Woods and West Woodsproperty. Although these two properties may not be the same age as the subject, they are in equal or better condition as this REAC report indicates. The most recent REAC conducted in 2016 has no deductionsfar the exterior ofthe building and only 5.98 point deductions due to a few cracks in the asphalt parking lot. Parking lots are typically scheduled every couple ofyears for crackfilling, sealing and striping. The Appeal response states that the ‘photos from the Capital Needs Assessmentwere also reviewed’. The photos and informationin this CNA, perfarmed by EMG on September 27, 2016, confirm the extremely goad condition of this property. The only items nated was $1,040 for sidewalk work and $3,250 for asphaltcrackfill/patch. {See REAC INSPECTION INFORMATION) Storage/Basement The $20, $30, and $35 adjustmentfor the additional space providedin the basements does not adequately representthe value of this extra space. In addition te having the laundry hookups for washers and driers and a laundry tub, we have had residents use this area for a child’s play area and a family area. Residents have put downfloor coverings, furnished a section with chairs/couches and used the area as an area to watchtelevision or as a hobby/sewing area. G

Tne appeal response state that there is no heat in this area. This is incorrect, there are heat vents in this area to provide heat makingthis area useable and functional. The response to the appeal makes the assumption that “applicants for the subject’s apartments are in the marketfer housing, not storage.” The numberof applicants that currently live in the comparable Indian Hills Anartments that are on the waitinglist for a Townhouse units, indicates that the basement adds value to this property. Due to the fact that the supply of townhouserental}units is very low, the demand, and thus the rental value is higher. Additionally, we don’t contend thatit can be assumed that the value ofthe space of this areais dependent on being a one bedraom, two bedroom orthree bedroom unit, on the family size. We have many elderly persons in one bedrooms thatutilize this space fer storage and collections and hobby area. Utilities: it is correct that the Owner used the utility allowance based on the typeofutility that the residents are responsible for paying at the comparable properties. It is correct that the Owner doesbelieve that the adjustments fortheutility is dependent on whatthe residents at the comparable units are paying. To be able to property compare the value of the comparable properties, the cost ofthe typeofutility that residents are responsible for paying, just as the current rent that they are paying, must be considered to be able to compare what the resident's total cost forliving in a unit is against the cost of living in the subject property. Example:Ifin the comparable properties that currently do notpayfor the utilities decided to include the utility costs in their rentalrates, (such as indian Hills Townhouses) the monthly rental rates at these properties would haveta increase based on the typeofutility provided at that property—electric or gas. Upon review ofthe adjustments used in our appeal Rent Grid Sheet, we do agree that the Heat, Cooking and Hot Water adjustments need to be changed to reflect the costs forutilities using the utility allowancefigures for apartments vs a townhouseunit since all the comparable are apartment buildings. This correction is included on the Rent Grids in the package. Patio/Balcony Thesliding glass doarsin the kitchen/dining room area lead to the patios at the subject property that are enclosed with a privacy fence, providing convenient additionalprivate space forsitting outside or dining. We believe that at least a $20 adjustmentis very reasonable. Please see the enclosed Revised Proposed Rent Comparability Grids which have adjustments per above comments. Financial: These Rent Comp Studies are based on rental information and rental rates on conventional properties without any consideration of the additional administrative and operating expenses experienced at HUD/Section 8 properties, such as: 1

Rent Comp Study every S years @ $2,300 - $2,500 AnnualFinancial Audit Report $6,240 per year Capital Needs Assessment $3,450 Specialized Section 8/HUDtraining, seminars and software Additional office supplies for software, resident processing and reporting. The rents determined by HUD through the Credit Vest Rent Compstudyare at the same level as the RCS prepared byNicollet Partners, and accepted by HUD, for contract renewalin 2004 for indian Hills Tewhouses. ® The Valbridge report contains a comment onthe fact that rents at properties with Section 8 units will have higher rents than conventional properties. So why are these additional costs net considered when comparing to market rate properties who do not have these expenses. © We understand that Vaibridge made some adjustments/carrections to the original RCS that they prepared, but we have nat recaived a copy of the Rent Comparability Grid. Additional comments/questions: Why has HUD required the properties to engage a Rent Comp Study every five years, at a cost exceeding $2,300, to renew their contracts, with OCAF factors applying for the following four years....then HUD engages Credit Vest/Valbridge, or some other contractor to prepare a different rent comp study....typically significantly lower that the reports that HUD had previously accepted? Please see the Rent Carmparability Grid that we have preparedwith the adjustments/corrections pursuantto this letter. These rents still do not calculate to the current level, however, they will be sufficient to operate this property. Please do not hesitateto contact us with any questions regarding indian Hills Townhouses. Respectfully submitted. INDIAN HILLS FOUSES. ert Poziwilko, General Partner Enclosure/Attachments Ce: Sula Miller, RECAP Sue Pogozelski, Credit Vest Kelty Flatiey, Credit Vest Latrice Lyons, Account Executive, DHUD, Detroit Susie Sapilewski, Project Supervisor, BHUD, Detroit we

LETTER FROM HUD —DC The response from Minnie Monroe-Baldwin to our initial Appealletter contained numerouserrors. We submitted additional information regarding these errors. HUD-DC refused to review this information.

LETTER FROM HUD—DC The response from Minnie Monroe-Baldwin to ourinitial Appealletter contained numerouserrors. We submitted additional information regarding these errors. HUD-DC refused to review this information. Q9

4a PR U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPME? WASHINGTON, DC 20410-8000 ‘OFFICEOF HOUSING APR OO4 2077 Robert Poziwilko, General Partner Indian Hills Townhouses 207 Hawthome Avenue St Joseph, Mi 49085 Project Name: Indian Hills Townhouses FHA Number: Property ID: 800010237 HAP Contract # MI33L000019 Dear Mr Poziwilko: This letter is a response to your letter dated March 17, 2017 concerning the subject property. In the caseofassets that enter Mark-to-Market (M2M) for a determination of market rent without debt restructuring,there is only one opportunity for an appeal. This is in accordance with the M2M Program Operating Procedures Guide, Chapter 10, Section 8 Contract renewal with a Reduction of Section 8 Rents without Debt Restructuring (“Lites”). Per the above guidance one appeal has been submitted and a response was provided dated March 2, 2017, therefore no more appeals will be processed by Recap. The appeal process is now complete. Wewish youthe best with your future endeavors. Aincerely, q PhraTbh Me Monroe-Baldwin M2M Branch Chief Office ofRecapitalization ec: Sue Pogozelski, CreditVest Kelly Flatley, CreditVest Latrice Lyons, Account Executive, Detroit HUD Office Susie Sapilewski, Project Supervisor, Detroit HUD Office www.hudgov espancLhud.gov 2

RENT COMP STUDIES 22

HUD engages Valbridge Appraisers to prepare rent comparison study. The rents determined by Valbrige Appraisers prove to be insufficient to support mortgage. HUD then engages Valbridge Appraisers to work with Ownersto go through a Full Debt Restructuring, for which Valbridge is engaged to administer. Ownership of property forced to incursignificant costs and fees throughthe processing of a new mortgage, when it would not be necessary if the rent comp studies were correct

INDIAN HILLS TOWNHOUSES Nicoflet Valbridge HUD Current iT Partners* be APPEAL (from 2014) 1 Bedroom $ 665.00 $ 495.00 $ 545.00 $ 682.00 $ 641.00 2 Bedroom $ 795.00 $ 600.00 $ 655.00 $ 789.00 $ 764.00 3 Bedroom § 870.00 $ 715.00 $ 805.00 S$ 839.00 $ 878.00 *Every S years HUD requires the apartments to engage a Rent CompStudyfirm to prepare a Rent CompStudy to establish the rents for the Section 8 units. Ownership pays approximately $2,500 for these reports, The prepareraf these repartsis a Certified General Appraiser

RENT COMPARABILITY STUDY Indian Hills Townhomes and Apartments 400 Cleveland Street Dowagiac, MI PREPARED FOR: Ms. Deborah Rock Superior Property Management DATE OF REPORT: July 31%, 2014

NICOLLETPARTNERS 1221 Nicollet Mall Suite 700_"__ Minneapolis,MN_55403" (612) 340-1236 - FAX (612}340-1848 July 31%, 2014 Ms. Deborah Rock Superior Property Management 207 Hawthome St. Joseph, MI 49085 RE: Rent Comparability Study (RCS) for the 40-unit Indian Hills Townhomes (FHA#047-11040 and MI33L000019) located at 400 Cleveland Street, Dowagiac, Michigan Dear Ms. Rock: The RCSfor the above referenced property has been completed with the supporting data, analyses, and conclusions presented in the attached report. The purpose ofthis study wasto estimate the market rents for units that will be assisted under the renewed Section 8 contract. Market rent is the rent that a - knowledgeable tenant would most probably pay for the Section 8 units as of the date ofthis report,if the tenants were not receiving rental subsidies and rents were not restricted by HUD or other government agencies. The following tablelists the market rents ] concluded for each Section 8 unit type. Number UnitSize] Appraiser’s Estimated Market Rent Prepared Grid Type ofUnit ofUnits SqFt, NetMarketRent Per Square Foot} _(YorN) One-bedroom -TH 7 698 $665 $0.95 Y ‘Two-bedroom/l bath - TH 1 919 $795 $0 87 Y Three-hedroom -TH 6 1027 3870 $0.85 XY ‘One-bedroom - ept 8 650 $425 30.65 Y Two-bedroom/! hath - apt u 800 $490 $0.61 y * Thereare an additional 16 TH(1, 13 and 2, respectively) and 21 apartments(1 and 20, respectively) that are non-Section 8 The RCS was prepared in accordance with the Uniform Standards of Professional Appraisal Practice (USPAP) and the supplemental standards of HUD Section 8 Renewal Policy and the supplemental standards ofHUD Notice H 00-12. Market rents were defined and estimated in accordance with Section 9-7 through 9-13 and the report was prepared in accordance with Section 9-14 through 9-16 of the HUD Section 8 Renewal Policy. J understand that HUD/the Section 8 Contract Administrator (CA) and the project owner will use my estimate of market rents to determine: 1) the owner’s options for renewing the project’s Section 8 contracts; and 2) the maximum rents allowed under any renewal contract. Please contact our firm if you have any questions or comments after reading this report. It has been a pleasure being of service on this assignment. Cordially, Nicollet Parmers 1a 7\ ingen Douglas J. Wageman, MAT MN Certified General Appraisal LicenseCee MICertified General Appraisal License (b)(6} Real Estate Advisors oe

Rent Comparability Grid Subject Indiar Hills “00 Cleveland Street Dos ME Fast Rent/ Restricted? HDate Last Leased (u/} Concessions for Usit Ty [eMective Rout& Reut/ ft D Condition [Serncture f Stories iyr, BuilYr Renovated [Condition Street A} IN Market? Mies ca Bedrooms ‘Backs Unit Interior Fe yf Fano. AC: Ceneral/ Wat Mireromave/ Dishwasher ‘SateliiteTarernet Feareres, fot Water 7: ‘Adjustments Bt UnityAdjustments Neti Gross. BwE ‘Rent(9-43) Rentllast rea" ated Marhet Rent i Soak “Appraiser’s Signature Unit Type > Comp BE Comp #2 HiPeres ‘village Wes! 300.11Sireet "36 Coloay Court Dowagra, Wi ‘Riles. Mi Re 3a $425 $550 NX Jul 14 dois None None 100% 98% so fu Parts B thr£, adjust ont for di S Adj Dae SAd $60 S60 520 1966-68 310 Ge G VAS 7, NEI. Elec, Yves 6 ¥ yy. 153% % << Estimated Market Rent/ Ft ‘Oue-bedroom TE Atachaient #22 OMB Approval 2502-05 Subject's FHA te: {exp 11/30/2014) Camp #3 Were Opts 2700 Lake Shove Dr Comp =f Takeerest Ravine 2850 Cleveland Ave. Se Tosepa, Mt Data $662 S610 N Tuts Tehlé __ Nowe Nose 99% 10086 ‘$662 18 i Comp 28 Fountan View “HID Red ArrowDr ‘Stevensuile, Vil ‘ences the subject's market values. Date SAdi S60 1977/2000 say S255 5524 107% 100%. Attached are explanationsof] 2. why & howeach adjustment was made 1b, hows market rent was derived from adjusted rents ©, howthis analysis was used fora similar unit type gd Mangally Using HUD's Excel form, HUD 9273.58 x

Rent Comparability Grid Subj Inara Hills Location, Condinan, 7Storses lve. Built/¥r. Renovated iSteest A ‘Marker? Mites 10: [¥ Bedroams iW Barks. Unit interior Fe Balcony? Pano IAC: Centrai/ Wall Mrerowaver Dishwasher fasheriD: Floor do ‘Meeting Rooms ‘Recreation Areas Gorenype) oe Water(mrepe) ‘Water? Sewer jasunentsB fo. we Re New Gross, Bie Rent(0-43) ReniLast ne ‘Market Rent ‘Appraiser’s Signature Antachovent#2 OMB Approval # 2502-0507 (exp 11/50/2014) — Geer| Comp BT Comp #2 Dara Hillcrest ‘West om 300 Hill Street 736 Colom Cont Subject Dowaganc, MI Niles ML ta SA 5450 N S850 3750 N Juki4 Buhls Jul14 ‘None, Nowe, ‘None, 100% 982% 99%, 30.60 $0.85 Ju Parts 8 Guru L, adjust onlyfor differences the subject's market values Daca 5 Dor 3 Date TH? 350, THA 1974/2000~, 1965) 320 1566.68 sto 1970'/2000+ GIG a IG GIG c g g G Unit Type Subject's FHA #: Comp #3 Westview Apts. Lakecrest Ravine, 2700 Lake Shore Dr 72850 Clevelané AVE ‘Si_Joserty, ML St MI Conip #4 ‘SG Dare Adi 2 15 1st 1000 556 P c RE D WD cw N C(tenmn’ Nove THs DE 414 sfbsmae. TH entry z ° 350) 151551] 35 S29, SH $363 S228) $689. 3874, $848, 153%, 703% 106%. 79% S087 «————_Estunated Varker Remy Ft ‘Attached are explanations af] *- why & how each adjustment was made Gridwas prepared? =] Manually Usiug HUD's Exod form Comp #7 Pawaring Apts 1 Fon Sueet Wiles, MI Data, 3m S750 N None lo SHEE [>|Sfale Blol=i|cfe 3 | eb fe @ {S103} g S214 ig& , how market rentwas derived [rom adjusted rents : 6. how this nalysis wes used for a similar unit type HUD 92273 - $8

Rent Comparabs Sul Tdven Fite 700ClevelandSteet Dowagiae Ml Rens ‘Last Reat / Restricted? Last Leased (oir) Rent Concessions for Unie Te Rent & Reni’ Location, Condimoa Structare / Stories Vr. Bol/¥r, Renovated KCoaditien Street [Sance Marker” Mies 0: Bedrooms Baths [Lait Interior Fe Patio ‘Central? Wall ticrawave/ Dishwasher [Clabhouse/ M ‘Rooms oal/ Recreation Areas. ucmess Cer Nbid Netwie Bwo AdjestmentsFtoD italy Adjustments Net! Gross Adjats B to FE Adjasted Rent (5+45) Ren/Last reat jraated Market Rent — as, wee. > 4 ‘ Appraiser’s Signature Date Unit Type Comp at Data Hillcrest Aparononis ff ___ Village West co 300 pull trae” 136 Coleny Court ‘Subject MM ME Dara SAG $535, N Suki ‘Nout. 100%. Comp #2 059 dn Paris B thru E, adjust onlv for differences the SAG Date SAdi He 1974/2000 $20 S10) Gi ¢ 455 sfbsmt. TH 13107 _ {SH} (Si) $270 > B25, S895) 1a3¥e, 39% S085 <—————_ sumated Market Rent Ft — | Three-bedroom -TH j Anachnens#2 OMB Approval = 2502-0507 (exp. 11/30/2014) Subject's FA 8: Comp 33 Comp a Comp #7 Weenes ApS Lakecren Ravine Pawarung Ape 2709 Lake Shore Dé 2830 Cleveland Ave 1 Fort Sueet S Mr & MI res, AH Daw Sagi Dats Sag SH $895 N ¥ N Subi4 Jul-14 ‘None. ‘None, 99% 94% S077, ject's market values. Sai Dara, THO 19772000= GG. Slo ae 19) -[ofetale _ 5150 S105. (5206) ey ‘$447 B02) $924 3949 105% Attached are explanationsof| 2. why & bow each adjustment wes made © how market rent was derived from adjusted rents ¢ how this analysis was used for a sunilar ann type Grid was prepared: =] btanvai Using HUD's Exeel form HUD 9273-58

4aprser Cerujication Prgjert Name: “ndien EL's Townhomes and Apartments Project No.: signature below, I certify that, to the bestofmy knowledge andbelief: Terens 0 fact contained smthis report are true and correct. mane cuehy Ses. opmuens, and conclusions are limited only by the reported assumptions and [imitmng conditions, personal. unpartal, and unbiased professional analyses, opinions, and conclusions. ni OF prospective financial imterest m the above property, its ownership or management agent entity, or those enties. | am not an employee ofthose principals or entities and I have no business or close amas}y interest with those parties that commonly would be perceived to create bias or a conflict ofmrerest. ~ <= no biag with respect to tbe property that is the subjectof this report or to the ownership or managementparties J. oled withthis assignment. gement m and compensation for tus assignment were and are not contingent upon the reporting of a nea rent or direction 1m rent. My fee is my only compensationfor this rent study assignment. There are no et side agreements or considerations. =, \fy analvses, opumons. and conclusions were developed, and this report has been prepared, im conformity with the Laiform Standards of Professional Appraisal Practice and all applicable HUD procedures for performmg Rent Comparability Studies for Section 8 contracts, ~. Douglas J Wavemap, MAI inspected the intenor and extenar of the subject property. Jas J. Wageman, MAI inspeoted the extensors ofthe properties used as comparables in this report. 3. No one provided significant professional assistance to the person signing this report except the persons listed here: If anyone is listed here, his/her contnbution 1s identified m the Scope of Work section ofthis report, > fam a certified general appraiser, licensed and in good standing with the state apprasser regulatory agency where the supject property is located and I meet all of the appraiser qualifications required in HUD"s rent comparability procedures, 2 |. Lam not debarred or suspended from domg business with the Federd Govemment. { also am not under a Limited Denial of Participation (LDP) imposed by the HUD Mutnfamaly HUB or Program Center having jurisdiction over the Secon 8 project. Any LDPs in effect now or m the past three ycars were imposed by the following HUD offices; “3. The reported analyses, opinions, and conclusions were developed, and this report has been prepafed, n conformuty with the requirements of the Code ofProfessional Bttncs & Standards of Professional Appraisal Practice of the Appratsal lustitute. which include és Uniform Standards of Professional Appraisal Practice. iv . The use of this report is subject to the requirements of the Appraisal Institute relating to review by ts duly authonzed yepresentatives. 13. As o°the date ofthis report, (Douglas J. Wageman. MAI) have completed the continuing education program ofthe Appraisal Institute. Warning: If you knowingly make a false statement on this form, you may be subject to civil penalties under Section 1001 of Title 18 of the United States Code. In addition, any person who knowingly and materially violates any required disclosure of information, including intentional non-disclosure, is subject to civil money penglty not to exceed $10,000 for each vielation. Appraiser’s Name: Douglas J. Wageman, WAI Signature:, we Date: 7/31/2014 PermanentLicense No: (b)(6) issuing State: Minnesota Expires: 8/31/2014 Permanent License Noy Issuing State:, Michigan Expires: 7/31/2014 Dic you prepare the RCS under a temporary license? No - Ifso, attach a copy afthe temporary license

APPRAISERS’ LICENSES DOUGLASOHN WAGEMAN §A00 CIRC! OWN GOLDENVALLEY, MN 55416 Depariment of Commerce The Undersigned COMMISSIONER OF COMMERCEforthe State of Mmnesota hereby certifies that DOUGLAS JOHN WAGEMAN 5400 CIRCLE DOWN GOLDEN VALLEY, MN 55416 has compiled with the laws of the State of Minnesota and is herebylicensed fo ransact the business of Resident Appraiser: Certified General Licensa Number: 4003297 unless this authority ws suspended, revoked, or otherwise legally terminated. This license shall be in effect untilAugust 31, 2074 IN TESTIMONY WHEREOF, I have hereunto set my hand this August 02, 2012. CONMISSIONER OF COMMERCE Continuing Education: Minnesota Department of Commerce R Licensing Division 25 7th Place East, Suite 500 Total -Apprarser 30.00 St. Paul, MN 55101-3785 USPAP 7.00 Telephone (681) 288-6319 Ematt: ficersing.commearce@state mus Website. commerce.siate.mn.us Notes: . ‘Continuing Edueabon: 15 nours © requred in the first renewal periad, which moludes 2 7 hour USPAP course. 30 hours: ‘8 required foreach sxboequens Terigeralpasion,whech melvGes 27 howUSPAP course . Appraisers: You must hold a licensed Resxiental, Cerlified Residential ofCertifed Genecal qualification in onder to perform appraisals for federally related wangactons. Teagiees do not qualify. Forfurtherdetaiis, please visk our website ‘al commerceStaleP7.us MinnesotaAppraisal License— Douglas J.Wageman, MAI