1. HUD Multifamily Housing Compliance What Every Tax Credit Investor, Loan Server, and Borrower Needs to Know May 10-11, 2007

2. WHAT KINDS OF PROGRAMS ARE WE DISCUSSING? – Grants To Local Government – HOME, CDBG – Multifamily Mortgage Insurance – Section 8 – Project-based, AAFs, FMRs, OCAFs, Budget Based, 50 Percent Incomes – Vouchers – HOPE VI – Public Housing

3. Introductory Regulatory Issues In Non- Procurement Government Contracts. You Are In The Real Estate Business, But So Much More! – You Have Extra Civil, Criminal Law Requirements False Statements Act False Claims Act 666 – Watch out for Faustian bargains!

4. Administrative Issues – Flags – LDP – Suspension And Debarment -- EPLS

5. * Regulatory Requirements – Audits, Inspections, Reviews – Tax Credits -- 8823s Follow HUD Handbook 4350.3 Plus New 8823 Guide

6. 2530 – Previous Participation Review – 24 CFR Part 200 Subpart H – Plus Memos, Unpublished Lore

7. – Key Concepts – MPRC Process Principles Properties Officers GPs LPs LLCs Baseline

8. – Paper v. Electronic – APPs History Of Delay, Problems – Substantive Changes Along With APPs – Federal Register Change – Pending Bill, Recent Memos – January Memo, March Memo On Investors, H.R. 1675

9. * Starting Point For Using APPS: – Quick Tips, Glossary – Absolution, HUD Absolves You Of Your Sins – Sets the tone – REMS And Interpreting With Flags – Leads To Field Office Confession

10. KEY BUSINESS AGREEMENTS – Regulatory Agreement – Key Documents In FHA Loans. – Read It All But Focus on: Limits – Para 2 – deposits Para 4 – rent schedule Para 6-Transfers (TPA), distribution (surplus cash, inspection) Para 7-Maintenance, Inspection Para 9-Management Contract, MOR, Audits Para 10-Fair Housing, but that applies in law by own force too

11. HAPs – Housing Assistance Payments – Many Of The Same Requirements As Regulatory Agreement – HAP Forms Can Differ Substantially In Different Section 8 Programs. Always Check The HAP: Part II in example paras. 2.4 to 2.6, 2.10, 2.17, 2.20 Renewals – MAHRA, Section 8 Renewal Guide

12. USE AGREEMENTS – Vary Widely – Seen Only In Some Programs, Such As Flexible Subsidy Program Property Dispositions Non-Profit Prepayments

13. * Audits – This Is A Regulatory Agreement And Increasingly, HAP Requirement (usually) – 4370.2 – Hot topic – Repayment of Advances – Project v. Owner – 4381.5 – Common concept creating conflict

14. * YOUR FHA LOAN IS NONRECOURSE – SORT OF – REACs – MOR – Integrity Of Site Records – Managers – Good Samaritan Can Hurt – Use Agreements

15. CASE STUDIES – How Enforcement Center Works – Harvey Case – Project v. Owner Expenses – Penalties May Not Be Worth The Principle! – David Case – Pays To Avoid Controversial Programs and Acts (coinsurance and default), Or Be Prepared Ahead Of Time – Livecchi Case – Owner Advances And Repayments – Respect Surplus Cash, Get Approvals and Keep Receipts!