Tag Archive for: Rural Housing

HAC News: September 17, 2014

/in

HAC News Formats. pdf

September 17, 2014
Vol. 43, No. 19

• Sept. 15-Oct. 15 is National Hispanic Heritage Month • Congress to pass continuing resolution for early FY15 • Vilsack responds to congressional letter about 502 spending • Senate committee advances Mensah nomination • Rural poverty decreases, yet remains higher than U.S. poverty • HUD offers economic development funds for Appalachia and the Mississippi Delta • USDA posts amended maps showing future area eligibility • Regulators seek comments on proposed revisions to CRA questions and answers • HUD revises model standards for manufactured home ground anchoring • GAO report says HUD can do more on manufactured housing • Broad access to mortgage financing recommended to help reduce income inequality • Farmworker housing and health conference set for November • Webinar to cover protecting seniors and other RD tenants from displacement • Please nominate national or local rural housing leaders for HAC awards!

September 17, 2014
Vol. 43, No. 19

SEPT. 15-OCT. 15 IS NATIONAL HISPANIC HERITAGE MONTH. President Obama’s proclamation includes a call for comprehensive immigration reform.

CONGRESS TO PASS CONTINUING RESOLUTION FOR EARLY FY15. The House is expected to pass a CR on September 17 and the Senate soon after that. It will fund the federal government at FY14 levels until December 11. In a post-November-elections session Congress will have to complete work on FY 2015 appropriations or pass another CR.

VILSACK RESPONDS TO CONGRESSIONAL LETTER ABOUT 502 SPENDING. Responding to concerns about USDA’s ability to use all available Section 502 direct funds before FY14 ends September 30 (see HAC News, 8/6/14), USDA Secretary Tom Vilsack wrote to House and Senate Agriculture Appropriations Subcommittee leaders explaining steps being taken this year (see HAC News, 7/23/14) and planned for next year.

SENATE COMMITTEE ADVANCES MENSAH NOMINATION. The Senate Agriculture Committee held a hearing September 10 on the selection of Lisa Mensah as USDA Under Secretary for Rural Development (see HAC News, 5/14/14). A confirmation vote by the full Senate has not yet been scheduled.

RURAL POVERTY DECREASES, YET REMAINS HIGHER THAN U.S. POVERTY. The number of rural Americans living in poverty decreased last year, according to a new Census Bureau report. Overall, the official U.S. poverty rate was 14.5% in 2013, a decline from 15% in 2012. Income and Poverty in the United States: 2013 says there was no statistically significant change in either the number of people living in poverty or real median household income. State and local data will be released September 18. A HAC Rural Research Note provides more details.

HUD OFFERS ECONOMIC DEVELOPMENT FUNDS FOR APPALACHIA AND THE MISSISSIPPI DELTA. Both programs aim to increase access to capital for business lending and economic development, and applications are due November 3. For Appalachia, the only eligible applicants are state community and economic development agencies. For Delta funds, nonprofits and tribal governments are eligible. Contact Thann Young or Monica Wallace, HUD, 877-787-2526.

USDA POSTS AMENDED MAPS SHOWING FUTURE AREA ELIGIBILITY. Maps now available on RD’s website (under the Future Eligible Areas heading) eliminate “rural in character” changes (see HAC News, 9/3/14). A disclaimer indicates slight alterations may be made before the maps take effect on October 1.

REGULATORS SEEK COMMENTS ON PROPOSED REVISIONS TO CRA QUESTIONS AND ANSWERS. The Interagency Questions and Answers Regarding Community Reinvestment, revised periodically, supplement the Community Reinvestment Act regulations issued by the Federal Reserve board, the FDIC, and the Office of the Comptroller of the Currency. Comments are due November 10. Contact Bobbie Kennedy, OCC, 202-649-5470.

HUD REVISES MODEL STANDARDS FOR MANUFACTURED HOME GROUND ANCHORING. A final rule amends the Manufactured Home Model Installation Standards, establishing a uniform test method to determine and rate ground anchor performance in different soil classifications. Contact Pamela Beck Danner, HUD, 202-708-6423.

GAO REPORT SAYS HUD CAN DO MORE ON MANUFACTURED HOUSING. Manufactured Housing: Efforts Needed to Enhance Program Effectiveness and Ensure Funding Stability (GAO-14-410) recommendations related to the HUD Code updates, FHA insurance, and fees. Contact Matthew Scirè, GAO, 202-512-8678.

BROAD ACCESS TO MORTGAGE FINANCING RECOMMENDED TO HELP REDUCE INCOME INEQUALITY. Continued government provision of affordable housing and financing is among the recommendations of Responding to Rising Inequality: Policy Interventions to Ensure Opportunity for All, a brief published by the Haas Institute for a Fair and Inclusive Society at the University of California at Berkeley.

FARMWORKER HOUSING AND HEALTH CONFERENCE SET FOR NOVEMBER. “Farmworker Housing Quality and Health: A Transdisciplinary Conference” will be held November 11 in Arlington, VA. Registration is $50 until October 1.

WEBINAR TO COVER PROTECTING SENIORS AND OTHER RD TENANTS FROM DISPLACEMENT. The National Housing Law Project will offer a free webinar on October 21 at 2:00 pm Eastern time/11:00 am Pacific on “Prepayments, Maturing Mortgages, and Foreclosures: Protecting Seniors and Others from Rural Development Rental Housing Displacement.”

PLEASE NOMINATE NATIONAL OR LOCAL RURAL HOUSING LEADERS FOR HAC AWARDS! Nominations are due September 30 for the Cochran/Collings Award for national rural housing service and the Skip Jason Community Service Award. The honors will be presented at the National Rural Housing Conference in December. Complete the online nomination form. Questions? Contact Lilla Sutton, HAC, 202-842-8600.

Coming Together for a Common Cause

/in

by Eric Oberdorfer

It’s hard to believe that two years have passed since the last HAC Rural Housing Conference. As rural housers, we have faced our share of challenges recently. Congress is deadlocked, funding for needed federal housing programs remains historically low, and the stock of safe, high-quality, affordable housing in rural America continues to decline, leaving too many low-income families and individuals without sufficient housing options.

These past years have seen the support and resources necessary for our network threatened, and we have had to fight to maintain our work. These challenges make coming together for our common cause even more important in 2014. The rural housing network has a proud history of empowering individuals and families, improving lives, and making lasting impacts across rural America. However, for a number of years, we have been in a defensive posture. It is time for us to shift away from this and go on the offensive. To do this we mustretool our collective talents, rebuild the innovative spirit that got us where we are, and renew our passion for the mission that guides us.

Retool, Rebuild, Renew is the theme of our conference this year. Although this theme could describe the construction or rehab of housing, the theme is not about bricks and mortar. It’s about a housing movement – these actions are more critical to our work than ever before.

Rural communities desperately need affordable housing to combat serious challenges that have developed over the past few years. The United States’ economy fell into one of the most severe economic recessions in a half century. Our country’s rapidly aging population will have significant impacts on our current housing stock. Poverty rates in rural America have grown. Further compounding these issues is the continued downsizing of federal programs that support the development of housing in rural communities, programs that are needed now more than ever. Luckily, rural housers are a resourceful group and have met these issues head-on by learning new skills, forging new partnerships, and considering new approaches. It is time we come together to share our successes and determine strategies to ensure our continued ability to provide our communities with safe, affordable housing.

Fostering the development of new skills and partnerships is a key part of the National Rural Housing Conference. More than just a collection of workshops and plenaries, the Conference is about coming together to share our collective experiences, build our expertise, and gain a better understanding of what works, what doesn’t, and why. It is a space that encourages networking and the sharing of ideas between people who know firsthand the challenges the housing movement faces. It provides an opportunity to gain new tools that can help us succeed in the current environment of housing and community development.

Although the landscape for affordable housing has changed dramatically since the first National Rural Housing Conference 45 years ago, one thing remains as true as ever – individuals, families, and communities need to have high-quality affordable housing in order to thrive. To respond to the needs of rural communities we must first come together. The National Rural Housing Conference gives us the chance to gain new tools, learn from each other, and, most importantly, renew our commitment to affordable housing.

The HAC Rural Housing Conference will be held December 3-5, 2014 in Washington, DC. Registration is currently open.

Registration is now open for the HAC Rural Housing Conference

/in

slider 1600x400 rnd3

ABOUT THE CONFERENCE

Register-Now-Button

The biennial HAC Rural Housing Conference brings together stakeholders in the field of rural affordable housing from local nonprofits, federal agencies, Congress, state and local governments, and other industry leaders for two-and-a-half days of training, discussion, and networking.

The Conference features nearly 40 workshops where participants will learn best practices for housing development, organizational management, resource development, and innovative approaches to housing and community development. The Conference also includes a pre-Conference day, packed with gatherings for coalitions, association, and working groups.

For rural nonprofits, the Conference provides an excellent opportunity to network and improve connections to federal agencies and national nonprofit organizations. For many of the attendees, this conference represents their sole opportunity during the year to connect with these important policy makers and experts.

Retool, Rebuild, Renew

This year’s conference theme is Retool, Rebuild, Renew. Although these verbs could describe the construction or rehab of housing, the theme is not about bricks and mortar. It’s about our movement. The rural housing network has a proud history of accomplishment and has empowered, improved, and made lasting impacts across rural America. However, for a number of years, we have been in a defensive posture-the support and resources necessary for our network have been threatened. It is past time to shift from a reactive to a proactive posture. It is time go on the offensive and retool our collective talents, rebuild the innovative spirit that got us where we are, and renew our passion for the mission that guides us. HAC’s Rural Housing Conference will help get us back on track to expand the accomplishments of the past.

For more information on the HAC Rural Housing Conference, visit HAC’s registration portal.

Conference app

Discussion Topics and Papers

HAC News: September 3, 2014

/in

HAC News Formats. pdf

September 3, 2014
Vol. 43, No. 18

• RD suspends rural in character eligibility changes • National Office agreement required for some RD prepayment incentives • New guidelines apply to extensions and deobligations of unused Section 515, 514, and 516 funds • Online homeownership education provider approved for Section 502 borrowers • RD addresses thermal standards for manufactured housing • Guidance provided for rural multifamily design/build and construction management proposals • Reminder issued about Section 515 borrowers who received litigation damages • FHFA proposes new housing goals for Fannie Mae and Freddie Mac • Changes to HMDA regulations suggested • New report covers challenges of housing seniors • Drop in homeless veterans estimated • Shortage of affordable rentals remains • CONFERENCE REGISTRATION IS OPEN!

September 3, 2014
Vol. 43, No. 18

RD SUSPENDS RURAL IN CHARACTER ELIGIBILITY CHANGES. In response to public concerns about changes in eligibility for rural housing programs based on determinations that some places are no longer “rural in character,” USDA has suspended use of this factor to alter a community’s rural status. No changes will be made until October 2015 at the earliest, and a new procedure will provide a 90-day public comment period on proposed modifications. This issue is not related to eligibility changes based on population growth (see HAC News, 2/5/14).

NATIONAL OFFICE AGREEMENT REQUIRED FOR SOME RD PREPAYMENT INCENTIVES. An Unnumbered Letter dated July 11, 2014 requires RD state offices to obtain advance approval before offering additional Rental Assistance or equity loans to Section 515 borrowers who want to prepay their loans. The UL says it is “an interim step” while regulatory changes are developed. Contact Tiffany Tietz, RD, 616-942-4111 ext. 126.

NEW GUIDELINES APPLY TO EXTENSIONS AND DEOBLIGATIONS OF UNUSED SECTION 515, 514, AND 516 FUNDS. An Unnumbered Letter dated July 30, 2014 provides timeframes and processes for USDA staff. Limited extensions may be permitted. Contact Mirna Reyes-Bible, 202-720-1753 (Section 514/516) or Melinda Price, 614-255-2403 (Section 515).

ONLINE HOMEOWNERSHIP EDUCATION PROVIDER APPROVED FOR SECTION 502 BORROWERS. An Unnumbered Letter dated August 22, 2014 announces the agency has approved Framework to provide online education, which can be used only when other formats are not available. Contact Shantelle Gordon, RD.

RD ADDRESSES THERMAL STANDARDS FOR MANUFACTURED HOUSING. The HUD Code specifies minimum thermal standards for each state, while RD applies them by county. Administrative Notice (AN) 4772 (Aug. 4, 2014) lists the standards for specified counties. Contact William Downs, RD, 202-720-1499.

GUIDANCE PROVIDED FOR RURAL MULTIFAMILY DESIGN/BUILD AND CONSTRUCTION MANAGEMENT PROPOSALS. AN 4770 (July 11, 2014) requires National Office approval to use Section 514 or 515 loans for design/build or construction management arrangements. Contact Sherry Engel, RD, 715-345-7677, or William Downs, RD, 202-720-1499.

REMINDER ISSUED ABOUT SECTION 515 BORROWERS WHO RECEIVED LITIGATION DAMAGES. An Unnumbered Letter dated June 24, 2014 instructs RD staff about servicing the accounts of borrowers who received damages payments pursuant to the May 21, 2007 agreement that settled a lawsuit against USDA regarding prepayments. Those owners cannot prepay their loans (unless USDA determines a property is no longer needed) and cannot receive incentives to discourage prepayment. Contact Tiffany Tietz, RD, 616-942-4111 ext. 126.

FHFA PROPOSES NEW HOUSING GOALS FOR FANNIE MAE AND FREDDIE MAC. Comments are due October 28 on possible changes to be in effect from 2015 through 2017, including a new subgoal for financing small multifamily rental properties (5-50 units). No rural subgoal is proposed. Contact Dr. Nayantara Hensel, FHFA, 202-649-3122.

CHANGES TO HMDA REGULATIONS SUGGESTED. Comment by October 29 on a Consumer Financial Protection Bureau proposal to implement a portion of the Dodd-Frank Act. Lenders subject to the Home Mortgage Disclosure Act would have several new reporting requirements, some existing requirements would be clarified, and some institutional and transactional coverage would be changed. Contact CFPB’s Office of Regulations, 202-435-7700.

NEW REPORT COVERS CHALLENGES OF HOUSING SENIORS. Housing America’s Older Adults – Meeting the Needs of an Aging Population, published by Harvard’s Joint Center for Housing Studies, analyzes the ability of the existing U.S. housing stock to meet growing needs for affordability, accessibility, social connectivity, and supportive services.

DROP IN HOMELESS VETERANS ESTIMATED. HUD, VA, and the U.S. Interagency Council on Homelessness (USICH) estimate that as of January 2014 veterans’ homelessness nationwide had declined by 33% since 2010.

SHORTAGE OF AFFORDABLE RENTALS REMAINS. A new Housing Spotlight report from the National Low Income Housing Coalition shows that nationwide there are only 31 affordable and available units for every 100 extremely low-income renters (with incomes at or below 30% of area median) and only 16 for every 100 deeply low-income renters (below 15% of area median). The report provides data for states and for 50 large metro areas.

CONFERENCE REGISTRATION IS OPEN! Register online for the National Rural Housing Conference 2014: Retool, Rebuild, Renew, in Washington, DC, December 3-5 with pre-conference activities December 2. Until October 31, the rate is $350 for nonprofits and government, $400 for for-profits. Contact HAC staff, registration@ruralhome.org.

Understanding HAC Loan Products: An Overview on Uses, Eligibility, Requirements and Restrictions

/in

Materials Posted

Power Point Presentation | Webinar Recording

As funding requirements become more rigorous, it is increasingly important for borrowers to be aware of and understand lender restrictions and overall requirements. This webinar is specifically designed to enhance current HAC borrower knowledge and provide potential nonprofits, for profits and government borrowers with an overview of HAC’s available loan products. Participants will hear directly from HAC’s senior loan fund staff and be able to obtain answers to many loan product related questions.

understand-hac-loans-img

Don’t miss this opportunity to obtain first-hand information and guidance; register now and join the Housing Assistance Council for a detailed overview of its loan products, borrow eligibility and uses!

HAC News: August 20, 2014

/in

HAC News Formats. pdf

August 20, 2014
Vol. 43, No. 17

• USDA RD to revise guidance on domestic violence • Section 502 direct processing improvements scheduled • RD to delay implementing new rule for Section 502 guaranteed loans • HAC recommends notice to tenants about maturing USDA mortgages, asks for dialogue • Amendments proposed to reserve account rules for properties with 515 and 538 loans • Fair Market Rents for FY15 proposed • HUD to change environmental review form • Manufactured housing label fee increased • FHFA requests comments on its strategic plan • Study documents digital divide for tribal libraries • Permanent supportive housing found to reduce chronic homelessness • Conference on farmworker housing and health set for November • Please nominate national or local rural housing leaders for HAC awards!

August 20, 2014
Vol. 43, No. 17

USDA RD TO REVISE GUIDANCE ON DOMESTIC VIOLENCE. HAC and a number of other organizations signed on to a letter from the National Housing Law Project to USDA rural housing administrator Tony Hernandez requesting changes in AN 4747, which applies the Violence Against Women Act to USDA’s multifamily programs (see HAC News, 3/5/14). In a response dated August 6, Hernandez agreed to make most of the changes.

SECTION 502 DIRECT PROCESSING IMPROVEMENTS SCHEDULED. Administrator Tony Hernandez gave HAC a summary showing that in FY15 USDA will automate underwriting for Section 502 direct loans, revise its packaging regulations, allow packagers to submit applications electronically, and establish an imaging system for documents.

RD TO DELAY IMPLEMENTING NEW RULE FOR SECTION 502 GUARANTEED LOANS. An email sent to stakeholders on August 19 says a notice will be published in the Federal Register delaying the rule’s effectiveness to December 1, 2014 rather than September 1, the date originally scheduled. Contact USDA, 202-720-1452.

HAC RECOMMENDS NOTICE TO TENANTS ABOUT MATURING USDA MORTGAGES, ASKS FOR DIALOGUE. In an August 9 letter to Tony Hernandez, HAC expressed concern about tenants who will lose Section 521 Rental Assistance when USDA mortgages end. HAC urged USDA to ask owners to notify tenants well in advance of mortgage maturities, and suggested further discussions about ways to maintain the affordability of these units.

AMENDMENTS PROPOSED TO RESERVE ACCOUNT RULES FOR PROPERTIES WITH 515 AND 538 LOANS. USDA’s countersignature would no longer be required for rental projects that have both Section 538 guaranteed loans and Section 515 direct loans; the Section 538 regulations would apply. The change would also clarify that loan guarantee fees must be paid from operating accounts, not reserve accounts. Comments are due October 14. Contact Tammy S. Daniels, USDA, 202-702-0021.

FAIR MARKET RENTS FOR FY15 PROPOSED. Comments are due September 15 on the FMRs HUD will use in FY15. Contact local HUD program staff.

HUD TO CHANGE ENVIRONMENTAL REVIEW FORM. A final rule allows HUD to develop a single form to be used by HUD employees and other responsible entities. Contact Danielle Schopp, HUD, 202-402-4442.

MANUFACTURED HOUSING LABEL FEE INCREASED. The increase, proposed in May (see HAC News, 5/14/14), is effective September 12, 2014. Manufacturers will pay $100 for each new transportable section produced. Contact Pamela B. Danner, HUD, 202-708-6423.

FHFA REQUESTS COMMENTS ON ITS STRATEGIC PLAN. The Federal Housing Finance Agency’s plan “reflects the agency’s priorities as regulator of the Federal Home Loan Bank System and as regulator and conservator of Fannie Mae and Freddie Mac” and is the first under new director Mel Watt. Comments are due September 15.

STUDY DOCUMENTS DIGITAL DIVIDE FOR TRIBAL LIBRARIES. Digital Inclusion in Native Communities: The Role of Tribal Libraries, a report by the Association of Tribal Archives, Libraries, and Museums funded by the Institute of Museum and Library Services, provides the first comprehensive data on the subject. Research found that 89% of tribal libraries offer access to the internet and 86% have public computer workstations, compared to 100% of public libraries. At least 40% of tribal libraries studied do not have a broadband internet connection. Contact Susan Feller, ATALM, 405-401-8293.

PERMANENT SUPPORTIVE HOUSING FOUND TO REDUCE CHRONIC HOMELESSNESS. An examination of data at the community level confirms findings at the individual level: over time, increased investment in permanent supportive housing is associated with decreased rates of chronic homelessness. “The Relationship between Community Investment in Permanent Supportive Housing and Chronic Homelessness” was published in Social Service Review 88.2 (2014).

CONFERENCE ON FARMWORKER HOUSING AND HEALTH SET FOR NOVEMBER. “Farmworker Housing Quality and Health: A Transdisciplinary Conference” will be held on November 11 in Arlington, VA. Registration is $50 until October 1 and $70 after that date.

Please nominate national or local rural housing leaders for HAC awards! Nominations are due September 30 for the Cochran/Collings Award for national rural housing service and the Skip Jason Community Service Award. The honors will be presented at the National Rural Housing Conference in December. Complete the online nomina-tion form. Questions? Contact Lilla Sutton, HAC, 202-842-8600.

Building a Community for Veterans: Patriot Place, Tennessee

/in

Materials Available

Power Point Presentation | Webinar Recording

The Housing Assistance Council (HAC) is pleased to invite you to participate in a webinar on single- and multi-family affordable housing for veterans. Targeted to veterans, Patriot Place is a community with a mix of affordable rental and homeownership opportunities for up to 75 households within a subdivision/neighborhood setting in Johnson County, Tennessee. The project site is accessible to services and is within 40 minutes of a nationally-ranked VA hospital in Mountain Home, Tennessee. Eastern Eight CDC, the local nonprofit developer of this community, offers a range of affordable housing options in this community including rental, rent-to-own, and self-help homeownership.

Affordability is one of the nation’s biggest housing challenges, for veterans and non-veterans alike. Households who spend over 30 percent of their income on housing costs are considered cost-burdened. Approximately 34 percent of rural veterans in their 20s, and 25 percent of veterans in their 30s have affordability problems. The goal for Patriot Place is to provide veterans with decent, safe, comfortable and affordable housing. Providing housing and needed services for our veterans can be complicated in rural areas due to vast geographies, limited resources, and less social service infrastructure.

Please join us on August 20th to learn more about the challenges faced and steps pursued in this innovative and successful model for serving rural veterans.

This webinar is supported by The Home Depot Foundation. For more information, please email Janice Clark at Janice@ruralhome.org.

Register Now! https://ruralhome.adobeconnect.com/e273e88kun9/event/event_info.html

Learn more about the HAC loan fund

/in

The HAC loan fund is hosting two upcoming webinars that will provide an overview of its products and help organizations in rural areas better understand how to access and creative utilize capital from HAC.

Understanding HAC Loan Products: An Overview on Uses, Eligibility Requirements and Restrictions

Register Now!

Making it Work: Creative Ways to Utilize HAC Loan Products in Your Affordable Housing Development

Register Now!

The HAC loan fund lends only to organizations that develop housing in rural areas and does not offer programs accesible for individuals looking for housing. If you are looking for housing for yourself, visit our “Looking for Housing” page.

HAC Recommends Notifying Tenants about Maturing Mortgages

/in

On August 7, 2014, HAC wrote a letter to Tony Hernandez, USDA’s rural housing programs administrator, to express concern about tenants in properties that will lose USDA Section 521 Rental Assistance when their USDA mortgages mature. Over 8,000 properties with Section 515 or Section 514 mortgages are expected to make their last payments to USDA by the year 2020. Because many of the tenants rely on USDA Section 521 Rental Assistance, which is available only when a USDA mortgage is in place, thousands of tenants in those 8,000 properties risk losing their aid when these mortgages mature.

HAC’s letter to Hernandez encourages USDA to follow HUD’s practice and ask property owners to notify tenants at least nine months before their Rental Assistance ends. The letter also asks for a dialogue between HAC, USDA, and other interested parties to identify approaches to keeping the housing affordable.

Is the Housing Crisis Over in Rural America?

/in

by Lance George

In 2008 the U.S. economy fell off a cliff. Depending on your perspective it either slipped or was pushed from that precipice by the housing markets. In 2009 and 2010, when the crisis was arguably at its worst, the Housing Assistance Council began receiving frequent inquiries from the press and others asking, “How is the housing crisis affecting rural America?” We simply had no answer. Mortgage and foreclosure data were virtually nonexistent for most rural areas.

After six years and some hindsight, we are asking some questions ourselves. Is the crisis over? And what are the lingering effects? These seemingly basic inquiries still prove challenging, particularly from the rural perspective. So we sought assistance from four affordable housing experts to help answer these questions.

Read the complete blog post at Rooflines.

GET THE HAC NEWS!

Sign-up for HAC information products

SIGN UP HERE
Link to: Impact

50 Years for Rural America

Over 50 years HAC has worked in every U.S. state and the territories. Learn more about what our work means for rural communities.

Board Portal

Housing Assistance Council   |  1828 L Street. N.W., Suite 505, Washington, D.C. 20036
(202) 842-8600  |  (202) 347-3441  |  hac@ruralhome.org

HAC is an equal opportunity provider, employer, and lender.