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INTEROFFICE MEMORANDUM
Department of Development Services
Division of Housing and Neighborhood Revitalization
Date: July 29, 2015
To: Brian McDougal, City Manager
Mayor and City Council
From: Beverly Freeman, Acting Director of Housing and Neighborhood
Revitalization
RE: P.R. NO. 19092—Authorizing Tender Loving Care Center for
Children d/b/a Legacy Community Development Corporation to
Implement a Lease Purchase Program
Nature of the request:
The Housing and Neighborhood Revitalization Division recommends the City
Council adopt Proposed Resolution No. 19092 authorizing Tender Loving Care
Center for Children, d/b/a Legacy Community Development Corporation
(TLCCC, d/b/a Legacy CDC) to implement a Lease Purchase Program.
Staff Analysis/Considerations:
Among the purposes of the Cranston-Gonzalez National Affordable Housing Act
of 1990 (NAHA), as amended, participating jurisdictions are required to (1)
promote partnerships with nonprofit organizations, and(2) expand nonprofit
organizations' capacity to develop and manage decent and affordable housing.
To assist in achieving these purposes, participating jurisdictions are encouraged to
identify Community Development Corporations that are capable, or can
reasonably be expected to become capable, of carrying out elements of its housing
programs. It is essential that participating jurisdictions build and strengthen
partnerships with Community Housing Development Organizations (CHDO).
TLCCC, d/b/a Legacy CDC is a chartered Texas non-profit corporation and has
obligated themselves to assist the City with meeting the requirements of the
"Remember we are here to serve the Citizens of Port Arthur"
P.O. BOX 1089 • PORT ARTHUR,TEXAS 77641-1089 • 409/983-8101 •FAX 409-982-6743
HOME Program and all other Federal Requirements. To assist the City of Port
Arthur in carrying out its mission to eliminate blight and provide decent, safe,
sanitary and affordable housing for the low and moderate income persons/families
of the community, TLCCC, d/b/a Legacy CDC will implement a Lease Purchase
Program.
Recommendation:
The Housing and Neighborhood Revitalization Division recommends the City
Council adopt Proposed Resolution No. 19092 authorizing TLCCC, d/b/a Legacy
CDC to implement a Lease Purchase Program.
Budget Consideration:
None
P. R. 19092
07/29/2015 BF
RESOLUTION NUMBER
A RESOLUTION AUTHORIZING APPROVAL OF GUIDELINES
FOR THE IMPLEMENTATION OF A LEASE PURCHASE PROGRAM
CONSISTENT WITH THE HOME PROGRAM, AND AUTHORIZING
TENDER LOVING CARE CENTER FOR CHILDREN, D/B/A LEGACY
COMMUNITY DEVELOPMENT CORPORATION TO IMPLEMENT A
LEASE PURCHASE PROGRAM.
WHEREAS, Tender Loving Care Center for Children, d/b/a Legacy Community
Development Corporation, (TLCCC d/b/a Legacy CDC), Port Arthur, Texas was chartered as
a Texas Non-profit corporation to provide safe, decent, sanitary and affordable housing to
low and moderate income families; and,
WHEREAS, the Department of Housing and Urban Development awards
Federal HOME Program funds to the City annually, pursuant to the Housing and
Development Act of 1974 for the primary benefit of low and moderate income
persons/families; and,
WHEREAS, the City Council, by its adoption of Resolution Number 15-118,
(authorizing submission of a 2015 Consolidated Plan) has obligated the City to provide
assistance for Community Housing Development Organizations (CHDO) to assist low and
moderate income persons/families; and,
WHEREAS,TLCCC, d/b/a Legacy CDC has obligated themselves to assist the
City with meeting the requirements of the HOME Program and all other Federal
Requirements to assist in carrying out the mission of the City of Port Arthur to eliminate
blight and provide decent, safe, sanitary and affordable housing for low and moderate-
income persons/families of the community; and,
WHEREAS, TLCCC, d/b/a Legacy CDC has met the criteria for implementing a
Lease Purchase Program in accordance with Federal and State Program requirements; and,
WHEREAS, the Housing and Neighborhood Revitalization Division
recommends the City Council authorize TLCCC, d/b/a Legacy CDC to implement a Lease
Purchase Program in accordance with Federal and State Program requirements as
identified in the Program Guidelines in substantially the same form as the attached hereto
as Exhibit "A".
NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
PORT ARTHUR:
Section 1. That the facts and opinions in the preamble are true and
correct.
Section 2. That the TLCCC, d/b/a Legacy CDC is authorized to
implement a Lease Purchase Program in accordance with Federal and State Program
requirements as identified in the Program Guidelines in substantially the same form as
the attached hereto as Exhibit "A".
Section 3. That a copy of the caption of this Resolution be spread
upon the minutes of the City Council.
READ, ADOPTED AND APPROVED this day of August, A.D., 2015
at a Regular Meeting of the City Council of the City of Port Arthur, Texas by the following
vote: AYES:
MAYOR
COUNCILMEMBERS
NOES:
MAYOR
ATTEST:
SHERRI BELLARD, CITY SECRETARY
APP OVED AL TO FORM:
\ictk
VAL TIZENO, CITY4 ORNEY
APPROVED FOR ADMINISTRATION:
BRIAN MCDOUGAL, CITY MANAGER
BEVERLY FREEMAN, ACTING DIRECTOR
OF HOUSING AND NEIGHBORHOOD REVITALIZATION
EXHIBIT "A"
LEASE PURCHASE PROGRAM
GUIDELINES
TENDER LOVING CARE CENTER FOR
CHILDREN,
D/ B/A
LEGACY COMMUNITY DEVELOPMENT
CORPORATION
LEASE-PURCHASE PROGRAM
2015
EQUAL HOUSING
OPPORTUNITY
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 1 of 17
TABLE OF CONTENTS
1. Rationale and purpose
2. Policies
3. Lease-purchase agreement
4. Pro forma of a typical unit
5. Procedures
6. Property selection criteria and rehab standards
ATTACHMENTS
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 2 of 17
• RATIONALE AND PURPOSE
a. Definition/summary
The goal of LCDC's lease-purchase program is to provide potential first-time homebuyer's with
the opportunity to live in and lease the home they intend to purchase while addressing any
obstacles to obtaining a mortgage.
Terms:
Sponsor— Manager of the Lease-Purchase program as a developer (recommended) or as a
subrecipient (often in turnkey approaches)
Lease-Purchaser— Household which enters into a lease agreement with the Sponsor with the
expectation of exercising an option to purchase before the end of the leasing period.
Lease agreement—An agreement by the lease-purchaser to enter into a lease with the sponsor
for the purposes of occupying a property for a specified period during which the Lease-
Purchaser would become mortgage-eligible and prepare to purchase.
Lease option—A reference in the lease agreement to an attached purchase agreement.
b. Purpose for lease-purchase
The purpose of LCDC is to provide for the following:
• To stimulate a weak market in the target area of the Lease-Purchase program
• To provide a community with the opportunity to re-stabilize with families making a long
term commitment to the property
• To allow time for potential buyers to resolve credit issues and become mortgage-ready and
lender qualified
• To provide for a long-term method of working with potential homebuyer families that will
not be ready for homeownership within a short-term window of opportunity
• To provide time or a mechanism during the leasing period to accumulate cash for a down
payment
• To provide the sponsor with a mechanism to maintain or boost production in affordable
housing in the current (overall or local) market downturn
• To provide another affordable housing option as part of a continuum of housing options, i.e.
ownership, rental, shelter.
c. Capacity statement to undertake a lease-purchase program (see Section 2)
The LCDC has assessed its capability to undertake a lease-purchase program and has
determined that it can manage the following:
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 3 of 17
• The board of directors has reviewed and approved program policies
• The organization has no outstanding audit findings for the past three years
• The organization has sufficient lines of credit or financing to obtain funds at a scale
sufficient to cover program development costs and not negatively impact other lines of
business
• The organization has a housing development and management track record that supports
the development and management of a lease-purchase line of business at a production
level that is sustainable
• The organization has developed the necessary partners to manage rental properties and
close units into homeownership
• The organization has the capacity to undertake the necessary functions for a lease-purchase
program either in-house with staff or with secured subcontractors, including:
o Development and project management, including financial packaging and
construction
o Homeownership training and counseling, including credit/budget counseling and
home maintenance
o Applicant screening, selection and underwriting including qualifications used by local
lenders and the secondary market.
o Property management, maintenance staff and subcontracting
o Staff or partner experienced in managing sweat equity (if offered)
o Legal services available to advise potential buyers of responsibilities
o Legal counsel experienced in real estate and tenant law (for agreement)
• The organization has housing product and sufficient inventory that matches target market
in price, subsidy levels, locations, features and amenities
• Lease-purchase program design and components have been determined
• Procedures and forms are in place for intake, verification, tracking and evaluation
• POLICIES
a. Type of lease-purchase
The LCDC's lease-purchase program follows the developer-driven approach, in that LCDC will
acquire sites and (re)develop the site for leasing to a potential buyer directly
(or through a third party). The sponsor will administer the lease-purchase program and manage
the property directly (or through a subcontractor).
b. Lease term
The term of the short-term lease will be for up to 2 years based on terms specified in the lease
and purchase agreement.
c. Qualification criteria
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 4 of 17
Following is a framework for predicting the lease-purchaser's readiness to purchase and be
mortgage-ready within the short term. Exceptions can be made for each criterion but would
have to be justified. Front line underwriters would have to justify and have approval by the
manager to be finalized. Furthermore, the homeownership counselor should offer an
assessment of the candidate's qualifications, steps and ability to achieve ownership including a
subjective sense of candidate's motivation to ownership:
• Standard rental criteria can form the basis for leasing as well as the foundation to build
other criteria. Typical leasing criteria look at income, employment, stability of the income
and family, credit, outstanding debts,judgments, bankruptcies, criminal background check,
household size, caring for property as evidenced by a home visit.
• FICO score—since this is the standard used for qualifying for a mortgage, it can also be used
to provide a parameter for qualifying a lease-purchase candidate. Since Fannie Mae/Freddie
Mac and FHA set the standard for mortgage eligibility, a score below the current standard
can be considered. The lower the score, however, the more time it may take to achieve a
score that meets the standard minimum level. The extent to which the score is lowered may
also be an indicator of risk. For example, if the current standard FICO score is 620 then the
minimum score for a lease-purchaser might be 580. There may also be other factors that
may directly impact their ability to obtain a mortgage in the future- such as a previous
default- even if the credit score is in the high 500's.
• Employment history—any variations from the standard number of years of steady
employment (usually two years) or evidence of steady work in a variety of jobs (for
seasonal, construction workers) need to follow local or the organization's usual
requirements for rental or exceptions for homeownership.
• Debt payment history—an estimate that the lease-purchaser's ability to pay down debts
within the term of the program is within an acceptable back-end ratio for an eventual
mortgage application. For example, if the back-end ratio for a current mortgage is 41%, the
back-end ratio for a lease-purchaser might be set at no more than 55%, anticipating that it
will take no more than the lease period (minus three or more months to allow time for the
lease-purchaser to apply for financing prior to the purchase due date) to lower the 55%to
41%.
• Extinguishing judgments and bankruptcies—estimates that the compliance or extinguishing
period ends in time to apply for a mortgage.
• Criminal background —this is used more often for multi-family rental situations than
ownership, especially single family, detached homes. A policy should be established to
determine eligibility and a consistent approach for exceptions to comply with Fair Housing
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 5 of 17
Laws. Some local jurisdictions require sexual offender information and there are local
ordinances that govern using housing subsidies for convicted offenders.
• Legal status to qualify for the loans or programs
• Rental history— a track record of on-time rent payments for two years
• Savings - cash savings at time of lease of no less than $500 or the minimum down payment
(see below).
• Other—such as, an analysis of bank statement activity and their consistency with
candidate's description of spending pattern or a home visit
d. Down payment requirement
There are two points in time when down payment requirements can be met. The first is on
payment of the initial leasing fee, which is typically the security deposit plus one month rent.
The second is at time of purchase, when the financing organization will determine its own down
payment and cash requirements.
e. Maintenance requirements
Maintenance requirements are described in the lease agreement and generally stipulate that
any repair under a certain amount is the lessee's responsibility and any repair over that amount
is the sponsor's. As an alternative, the agreement may list those repairs that are the lessee's
responsibility and those that are the sponsor's. The list may include items that are regular and
non-capital improvement. Examples are in attachments.
Maintenance training can be included in pre- and post-homeownership training workshops.
Attendance at the workshops can be a program requirement. (The family's attendance and
verification of attendance to a pre-homeownership workshop through a qualified counseling
agency)
f. Plan for becoming mortgage-ready
Areas to monitor progress include resolving credit deficiencies that need to be corrected and/or
savings requirements for down payment, and when these items will be reported.
Reporting required during lease may include:
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 6 of 17
• Progress toward retiring debt and lowering back-end ratio (at minimum, not taking on
further debt)
• Adherence to budget plan
• FICO score repair
• Savings accumulation
• Use if IDA accounts
Reports and verifications are required:
• On a regular monthly or quarterly basis
• At a set time period, such as six months or a year prior to purchase
• To include home inspections and review of goals and progress towards ownership readiness
g. Scattered site property management plan N/A
h. Exit strategy
There are few examples of a lease-purchase program in which every lease-purchaser succeeds
in becoming an owner. The best programs in the country report a success rate between 80%to
as high as 95%. Therefore, if the lease-purchaser does not purchase the home, and does not
voluntarily leave the unit when the lease expires, the ultimate exit remedy must be a
termination or eviction. Furthermore, some lease-purchasers may fail to comply with their
leasing agreement by making payments late or not at all, not maintaining their units, disturbing
other neighbors' peaceful enjoyment of the property, etc. Therefore, the lease-purchase
sponsor must be prepared to terminate a lease. A lease-purchase agreement must be
structured to handle either scenario. (See section 5) For the lease-purchaser who is a solid
tenant yet cannot purchase, the sponsor might consider alternatives:
• Convert unit to permanent rental
• Provide for an extension
• Transfer the participant to other rental property
• Provide an alternative rental unit (non-obligatory [note URA requirements])
Nevertheless, the lease-purchase sponsor should consider financial incentives and support
services and other preventative measures to encourage purchasing.
Sponsor may provide the following financial incentives:
• Housing payment or rent will be set to include all operating expenses and be higher than
projected PITI at sale
• A portion of the monthly rent will be accumulated for a rebate at purchase only if the lease
purchaser closes on the sale
• Lease-purchaser will have access to assume second loans or grants for principle reduction
• Lease-purchaser will be advised on other down payment assistance loans
• Lease-purchaser will be advised on special purchase financing
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 7 of 17
• Sale price is set at current market value upon lease execution
• Sponsor offers allowances for sweat equity (only recommended if sponsor has an ongoing
sweat equity program)
• Sponsor may have IDA's or other program partners such as a public housing authority
Sponsor will provide housing counseling prior to and during the leasing period. (At least eight
hours of homeownership counseling from a HUD-certified agency is required for HUD-funded
programs). Homeownership preparation will include workshop/group education and individual
counseling. Other support may include:
• Budget management counseling
• Debt reduction intervention
• Maintenance training
• Loan Products
• Predatory Lenders
• Secondary Lender Requirements
• Taxes and Insurance Requirements
• LEASE-PURCHASE AGREEMENT
a. Lease
The Sponsor's lease will:
Follow organization's existing tenant lease with purchase option added
Lease purchasers will also be required to sign the URA "MOVE-IN NOTICE (GUIDEFORM NOTICE TO
PROSPECTIVE TENANT)."
b. Purchase option
To determine the option price, the sponsor will:
Sales price will be determined by current appraisal or total development cost, whichever is less.
Operating income and expenses
The lease payment will be sufficient to generate positive cash flow and cover:
• Management expenses, including fees, taxes, insurance, utilities, maintenance
• Rebate savings (This line item may be the last calculated after NOI and DS to capture all
cash flow so as to eliminate program income.)
• Debt service
• And, set at an amount that makes the lease payment higher than the projected PITI.
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 8 of 17
Setting sale price
The projected sale price is set at the current appraisal or Total Development Costs (TDC),
whichever is less. After a determination of affordability levels, additional subsidy in the form of
a silent second will be offered to an affordable mortgage amount, such that the PITI is equal to
or less than 30% of the buyer's income. Subsidy will be based on availability of City funds.
Affordability determination
Target affordability levels will be set for incomes of less than:
• 80% of AMI
Housing or lease payment should be set at close to market rents for the target area and be
sufficient to cover operating expenses. The payment should also be higher than the projected
PITI as an incentive to the lease purchaser to buy.
• PROCEDURES
Intake and screening process
Forms used in sponsor's other screening activities (rental, down payment program, counseling
(such as Counselor Max) will be used to collect information on potential lease-purchase
candidates.
Qualification and underwriting
The following criteria should be considered to collect and analyze information to qualify a lease-
purchase candidate:
• Income
• Cash savings
• Standard rental criteria
• Previous landlord references
• FICO score (credit history)
• Employment history
• Debt payment history
• Calculation of current debt coverage ratio
U.S. Department of Housing and Urban Development
HOME Investment Partnership Program Page 9 of 17
• Extinguishing judgments and bankruptcies
• Criminal background
• Other program qualifications (income limits)
Tracking and evaluation
Counselormax will be used to track reporting information on lease-purchasers (for example,
lease-purchaser reports on maintaining budget goals, lowering back- end ratio, increasing FICO
scores).
Marketing strategy
See marketing plan in Attachments that include:
• List of target populations
• List of messages connected to target populations
• List of advertising methods using messages and target populations
• Schedule of activities and person responsible
Preparation and support
Training and counseling will be provided for the following phases:
• Pre-lease
• During lease and meeting continuous program requirements
• post-purchase
Training content
Realizing the American Dream
Disposition steps
Step by step description of what happens prior to lease purchase and consequences of lease
purchaser not purchasing.
Once property is owned by a lease-purchase sponsor, a qualified lease purchaser is
recruited and a lease signed.
If the 1 year lease is not renewed at any time during the leasing period or not sold at the
end of the leasing period, the house will be offered for sale with the latest income
restrictions and down payment incentives.
If the house does not sell then the cycle above is repeated.
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 10 of 17
Construction standards
Follows HUD guidelines for federal programs (list locally determined construction standards).
In addition, the sponsor adds the following standards (Note: no luxury items - only those that
conform to local markets, e.g. dishwashers, etc. See full list in ATTACHMENTS):
• Floor treatments—wood, carpet, vinyl or ceramic tile
• Kitchen —counter tops, cabinet treatments
• Bathroom —fixtures, etc.
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 11 of 17
SUGGESTED ATTACHMENTS FOR TOOLKIT USER
• Lease and purchase agreement including program guide for lease purchaser and URA
"MOVE-IN NOTICE (GUIDEFORM NOTICE TO PROSPECTIVE TENANT)"
• Development, operating and sales pro forma
• Property management plan
• Marketing plan
• Maintenance policy itemization
• Criminal background policy
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 12 of 17
Lease-purchase readiness assessment checklist
Issues to review
Market
o Affordable income range
o Buyer readiness—
o FICO score
o Credit considerations
o Employment requirements
o Down payment requirements
o Product features—
o #of bedrooms
o size—square footage
o style—attached, semi-, etc.
o new/rehab
o unique amenities
o Absorption rate/Scale of production
o Market features of targeted community—accelerating,
flat/stagnate, or declining
Organizational capacity
o Organizational and fiscal health, i.e., credit worthiness
o Development track record -
o Development types, i.e., sale, rental, other
o Production levels
o Homeownership counseling/ Pre-lease training —
o What types—pre-purchase, post, delinquency
o Method—workshop, one-on-one, distance learning
o Property management—
o Current number of units/properties under
management,
o Clustered in communities (multifamily) or scattered-
site
o Level of maintenance policy
Financing
o Per unit costs/desired price range
o Anticipated sources of subsidy
o Anticipated sources of permanent financing
o Anticipated sources of interim financing
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 13 of 17
Program structure
o Lease-purchase format—
a.) lease-to-purchase
b.) contract for deed (land installment)
c.) transitional loan
o Time period
o Anticipated impact of local tenant/landlord laws
The above chart is designed to assess the potential for a nonprofit housing development
organization to pursue a lease-purchase program. It can also be used to evaluate an existing
program.
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 14 of 17
Guidance on Assigning Responsibility for Repairs and Maintenance
For Short Term Lease Purchase NSP Programs
Policies and Procedures Manual Attachment
TASKS By Landlord at their cost By Tenant at their cost
REPAIRS
Ensure that unit is fit for X
habitation
Comply with all state and local X X
laws
Repairs to damage by Tenant X
Storm or other hazard caused X
damage
Broken appliances- refrigerator, X Tenant responsible for
stove, dishwasher, microwave, warranty service fee and any
clothes washer, dryer tenant damages
Hot water heater X
Air conditioner or heater X
Damaged flooring-carpet or tile X
Normal Wear and Tear- evaluate X
based on estimated lifetime of
appliance or fixture. If tenant
breaks or wears it out before this
time, tenant could be
responsible for pro rated cost to
replace.
MAINTENANCE
Keep home clean and sanitary X
Ensure that unit is fit for X
habitation
Comply with all state and local X X
laws
Maintain utilities including X
deposits and connection fees
Maintain in good working order X
water and sewer lines, septic
system, water quality, water
pressure, roofing, hot water
heaters
Complete and transmit any X
warranty cards, follow up on any
manufacturers warranties
Replace/clean AC filters X
Replace light bulbs X
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 15 of 17
Clean carpet X
Landscaping- mowing, hedge X
trimming and cleanup
Outdoor lighting X- if electrical problem exists X
Ensure that trash storage areas X
are clean and free of debris.
Keep trash in prescribed
containers and follow trash and
recycling schedules and required
disposal regulations
Driveways and Sidewalks kept X
clean and clear
Replace damaged or missing X
mailbox or house numbers
BASIC HOUSEKEEPING
Flooring- regularly(weekly) X
vacuum carpets, clean wood or
vinyl floors with appropriate
cleaners and tools
Kitchen and bath countertops X
should be cleaned with non-
abrasive cleaners weekly or
immediately after spills
Clean range, microwave and X
refrigerator regularly with
appropriate cleaning materials
and tools
Clean carpet spills immediately X
with mild detergent or specific
cleaning products
Interior painted walls should be X
washed with mild products to
remove scuffs, handprints and
dust
If house was built pre-1978 be X X
aware of lead paint hazards and
required actions for chipped or
loose paint. Landlord is
responsible for advising tenant
of the potential presence of lead
paint or other environmental
hazards but tenant must follow
basic safety rules while
occupying the home.
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 16 of 17
ALTERATIONS
Change, add or remove any part Permission required X
of the appliances,fixtures,
mechanical systems, furnishings,
carpeting, light fixtures, outlets
or
equipment in the unit
Paint or install wallpaper or Permission required X
contact paper in the unit
Attach awnings, ceiling fans, Permission required X
window guards or permanent
fixtures
Attach any shelves, screen doors, Permission required
storm doors, or other permanent
improvements in the unit
Install heaters, air conditioners Permission required
or waterbeds in the unit
Place any aerials, antennas, Permission required
satellite dishes, transmitters or
other electrical connections on
the unit
Gas grills and propane tanks are Tenant may use gas grills or
not allowed or barbecues on balconies or within
five feet of structures
Remove or alter existing walls or Prohibited
install new walls, bathrooms, or
enclose porches.
Install new fences, decks or Permission required
patios
Install additional or different Permission required If the Owner so consents,the
locks or gates on any doors or There will be a charge for lost Tenant will provide the Owner
windows keys and for keys not returned. with a key for each new lock or
gate. When this Lease
terminates,the Tenant will
return all keys to the unit to the
Owner.
Trampolines and above ground Prohibited
pools are prohibited
U.S.Department of Housing and Urban Development
HOME Investment Partnership Program Page 17 of 17