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HomeMy WebLinkAboutResolutions - 1987.05.28 - 18008A MISCELLANEOUS RESOLUTION NO. 87134 DATE May 28, 1987 BY: PUBLIC SERVICES COMMITTEE - RICHARD D. KUHN, JR., CHAIRPERSON IN RE: COMMUNITY DEVELOPMENT DIVISION - RENEWAL OF THE REHABILITATION FUND LEVERAGING AGREEMENT WITH MANUFACTURERS NATIONAL BANK FOR THE COMMERCIAL ASSISTANCE PROGRAM (CAP) TO THE OAKLAND COUNTY BOARD OF COMMISSIONERS Mr. Chairperson, Ladies and Gentlemen: WHEREAS, Oakland County has been a recipient of Community Development Block Grant funds from the U. S. Department of Housing and Urban Development since 1974 and has operated a residential rehabilitation program since 1976; and WHEREAS, the U. S. Department of Housing and Urban Development has established procedures allowing Community Development Block Grant recipients to draw (in one lump sum) the funds designated for property rehabilitation in their approved CDBG application in order to establish a Rehabilitation Leveraging Fund with a private financial institution; and WHEREAS, the County of Oakland by Miscellaneous Resolution #82283 of September 21, 1982 adopted the basic concept of utilizing Community Development Block Grant funds to leverage private financial resources for the rehabilitation of residential and commercial property; and WHEREAS, the County of Oakland by Miscellaneous Resolution #83034 of February 24, 1983 approved the creation of a commercial rehabilitation financing program with Community Development Block Grant funds and authorized the Community Development Division to solicit lenders for a financial leveraging agreement; and WHEREAS, the County of Oakland by Miscellaneous Resolution #84239 of August 30, 1984 approved the Rehabilitation Leveraging Agreement with Manufacturers National Bank of Detroit for a program of financing commercial property rehabilitation through the Oakland County Commercial Assistance Program (CAP); and WHEREAS, the Community Development Division recommends extension of the Commercial Assistance Program and the attached Rehabilitation Leveraging Agreement with Manufacturers National Bank of America; and WHEREAS, the Community Development Citizens Advisory Council has approved by a roll call vote of 13 to 1 (abstention) the attached Rehabilitation Leveraging Agreement. NOW THEREFORE BE IT RESOLVED that the Oakland County Board of Commissioners approves renewal of the attached Rehabilitation Fund Leveraging Agreement and authorizes the Oakland County Executive to execute the Agreement with Manufacturers National Bank. Mr. Chairperson, on behalf of the Public Services Committee, I move the adoption of the foregoing resolution. PUBLIC SERVICES COMMITTEE Chairperson OAKLAND COUNTY COMMUNITY DEVELOPMENT Rehabilitation Fund Agreement Preamble WHEREAS, the United States Department of Housing and Urban Development has enacted rules and regulations regarding the use of funds under a Community Development Block Grant program, and WHEREAS, the County of Oakland is a recipient of funds under such a program, and WHEREAS, the United States Department of Housing and Urban Development has through its rules and regulations established a procedure whereby a Community Development Block Grant recipient may draw in one sum funds designated tn its Community Development application for the establishment of a rehabilitatibn fund in a private financial institution, and WHEREAS, the County of Oakland is desirous of establishing such a fund, and WHEREAS, the County of Oakland has established a Community Development Commercial Assistance Program (herein referred to as "CAP") to provide rehabilitation financing for commercial structures, and WHEREAS, 24 CFR 570 as amended requires that a written agreement be entered into between the Community Development Block Grant recipient and the financial institution wherein the fund is to be established. NOW, THEREFORE, this Agreement is made as of this day of , 1987 by and between the County of Oakland, a Michigan Constitutional Corporation, acting by and through—its Community Development Division (herein referred to as the "County"), and Manufacturers National Bank of Detroit, a National Bank Association of Detroit, Michigan (herein referred to as the "Bank") for a period of two (2) years. In consideration of the premises and undertakings herein set forth, the parties do hereby agree as follows: Purpose The purpose of this Agreement between the County and the Bank is to permit the County to draw funds from its Community Development Block Grant Letter of Credit in a single lump sum to establish a Rehabilitation Fund with the Bank for the purpose of financing the rehabilitation of privately owned commercial properties, as a part of the County's Community Development Block Grant (CDBG) Program. The Rehabilitation Fund will also serve as a depository for funds to be transferred as required to any additional rehabilitation programs operated as part of the CDBG Program. Article I Definitions 1.01 "CAP" (Commercial Assistance Program) shall mean the program wherein the County and the Bank have agreed to cooperate in loans for commercial property rehabilitation in communities designated for the program by the Oakland County Board of Commissioners. 1.02 "CAP" Loan - Financing combination of a Bank loan and a County loan which may be forgiven under terms specified by the County. 1.03 "Commitment Letter" shall mean a letter submitted by the County to the applicant and the Bank setting forth the terms and conditions of the County's cooperation in a CAP Loan. 1.04 "Bank Note" shall mean a promissory note payable to the order of the Bank evidencing a borrower's obligation to the Bank on a CAP Loan. 1.05 "County Note" shall mean a promissory note payable to the order of the County evidencing a borrower's obligation to the County on a CAP Loan. 1.06 "Note" shall mean either the "County Note" or "Bank Note" herein referred to individually, or collectively as "Notes." 1.07 "CDBG Funds" shall mean funds received by the County from the United States Department of Housing and Urban Development under its Community Development Block Grant Program. 1.08 "Rehabilitation Fund" shall mean the deposits established from the lump sum drawdown of CDBG funds budgeted for rehabilitation , 1.09 "CDBG Account" shall mean the account or accounts established by the County at the Bank for the deposit of funds to be used in the Commercial Assistance Program (CAP) or as designated by the County. Article II Establishing the Rehabilitation Fund 2.01 The County agrees to deposit with the Bank from time to time certain CDBG funds and the Bank agrees to accept these funds in an amount to be determined at the sole discretion of the County. 2.02 The funds deposited by the County pursuant to Section 2.01 of this Agreement shall be placed in one or more accounts which shall earn the highest interest rate offered by the Bank to any of its customers as determined by the size and maturity of such deposits. The principal and interest will be made available for the County's participation with the Bank in the Commercial Assistance -Program and for CDBG funded rehabilitation programs as designated by the County. 2.03 The parties hereto acknowledge that the deposit of funds by the County pursuant to Section 2.01 of this Agreement is contingent upon the receipt of CDBG funds and the County reserves the right to delay deposit until the receipt of adequate funds from the United States Department of Housing and Urban Development (HUD). 2.04 The Rehabilitation Fund will be used to finance the County's property rehabilitation programs pursuant to the County's approved Community Development Block Grant Program. Pursuant to 24 CFR 570.313 (c) 2 of the regulations governing lump-sum drawdowns, interest income on the Rehabilitation Fund may be placed into a separate CDBG account. This program income shall be disbursed to CAP Loan activities first. 2.05 Use of the deposited funds for property rehabilitation financing shall commence within forty-five (45) days of deposit. In the event that the use of deposited funds does not start within the forty-five (45) day time limit, the County may be required by HUD to return all or part of the deposited funds not previously pledged or encumbered to the CDBG Letter of Credit. If that should occur, the Bank will no longer be required to continue in participation of this program other than those loans that have been made at the time of withdrawal. Article III Terms of Program 3.01 The County agrees to cooperate in CAP Loans to qualifying property owners and businesses participating in the program to the extent that sufficient funds are available and subject to the terms and conditions of this Agreement. -2- 3.02 The Bank will provide commercial rehabilitation financing based on a term of seven (7) years. Individual requests for shorter repayment periods or for longer repayment periods of up to ten (10) years where an applicant's cash flow may not be sufficient to service a shorter term will be considered subject to the Bank's normal lending standards. 3.03 The Bank will provide commercial rehabilitation financing at the following rates and terms: a) Seven (7) year loans at a fixed interest rate of one (1) point over the lowest interest rate available on five (5) year business loans according to the Bank's monthly listing of rates as determined by the Consumer Loan Department. Shorter term, five (5) year loans would receive the lowest fixed rate available for five (5) year business loans per the Bank's monthly listing of rates as determined by the Consumer Loan Department. Loans disbursed on the five (5) year maturity with payments calculated on the ten (10) year basis would carry a fixed interest rate of two (2) points over the lowest interest rate available on five (5) year business loans according to the Bank's monthly listing of rates as determined by the Consumer Loan Department. In no event shall the Bank's interest rate charged to a CAP loan exceed the interest charged for similar loans by the Bank. The maximum interest rate charged by the Bank for the duration of this Agreement will be 161/2% where terms do not exceed seven (7) years and 171/4% for longer terms. b) Floating rate flexible term loans will be made on a seven (7) year basis at six (6) points over the Bank's monthly Consumer Loan Department index (as determined by average six (6) month Treasury Bill rates for the previous month as published by the Federal Reserve Board). The interest rate charged may change on a quarterly basis as the index changes. Payments, however, will remain at a constant dollar amount and only the allocation of principal and interest subject to change. Complete information relative to the flexible term loan will be made available at the time of application. c) If the applicant can provide a first mortgage on the commercial real estate as security for the Bank's loan, the Bank will provide long term commercial mortgage financing as dictated by Bank policy in effect at the time of application. The applicant shall specify their preference for financing in the loan application. The final determination of the rate and terms shall rest with the Bank subject to the provisions of this section. 3.04 The County shall reduce the cost of financing for approved CAP Loan recipients by subsidizing the principal amount borrowed. Using the amount of loan principal approved by the Bank, the County will calculate how large a loan could be supported by the annual principal and interest payment (on the amount of the Bank's approved loan) if the interest rate -3- on the Bank loan was 61/2 points less than their CAP approved rate. The difference between the amount of the Bank's approved loan and what the loan amount would be at the reduced interest rate becomes the amount of the principal loan subsidy to be provided by the County. The term of the County's CAP loan will be the same as the Bank's except that the County's loan term shall not exceed ten (10) years. 3.05 The principal subsidy provided by the County to a loan recipient shall be in the form of a loan which shall be forgiven (over the repayment period of the Bank's loan], according to the following formula: $ Amount of County CAP Loan # of Months of the County's Loan Term Amount of Subsidy Forgiven Monthly The balance of the County's CAP loan not forgiven shall be due and payable to the County under the following circumstances: a) if the borrower or property owner sells, transfers or divests interest in the property, or refinances an existing mortgage or land contract and derives a profit therefrom; or b) if the borrower defaults in the Bank Note and the security agreement given by the borrower to the Bank involves the real estate for which the CAP loan was obtained. 3.06 The Bank agrees that when the applicant is an existing Bank customer, the Bank's CAP loan rate shall in no event exceed the interest rate that would be charged if the County were not participating in the loan. 3.07 The maximum CAP loan that the County will subsidize is $100,000 per building. Projects requiring amounts in excess of $100,000 per building must obtain additional source funds which may include, at the Bank's discretion, an unsubsidized loan from the Bank. 3.08 The Bank agrees that this Agreement-- shall include providing the following services at no additional cost to the County: (a) Documentation and closing of loans, including necessary filings and recordings (b) Servicing County accounts (c) Collection of outstanding indebtedness on loans (d) Reporting status of County accounts (e) Foreclosure and liquidation (f) Performance of this Agreement 3.09 The County's security interest in any collateral pledged to secure a CAP loan shall be subordinate to the Bank's security interest in same. Article IV Eligibility, Application, Approval and Disbursement Process 4.01 The County will designate areas wherein properties may be located and eligible for participation in the program. 4.02 All applications for a CAP Loan shall be initially submitted to the County by the participating local government. The County shall review the loan application and any supporting documents to establish initial eligibility for participation in the program. The County will calculate the respective amounts of the proposed Bank and County CAP loans. Eligible applications will then be submitted to the Bank to be approved or denied by the Bank in accordance with its normal lending standards. In cases of denial, the Bank shall send the loan applicant a written notice indicating its decision, with a copy of the notice forwarded to the County. The Bank shall identify to the County, the conditions under which the loan could be made. -4- 4.03 The Bank shall transmit to the County its underwriting decisions for loan requests, setting forth the terms and conditions of the Bank's approval in writing. The County acknowledges that the Bank has made no representation or warranty with respect to the accuracy of any information given by a borrower or as to the credit or ability of a borrower to repay the loan. 4.04 Upon receipt of the information requested in Section 4.03 of this Article, the County shall review the loan application and any supporting documents. The maximum amount of the County's cooperation and the terms and conditions of same shall be at the sole discretion of the County. If the County decides not to cooperate in a CAP Loan, it shall send the loan applicant a written notice indicating its decision. 4.05 When the County decides to cooperate in a CAP Loan, it shall issue a loan commitment to the Borrower setting forth the terms and conditions of the County's cooperation in the CAP Loan. A copy of the loan commitment shall be forwarded to the Bank. 4.06 Upon notification from the County, the loan closing will be scheduled. The Bank and the County shall each prepare their necessary loan closing documents. 4.07 At closing, the Bank, the County and the borrower shall execute the necessary loan closing documents. The Bank shall disburse the funds for the Bank's loan at loan closing. The County's loan will be disbursed upon satisfactory completion of the rehabilitation work. The County will then authorize the Bank to debit the CDBG Account and disburse the County loan. 4.08 At closing, the borrower shall execute two promissory notes, the "Bank Note" and a "County Note" and all documents required therewith. 4.09 The Bank shall have no liability, obligation or responsibility to the County for a borrower's obligations under the Notes and/or security therefor or for the validity, enforceability, collectibility, genuineness or sufficiency or of any -document executed in connection therewith or for title to any collateral. 4.10 The Bank and the County agree that neither party shall sell, assign or transfer, or suffer any sale, assignment or transfer in whole or in part of its interest in a Note or a portion of the security therefor without the prior written consent of the other party, except an assignment arising out of a borrower's default. Article V Default 5.01 Default by a borrower as used in this Agreement shall mean: a) Default by a borrower on a Bank Note or a security instrument b) Default by a borrower in compliance with federal regulations prohibiting or restricting certain uses of the loan and/or default by a borrower in compliance with the Commercial Assistance Program 5.02 Upon the occurrence of any default under any Bank Note or security agreement given by a borrower in conjunction therewith, the Bank shall within forty-five (45) days of the date on which the Bank becomes aware of the default, notify the County in writing of the default, specifying the nature thereof. By appropriate notice the bank shall promptly demand that the default be cured by the borrower. In the event such default is net timely cured, the Bank may take appropriate action, including the institution of legal proceedings and action to foreclose under any security instrument, and to effect collection of the Bank Note -5- in full. When the Security Agreement given by the Borrower to the Bank pertains to the real estate for which the Borrower obtained the CAP Loan, the Bank will also collect the County Note. Collection of the County Note will be waived upon written authorization from the County and received by the Bank. 5.03 If the Bank initiates legal action to collect an outstanding indebtedness after the occurrence of a default as described in Section 5.01 (a) of this Agreement, all costs and expenses of collection, including attorney's fees, shall be paid by the Bank. All proceeds received by the Bank resulting from legal action and/or foreclosure of its security interest in the Collateral shall be first applied to the payment of reasonable expenses incurred by the Bank in the collection of said proceeds. Any proceeds received by the Bank in excess of such costs and expenses shall be applied first to the Bank Note and then to the County Note. 5.04 The County may exercise its option to purchase the reaaining portion of the Bank Note and move independently against the borrower, if the Bank decides not to take any action on a default under Section 5.01 of this Agreement. For this purpose, the Bank shall negotiate to the County, the Bank Note and assign all collateral associated with the Note and any security instruments in connection therewith. 5.05 The County shall be responsible for monitoring a borrower's compliance with applicable federal regulations and compliance with CAP guidelines. Upon the occurrence of a default as defined in Section 5.01 (b) of this Article, the County shall notify the Bank in writing of the default within forty-five (45) days. By appropriate notice, the County shall promptly demand that the default be cured by the borrower. In the event such a default is not timely cured, the County may exercise its option to purchase the remaining portion of the Bank Note and move independently against the borrower. For this purpose, the Bank shall negotiate to the County, the Bank Note and assign all collateral associated with the Note and any security instruments in connection therewith. 5.06 Prior to default by a borrower, the Bank shall not without the prior written consent of the County, which consent shall not be unreasonably withheld: a) Make or consent to any alteration of the terms of a Note or the collateral; b) Make or consent to any release, substitution exchange of any collateral; or c) Waive any claim against a borrower in connection with a Note. Article VI Reporting 6.01 The Bank shall furnish and deliver to the County the following reports: a) A monthly bank account statement reflecting all transactions which occurred during the month, including the credits, debits and the account balance. b) A monthly loan activity reporting new loans and reflecting the status of outstanding CAP Loans. 6.02 The County shall have the right at any reasonable time during the Bank's business hours to examine all of the Bank's books or accounts and other records pertaining to the CAP Loans, Notes and security instruments. -6- Article VII Duration of Agreement 7.01 This Agreement will apply to new loan activity for a period of two (2) years from the date of this Agreement. The responsibilities of the Bank and County with respect to loans made under this Agreement shall remain in effect until those loans have matured or until such time as the County's investment has been returned, whichever shall occur sooner. 7.02 If for any cause the parties hereto shall violate any covenant, agreement, term or condition in this contract, the other parties shall thereupon have the right to terminate this Agreement by giving written notice of such termination, specifying the effective date thereof, at least thirty (30) days before the effective date of such termination and this Agreement shall terminate in all respects as if such were the date originally given for the expiration thereof. 7.03 In the event the County is required to terminate this Agreement pursuant to a directive from the federal government or pursuant to federal rules and regulations, the County shall be permitted to so terminate by giving notice in accordance with the terms of Section 8.01 of this Agreement. 7.04 At the termination of the two (2) year Agreement, all unobligated deposits of CDBG funds in the Rehabilitation Fund will be returned at the County's responsibility to its Community Development Block Grant Letter of Credit unless the County is authorized by the Department of Housing and Urban Development to extend the Agreement for an additional period. Article VIII Compliance With Laws 8.01 The parties hereto agree to comply with all applicable laws, ordinances, and codes of the federal, state and local governments. It is understood that all loans will be made pursuant to good and sound banking practices but under no circumstances shall an applicant be discriminated against because of race, color, creed, handicap, sex or national origin. 8.02 It is hereby understood and agreed that the terms and conditions of this Agreement are subject to the provisions governing lump-sum drawdowns for property rehabilitation pursuant to 570.513 of the Department of Housing and Urban Development regulations on Community Development Block Grants, being 24 CFR, Part 570, attached as "Attachment A." Article IX Insurance 9.01 The parties hereto shall maintain at their expense during the term of this Agreement on behalf of all of their employees performing any of the activities hereunder the following insurance where applicable: a) Worker's Compensation insurance for Employees which meets Aichigan's statutory requirements and Employer's Liability insurance with minimum limits of $100,000 each accident; b) Comprehensive general liability insurance with minimum limits of $1,000,000 combined single limit, each occurrence, for bodily injury and property damage. -7- Article X Indemnification 10.01 The Bank agrees to save harmless the County against and from any and all liabilities, obligations, damages, penalties, claims, costs, charges and expenses which may be imposed upon, incurred by or asserted against the County by reason of any of the following occurring during the terms of this Agreement: a) Any negligent or tortious acts of the Bank or any of its personnel, employees, consultants or subcontractors; or b) Any failure of the Bank or any of its personnel, employees, consultants or subcontractors to perform its obligations either implied or expressed under this Agreement. Article XI Fair Employment Practices 11.01 In accordance with the United States Constitution and all Federal legislation and regulations governing fair employment practices and equal employment opportunity, and including but not limited to the Civil Rights Act of 1964 (P.L. 88-352, 78 Stat. 252) and in accordance with the Michigan Constitution and all State laws and regulations governing fair employment practices and equal employment opportunity, including but not limited to the Michigan Civil Rights Act (P.A. 1976, No. 453) and the Michigan Handicappers' Civil Rights Act (P.A. 1976, No. 220) the Bank agrees that it will not discriminate against any person, employee, consultant or applicant for employment with respect to his or her hire, tenure, terms, conditions or privileges of employment because of his or her religion, race, color, national origin, age, sex, height, weight, marital status, handicap, sex or sexual orientation that is unrelated to the individual's ability to perform the duties of a particular job or position. 11.02 The Bank further agrees to take affirmative action to achieve reasonable representation of minority groups and women on their work force. Such affirmative action shall include, but not be limited to, the following areas: employment, promotion, demotion or transfer, recruiting or recruitment, advertising, layoff or termination, rates of pay or other forms of compensation, and selection for training or education, including apprenticeships. 11.03 Breach of the terms of this Article may be regarded as a material breach of the Agreement. The Bank hereby recognizes the right of the United States, the State of Michigan and the County to seek judicial enforcement of the foregoing covenants against discrimination against themselves or their subcontractors connected directly or indirectly with the performance of this Contract. Notwithstanding anything herein to the contrary, the provisions of this Article shall not be waived without the express consent of the appropriate enforcement agency. Article XII Amendment 12.01 The parties hereto may from time to time consider it in their best interest to change, modify or extend a term, conditon or covenant of this Agreement. Any such change, addition, deletions, extension or -8- modification shall be incorporated in written amendments to this Agreement. Such amendments shall not invalidate this contract unless expressly stated therein. 12.02 No amendment to this contract shall be effective and binding upon the parties, unless it expressly makes reference to this contract, is in writing and is signed and acknowledged by duly authorized representatives of all parties hereto. Article XIII Notice 13.01 A notice, demand or other communication under this Agreement by a party to the other party hereto shall be sufficiently given or delivered if it is dispatched by registered or certified mail, postage prepaid, return receipt requested, except that the reports required by Article VI hereof may be by regular mail or may be hand delivered at the discretion of the Bank. 13.02 In the' case of a notice, demand or communication to the Bank, such shall be addressed to it at the following address: Ronald D. Hooper Second Vice President 411 W. Lafayette Detroit, Michigan 48226 In the case of a notice, demand or communication to the County, such shall be addressed to it at the following address: Kenneth R. Patterson, Manager Oakland County Community Development Division 1200 N. Telegraph Road Pontiac, Michigan 48053 All notices shall be deemed effective on the date of mailing. The addresses to which notice is to be made may be changed at any time by any party by informing the other party of such change in writing. Article XIV Assignment 14.01 No party hereto shall assign or encumber directly or indirectly any interest whatsoever in this Agreement, and shall not transfer any interest in the same without prior written approval of the other party. Article XV Remedies 15.01 Each party to this Agreement shall have the right to protect and enforce all rights available to it by suit in equity, action at law or by any other appropriate proceedings, whether for specific performance of any covenant contained in this Agreement, or damages, or other relief, or proceed to take any action authorized or permitted under applicable law or regulation. 15.02 Except as otherwise specifically set forth in this Agreement, all rights and remedies of the parties under this Agreement shall be cumulative. 15.03 The parties hereto agree to submit to the personal jurisdiction of any competent court in Oakland County, Michigan for any action brought against it arising out of this Agreement. -9-- Position: Date: Attest: Date: Position: Oakland County Executive Date: Attest: Date: Article XVI Miscellaneous 16.01 This Agreement constitutes the entire agreement between the parties and supersedes any prior or contemporaneous oral or written agreements, understandings or representatives. 16.02 This Agreement and all rights and obligations imposed hereunder shall be interpreted and construed in accordance with the laws of the State of Michigan. 16.03 If any provision of this Agreement or the application thereof to any person or circumstance shall, to any extent, be invalid or unenforceable, the remainder of this Agreement, or the application of such provision to a person or circumstances other than those as to which it is invalid or unenforceable, shall not be affected thereby, and each provision of this Agreement shall be valid and enforceable to the fullest extent permitted by law. 16.04 The captions and headings of this Agreement are inserted for convenience only, and shall not modify or affect the intent to operative paragraphs of this Agreement, and shall be disregarded in construction or interpretation thereof. 16.05 This Agreement shall bind and shall inure to the benefit of the parties hereto, their successors and assigns. 16.06 Each party to this Agreement hereby represents and warrants to the other party that it has full right, power and authority to enter into and perform this Agreement; that its execution and delivery of this Agreement have been duly authorized by all necessary action; and that this Agreement is valid, binding and enforceable upon approval by the County and the Bank. IN WITNESS THEREOF the Bank and County have executed this Agreement as of the date first written above. MANUFACTURERS NATIONAL BANK OF DETROIT COUNTY OF OAKLAND By: By: Daniel T. Murphy Misc. #87134 May 28, 1987 Moved by Richard Kuhn supported by Law the resolution be adapted. AYES: Hobart, Jensen, Richard Kuhn, Susan Kuhn, Lanni, Law, McConnell, Angus McPherson, Rue] McPherson, Moffitt, Nelson, Page, Perinaff, Pernick, Price, Rewold, Rowland, Skarritt, Wilcox, Aaron, Caddell, Calandra, Crake, Dayon, Gosling. (25) NAYS: None. (0) A sufficient majority having voted therefor, the resolution was adopted. STATE OF MICHIGAN) COUNTY OF OAKLAND) I, Lynn D. Allen, Clerk of the County of Oakland and having a seal, do hereby certify that I have compared the annexed copy of • • this Miscellaneous Resolution adopted by the Oakland County Board of Commissioners at their meeting held on May 28,1987 with the orginial record thereof now remaining in my office, and that it is a true and correct transcript therefrom, and of the . whole thereof. In Testimony Whereof, I have hereunto set my hand and affixed the. seal of said County at Pontiac, Michigan this 28th day of 4111 411111111L May 19 87 ALLEN LEN County Clerk/Register of Deeds Attachment A ;Appendix V HOD Lump-Sum Deposit Regulations Fixiarel Regis / Vol.44. No. as Friday. April I. 1979 / Rules and Regulations DEPARTMENT OP HOUSING AND URBAN DEVELOPMENT Office of the Assistant Secretary for Community and Planning Development 2.4 CFR Part 570 Community Development Block Grants (CDBG); Grant Administration Requirements tor Lump Suns Dravociown of 0080 Funds for Property Rehabilitation Financing AceNoy: Department of Housing and Urban Development tHUaj, aCmioft: Final Rulestaking. summAwr: This Emsl rule establishes the conditions under which a Community Development Block Grant recipient may draw in one sum funds designated in its Community Deveiopment application for the establishment in a private financial institution of a fond for the purpose of financing the rehabilitation of privately. owned property. EFFECTIVE CAT!! May 7, 1979. FOR FURTHER INFORMATION com-rAoTt. Leonard f. Csarniecki. Rehabilitation Policy Division. Office of Urban Rehabilitation and Conrununity Reinvestment. Department of Housing end Liroari Development. Washington, D.C. Z8410 (202) 755-8300. SUP-P1_EMENTARY INFORMATION: On August 3. 1978. (43 L.t R 34424( proposed rovIsmns to 34 CFR Part 570 were nnhtished in he Federal Register for oublic C0.71111E11{. interested parties were given unlit September 5. 1978, to subralt ,...-rttten ornaments. All oomments ret:eived with respect to the Drpo.5ed rules se,,,ernarig the grant udrmnueitrauon rEqUIren-lernz for the Uinta sum dig:we oWn Or Community Development 54;ocic Cisut (CDPGt funds for property ren• tiara non fi...qaocuig were given cue nonstocreiion. As a result of the comments received the following changes were made: Basic Requirements • The first sentence of §57151.1 has been revised as a result of comments indicating the need to provide that a block grant recipient may draw hands from the letter of credit in single lump aunt to establish a rehabilitation fund in one or mere-private financial institutions for the purpose of financing the rehabilitation of privately owned properties (inciuding residentlai, mixed use, and nonresidential oronertiest and the private acquisition of properties for rehabilitation as a part of the recipients' community Ceveioament program. Section 570.513(a) which contains key definitions used in the regulation has been amenaea in response to comments to include clarifying language for "private funds" and a definition far 'rehabilitation'. Private funds can Include funtis heist in must for the benefit of bondholders or noteholders of the CDDG recipient or its agency where such bond or note proceeds are to be used in connection with the rehabilitation financing program- The defiai don of "private Financial Institution" was amended to make clear that savings and loan associations. credit Unions and other financial institutions. in which deposits are federally insured, are eligible .depositories for the rehabilitation fund. The definition of "rehabilitation" expands the use of the fund authorized by r3 570.8131c) to include the financing of private entities (both those organized for profit and also those on a not for profit basisi to acquire private properties for rehabilitation. and the rehabilitation of commercial and industrial buildings and structures pursuant to § 575003(c)(1). This change is in accord witn the activities eligible for financing under Section 15)a l(4 ( of the Housing and Community Development Act of 1974 as amended. at implemented by f 570.2.52IM51; of the regulations. Section 579.513(14) has been revised to make clear that the two year limit on the written agreement only limits the period during which new loans may be made. The agreement will necessarily have to cover a longer period in most cases. For example. an agreement calling for a lump sum drawdown of funds to be uied to guarantee rehabilitation loans made by the private financial institution(s) would have to rim as long as the private rehabilitation loans, i.e., the agreement must require the block grant recipient to leave some funds on deposit until the private rehabilitation loan is fully repaid. wnicht may take 20 years. Section 570.513(c5has been amended Lit response to comments to make clear Mat the rehabilitation fund can be used as reserves and to nay issuance or achniniscrative costs in connection with the issuance ciboria's or notes by the block gent recipient or its agency, where such bond or note proceeds are to be used to fund rehabilitation teens or grants. Several comments were received on § 570.513(d]. All comments expressed concern with the requirement that "rehabilitation loans made with such private funds shall be siMject to the same requirements as are applicable to direct loan or grant assistance provided for the rehabilitation of private property under this Pert" This is not a new requirement resulting from the enactment of the drawdown authority, since authority to use block mtant funds as subsidies or guarantees in connection with private loans has always been in the CDBG regulations. To the extent that private ioans are effectively intermingled with CDEG funds, e.g., through use of CD.BG for interest subsidies or loan ,iyruiii-Mite en, it bits always been true that Lie use of the private funds ties been governed by the CLMG roles on sac of CDBC, funds, For eximm ie. such loans could not be made in a socially discriminatory manner or avoid labor s tandards requirements of the Davis,Bicon Act. as amended. Specific concerns ci the commenters ,centeree on the procurement 42 At tachment A-2 renuirernerits of the Office of Managenaent and Budget Circular No. .A-102 dated September 1.2.197, which superseded Federal Management Cirmitiar 74-7. However, the Department has cietertraneci that the procurement standards fAttachment Cll. of the foregoing Circular ordinarily applicable to CDEG assisted construction activities do not apply to the contracting for services and materials by private parties who make use of rehabilitation assistance offered by the ;rent recipient. where the contract is not enterect .into by the grant recipient. itself. This means that the procurement of the necessary work and materiel is done at the instance and for the benefit of the private owner. Although formal competitive bidding is therefore not requtred. all procurement transactiens, regardless of whether negotiated or advertised.ishould be conducted in a manner which encourages open and free competition. It should also be noted that the requirernente of the Davis-Bacon Act are appiicable to the rehabilitation of reeidentlal property pursuant tri Section 110 of the Housing and Community Development Act of 1974. if such property is designed for residential use of eigrit or more Quite a number of comments were received on 570.510(e), which prescribes a 45 day time limit can the start of use of deposited funds, . Commenters requested Mat the time limit be extended 10 60 or SO days. The 45 day limit was prescribed by statute in Section iO4(i)(1i of the Housing and Community Development Action af 1074, as amended by the 11177 Act Pub. L 05.- 1781 and cannot be amended by regulation.' Several comments on § 570.513(fl , related to a lump sum deposit made by the block gent recipient for the purpose e sta biishing a fund to guarantee privately financed renabdita tion loans. The clarifying language added to 570.513 bi regarding block grant funds eettri to guarantee rehabilitation loans made by the private financial ineututions is responsive to these concertS. One commenter on 5 570.5131g) recommended that. as with any program income, the interest earned on the rehabilitation fund be used for any eligible community development activity. This change was not made because this requirements is based on the statutory provision (Secnon I04(ilf2I(D) that "interest earned an such cash deposits shah be used in a manner which supports the community rehabilitation program.' HUD Area Office Approval Section 570413(Iii received the most comments. Commenters were very concerned about the timing requirement for the submittal of requests for a lump sum drawdowm in response to these comments, this section has been changed to permit HUD Area Off.ces Cci accept these requests for review and approval any time during the program year. Generaily, HUD review will be carried out as s part of the review and approval of a block grant application but requests tar a lump sum deawoown , will be accepted throughout the program year to preclude delay in the establiaament of local rehabilitation funds. Acr.crdingly. Paragraph (h; of § 570.510 has been modified. Several comments were received on § 170.8131i(. Sortie of the most cornprehenstve comments on this section raised questions about terminology e.g.. "below market rate." "longer repayment period' and "higher risk." These am terms which are contained in the statutory provision 104(i) and serve as the basis for these rules. The provision contathed in 570.517(i)(1) that private financial institutions reey satisfy the benefit miterie by committing private funds for the rehabilitation financing activities in amounts which are subatantially in excess of the deposit of block grant funds to also based on iarrgusee contained in Section 104(i). The final regulations continue to use the language prescribed in the statute. One change that has been made in this section in respoese to a corement is to direct HUD Area Offices to encourage block grant recipients to use minority hanks (a bank whMti is owned at least sd percent by minoeiry gram members). This is cons:stem with the national gnat of expanding the opportunities for minority business enterprises. A list of minority owned banks can, be obtained from the Office of Minority Business Enterprise. Department of Commerce, Washington. D.C. 20=0. • Several commenters were concerned with the benefit tests prescribed in Paragraph (I) when market rate interest is not payable on the rehabilitation fund. The tests require an estimate of foregone interest, and a quantified estimate of the valite or the benefits of the conermtment under the agreement. The Department recognizes that these requirements will require carefully considered estimates of value by the block grant recipient and the participating financial insfitutions, but the Department considers that such economic analysis is needed to meet the requirements when interest is not earned on deposited funds. Accordingly. changes in paregrapris (il(ZilAl and were not mane at this time. Comments Not Acted Upon. The description of the changes to 570.513 discussed several comments which HUD was unable to act upon. 12 many cases. comments procoseu the inclusion or modification of activities not authorized by the statute or the • exclusion of activities which were specificaily authorized. Other comments proposed alternative directions on matters of Departmental pa i icy which after due consideration were not accented. The following are some of the cartiMentS already discussed which I-T150 did not agree to act upon for the reasons set forth above: 1. Eliminate the requirement that where the rehabilitation fund or other block grant assistance is used to subsidize or guarantee the payment of rehabilitation icons made with private fwecis, or is used to provide a supotemental loaner grant to the - borrower of private funds, the rehabilitation leans made with such private funds shall be subject to the same requirements as are applicable to direct then or grant assistance provided for the rehabilitation GI pnvat o propert y under this pert. 2. ilctenct the 45 da7., time limit on Me elan of use of deposited hinds to C.i.D or 50 days, 43 At tachment A-3 3. Use the interest earned an the rehabilitation fund for any eligible community development activity. 4. Eliminate use df.certain terms, e.g., "below market rate." One commenter recammended that the Department support a proposal to amend the Housing and Community Development Act to authorize State Housing Finance agencies to be an eligible financial under 570.513. Several comments were received on the needs of small rehabilitation contractors who require prompt payment for work completed because of cash flow problems. These included recommendations to establish a rehabilitation fund under § 570.513 for this purpose. Although the timely payment of small contractors is a very important element of a local rehabilitation financing activity, the primary purpose of establishing a rehabilitation fund in private financial institutions is generally designed to assure the leverage of communitY development block grantlunds so that participating financial institutions commit private funds for loans in the local rehabilitation program in amounts in excess of deposit of community development funds. OTHER INFORMATION: A Finding of Inapplicability with regard to Environmental Impact has been prepared in accordance with HUD Handbook 1303.1. Copies of the statement and findings are available for inspection and copying during business hours in the ()Moe of the Rules Docket Clerk. Room 5210. Department of Housing and Urban Development, 451 Seventn Street. S.W., Washington, D.C. 20410. Accordingly 31 CFR 570 is amended as follows: 1. Section 570.503 is revised to read as follows: 570.03 Cash weltrtdrswais. at Except as provided in § 570.513. which covers lump sum drawnowns for financing the rehabtlitazIon of pnvately owned properties. the ttrnmg and ,m-munt of c ash withdrawais from the U.S. Treasury by the recipient for activities which are free from all conditions specified pursuant to I§ 570.311 ar 570.433(1)1121 shall be in accordance with U.S. Department of the Treasury regulations an withdrawal of cash from the Treasury for advances under Federal programs 131 CFR part 2051, as incorporated in handbook 1400.22 Rev.. Letter of Credit Procedures—Treasury Regional Disbursing Office System. (b) To the maximum extant practicable, program income shall be disbursed prior to making additional draws from the letter of credit to finance approved community development activities (including local option activities) as follows: (1) Program income in the form of repayments to a revolving fund, other than a nand to finance the rehabilitation of pnvately owned properties as provided for in 571.511 estabiislied to carry out an approved activity, snail he substantially disbursed from such: fund before additional draws are made from the letter of credit for the same activity. !2) All other program income shall be substantially disbursed for any approved activity hefore additional are retort,. ,rArn the letter of credit. 2. § 570.513 is added to read as follows: 520.513 Lurrto aufn drisvirdowri for nrouqtrty radmiPilitastiOts itnaneing. Subject to the conditions prescribed in this section recipients of grants under this Part may draw funds from ti)c letter of credit in a single lump sum to establish a rehabilitation fund in one or more private financial institutions for the purpose of financing the rehabilitation of privately owned properties as a part of the recipient's community development program, (a )0e/in/bons. (1) "Rehabilitation fund- means a fund established with block grants drawn down in a lump sum from the recipient's letter of credit for use in a rehabilitation financing program under the terms ot an agreement between t.he block grant recipient and the depositoEy pnvate financial institution ounuant 0 the requirements. of this section. 12) -Private financial institution- means a depository (including banks, sayings and can associations, credit unions and other financial institutional, in which deposits are federally insured, and which is a parry to such an agreement.131 -Pinvate bands" means the funds of the private financial institution. Private funds include funds held in trust for the benefit of bondholders or notehoiders of the CDBC recipient or its agency where such bond or note proceeds are to be used in connection with the rehabilitation program. (41 "Rehabilitation" means the activities eligible for rehabilitation or properties - pursuant to 570.202(c), including the acquisition of properties for rehabilitation by private entities organized for profit or on a not-for-profit basis, and the rehabilitation of commercial and industrial buildings and structures pursuant to 570.233(c;f1). fhl Requirement for agreement. A written agreement for time deposit of block grant funds to estabblea a rehabilitation fund shall be executed by the block grant recipient and perticioanng pnvate financial instnutiontsl. The agreement shall specificaily describe the obligations and responsibilities of the parties and tire tern,is and conditions on which such funds are to be deposited and used consistent with the requirements of this secnon. Except as mav otherwise Ito authorized by the :in Area Office in connection with approvals ion uses of the rehabilitation fund pursuant to paragraph (c)(5) or (71,.the agreement shall authorize the use of the rehabilitation rand only in connection with grants and loans made within a period of two years from the date of the agreement. The description of the proposed use of decanted binds in tile agreement shall include a statement on the intended use of loan repayments and interest earned. The agreement shall expressly provide that its terms and conditions are subiect to the provisions governing lump sum cfrawdowris for property rehabilitation § 570.513 of the HUD regulations on communi ty deveiopment block grants. 24 CFR Part 570. 44 Attachment A-4 (c) Uses of rehabilitation ,fund, The rehabilitation fund may be used for the following purposes: ll)TP make direct rehabilitation loans or grants to property owners:. . (2) To pay interest subsidies, or establlish a fund for payment of subsidies, on rehabilitation loans made by private financial institutions with private funds; (3) To guarantee the repayment of rehabilitation loans made to property owners by private financial institutions with private funds: or (4)7a serve as collateral for financing actually extended to the applicant (or applicant's agency) where such financing is used to make rehabilitation loans or grants. 351 To fund reserves and/or pay issuance or adreinisetiative costs to connection with the issuance of boncis or times by the recipient or its agency, where such bond or note proceeds arc to he used to Lint rehabilitation loans or grants. (8) For the payment of reasonable administrative fees and charges of the private financial institution related to the provision of financing for the rehabilitation of private property; or for (7) Other uses as may be approved by 1-it'D consistent with the objectives of this section. (d) Rehabilitation loans made with private funds. Where the rehabilitation fund or other block grant assistance is used to subsidize or guarantee the payment of rehabilitation loans made wort private funds, or is used to provide a supplemental loan or grant to the borrower of the private funds, the rehabilitation loans made with such privaiii feeds shall be subject to the same requirements 'excluding the teeerre tier of loan repayments as preveam incernet as are applicable to direct loan or grant assistance provided for the rehabilitation of private property under this Part. (e) Time limit on start of use of deposited funds. Use of the deposited funds for rehabilitation financing assistance (eige first loan is made, subsidized or guaranteed) must start Within 45 days of the deposit. Should use of deposited funds not start within 45 days, the recipient may be required by HUD to return all or part of the deposited funds to the letter of credit, (fl Return of unused deposits. At the termination of the period of the agreement all uncioligaieti funds (funds of the rehabilitation fund that have not been encumbered or disbursed) then on deposit shall be returned to the recipient's letter of credit uniess the block grant recipient nes been or is being authorized by HUD to extend the agreement for an additional period. lin addition., the block grant recipient shall reserve the right to withdrew from the rehabilitation Emit/ any et:obligated amounts required by HUD in the exercise of coneeteve or remedial actions authorized under § 377.610(b) of the regulations. (g) Interest earned on the rehabilitation land. Interest earned on the rehabilitation fund shall be used pursuant to the terms and conditions of the agreement consistent with the 7.19s authorized under paragraph (c) of this section. (h) Request „far HOD review and approval of lL'177,7 sum aakwdaivn. HUD area office review and approval-of a request for a lump sum drawdown is required enter to drawdown. HUD review can be canned out anytime during the prograiri year but generally HUD will review these requests as a part of the review and approval of a block grant application except those requests submitted in conjunction with grants made under the Secretary's fund for new communities. A request suiamMed Ea connection with the new commumnes fund is subiect to the renuirernents of this section...however it sha.J be reviewed dna approved by the New COM.T111.1r11: Corporation. welch apprevee and administers granis under the new communitien lainei. All requests for drewdown snail include: (11 A copy of the written agreement described in paragrape (2) The reasons for the locality's belief that the agreement meets the HUD approval standards set forth in paragraph (1); and (3) Certification, described in paragraph f i j(2 ) i): where the request proposes that the benefit to be derived from lump sum drawdown qualifies under paragraph (fi(2)(i). (i) HUD review criteria for approval of lump sum arawdown request. The HUD area office shall approve a request for :Limo sum drawdown if it determines that the funds will be deposited to one or more private financial institutions under an agreement which includes, one or more of the commitments described in paragraph (1)(1) of this section: meets the benefit tests described in paragraph (i)(2.) of this section: meets the testy concerning the amount of drawdown described in paragrapo igt) of this section: and otherwise meets the • requirements of pa:agree:1 (bj of this section. Consistent with the zarional goal of expanding the opportunitiee for minority business enterprises. the 1-11I0 area office shall encourage 'block gran: recipients to use minority 'OE:71(.3 (a bank which: is owneo at least .N) percent by minority group members). (1) Commitments al, private financ:cl iriVitudcins, 01 Commitment of private funds for the rehabilitation financing ac.,jvities in amounte which are substantially in excess of the deposit of block grant funds: Cdramitment of private funds for rehabilitation financing activities ai below-market interest rates, or with longer repayment periods. or at higher risk than would mormaily be taken; (iii) Provision of administrative servicue by the financial institutions in suppert of the rehabilitation iirtancing activities at no cost oral reduced Cost, enelit loots. (i) When rnar.ket rate interest is payable an the reticoitiLitlori friinci--ivVhen interest at the market rate for deposits of similar maturity and size it payable on the rehabilitation fund, the apoileaet must certify that the cot:lei:intent ender the agreement ptitriipiarii to parai.3raph provides 4_5 Attachment A-5 or Or significant benefit meeting the needs of ' its rehabilitation obiecoves consistent with its block grant application. Such certification shall be accepted by the Area Office for the purpose of meeting the requirements of the benefits test of this paragraph in the absence of substantial evidence to the contrary. Eli) When market role rnterest is not payable on the rehabilitation fund— When less than the market rate interest is Payable an the rehabilitation fund, the value of the benefits of the commitment under the agreement must be at least equal to the interest foregone. The comparison of the benefit and interest foregone snail be based on the following: (A) Estimate of foregone interest—An estimate of the difference between the interest payable under the agreement and the amount of interest that would be earned on the estimated average monthly balance of the rehabilitation fund at the market rate for deposits of similar maturity and size. (13# Estimote of value of benefits—A quantified esumate of the value of the benefits of the commitment under the agreement. For example. if as a result of the deposit the private financial institution provides free loan origination services, the benefit would be quantified as the amount of the direct fee that • would otherwise have to be paid for such services. (3) Basis for amount of drawdoverr. The amount of funds that a block grant recipient proposes to draw for deposit for a rehabilitation fund shall not exceed the amount of funds that the applicant reasonably expects will be required under the terms or the agreement during the period of the agreement and based on either (i) Prior Level of rehabilitation activity: (11) Rehabilitation staffing and management plans of the locality for the period of the agreement. 0 • (Tine I. Housing and Carriaturtir., Develacrn ant Act at 174 142 U.S.C_ Z311 et seq.); Title I. Hausa-1g arid Comma:117 Da,eiopcient AC: Of 1977 {Pnisi,L 03-1281: and secten ridI, .Dapartrneni of Housing aria - Urban Devalapmenc Act 02 .1535Id).) Issued at Waii.turigtnct• D.C.. Marct 22, 1071. anti orr C., 04850. It, Assasa, Snrcrreary ler Canurfundry Piemonn; cncl O'-lg. Rttkret No. R-74-teat FR Co. taloa= Filed .1-5-aNG 04 smi lin-LA.3 CODE 611071--tA 4.6 pRI:7,155 119c-,,-7.7,1--7.!9/1,:,