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Agenda 04/11/2017 Item #16D 504/11/2017 EXECUTIVE SUMMARY Recommendation to amend the Board's State/Federal Subordination Loan Policy to expand the parameters for subordination requests to aid in continued home affordability. OBJECTIVE: To support the continued affordability of housing by allowing State/Federal housing assistance program recipients the advantage of subordinating their liens with Collier County. CONSIDERATIONS: For homeowners to refinance an existing first mortgage to a lower interest rate, thereby reducing their monthly housing expense, subordinate lenders must either be repaid or agree to remain in a subordinate position. On January 28, 2014, agenda item 16.D.9, the Board approved the current State/Federal Subordination Loan Policy. Under the current Policy, State or Federal grant program loans may only be subordinated to a new first mortgage that offers at least one percent interest rate reduction from the existing first mortgage and does not allow for the inclusion of other existing home financing mortgages/grants in the refinance. If a homeowner is unable to obtain a new loan as a result of the current Subordination Policy, they may choose to sell their home or the home may be lost to default/foreclosure, resulting in a loss to the primary lender and the State/Federal grant program. However, there are a few scenarios where the savings to the homeowner would be equal to or greater than the one percent interest rate reduction currently required. Recently, homeowners and lenders have requested that Collier County review its Subordination Policy and make changes that will be of mutual benefit to the borrower, lender and the County. Revision of the current Subordination Policy will allow for a combination of reductions and alterations that result in significant savings to the homeowner and remain beneficial to the primary lender and the County: a) Currently the Subordination Policy does not include payoff of additional subsidies (USDA, VA, et cetera). The proposed Subordination Policy adds them allowing for paid off as part of a refinance of a first position mortgage. b) Currently, the Subordination Policy does not allow Home Equity Loan or Line of Credits to be paid off. The proposed Subordination Policy adds them. Since they are generally at higher interest rates than first mortgages, the homeowner can achieve significant savings by refinancing the existing first mortgage plus the Home Equity financing into a new first mortgage. However, the Combined Loan to Value (CLTV) of the new financing plus the existing State/Federal financing to be subordinated must be at or below 80% of the new appraised value of the property. c) Currently, the Subordination Policy requires a one percent reduction in interest rate. The proposed Subordination Policy does not limit the consideration to a reduction in interest but it also considers the overall decrease in monthly payments even if the interest rate is not reduced. Expansion of the Subordination Policy will allow more homeowners the opportunity to refinance their existing financing, thereby aiding in continued affordability of their homes. FISCAL IMPACT: The homeowner will bear the recording costs associated with the subordination agreement. Therefore, there is no fiscal impact associated with this item. LEGAL CONSIDERATIONS: This item has been approved for form and legality and requires a majority vote for Board action. -JAB GROWTH MANAGEMENT IMPACT: Approval of this item is consistent with the Growth Management Comprehensive Plan. 16.D.5 Packet Pg. 836 04/11/2017 RECOMMENDATION: To approve the expansion of the Subordination Policy to include the above- referenced recommendations to allow more homeowners the opportunity to refinance their existing loans, thereby aiding in continued affordability of their homes. Prepared By: Donald Luciano, Grant Support Specialist, Community & Human Services ATTACHMENT(S) 1. Subordination Policy 2017 (PDF) 2. Proposed Subordination Policy 2017 (PDF) 16.D.5 Packet Pg. 837 04/11/2017 COLLIER COUNTY Board of County Commissioners Item Number: 16.D.5 Doc ID: 2896 Item Summary: Recommendation to amend the Board's State/Federal Subordination Loan Policy to expand the parameters for subordination requests to aid in continued home affordability. Meeting Date: 04/11/2017 Prepared by: Title: – Community & Human Services Name: Donald Luciano 03/16/2017 8:53 AM Submitted by: Title: Division Director - Cmnty & Human Svc – Public Services Department Name: Kimberley Grant 03/16/2017 8:53 AM Approved By: Review: Community & Human Services Kristi Sonntag Additional Reviewer Completed 03/22/2017 2:56 PM Community & Human Services Leslie Davis Additional Reviewer Completed 03/22/2017 3:33 PM Public Services Department Kimberley Grant Additional Reviewer Completed 03/22/2017 5:59 PM Public Services Department Joshua Hammond Additional Reviewer Completed 03/27/2017 2:06 PM Public Services Department Sean Callahan Additional Reviewer Completed 03/27/2017 2:28 PM Public Services Department Hailey Margarita Alonso Level 1 Division Reviewer Completed 03/28/2017 8:35 AM Grants Erica Robinson Level 2 Grants Review Completed 03/28/2017 9:25 AM Public Services Department Steve Carnell Level 2 Division Administrator Review Completed 03/28/2017 10:48 AM County Attorney's Office Jennifer Belpedio Level 2 Attorney of Record Review Completed 03/28/2017 11:30 AM Office of Management and Budget Valerie Fleming Level 3 OMB Gatekeeper Review Completed 03/28/2017 2:33 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 03/29/2017 8:31 AM Grants Therese Stanley Additional Reviewer Completed 03/30/2017 12:34 PM County Manager's Office Nick Casalanguida Level 4 County Manager Review Completed 04/03/2017 9:13 AM Board of County Commissioners MaryJo Brock Meeting Pending 04/11/2017 9:00 AM 16.D.5 Packet Pg. 838 Revised 03/2017 Collier County Community and Human Services Department STATE/FEDERAL LOAN SUBORDINATION POLICY Requests for subordination must be approved in advance by the Community and Human Services Division (“Division”). We may consider subordinating our loan if the following factors are present:  The proposed transaction is a rate and term refinance (less than $500.00 to borrower at closing); and  The new interest rate is a least one percent less than the current interest rate; or any combination of Interest Rate reduction plus Mortgage Insurance reduction that would be the equivalent of a one percent interest rate reduction; and  The new principal and interest payment is lower than the current total payment(s) as evidenced by the Loan Application or Loan Estimate; or if the new monthly payment is increased due to a reduction to the term of the loan, the Division will determine if the new payment is reasonable and beneficial to the client; and  The proposed transaction may include the current first mortgage plus other purchase related grants and/or financing (ie, USDA Subsidy, etc.) and  The proposed transaction may also include post-purchase Home Equity Loans or Home Equity Lines of Credit, provided the Combined Loan-To-Value (CLTV) ratio of the new mortgage plus the SHIP Second Mortgage does not exceed 80% of the current appraised value for the subject property. In this instance, the one percent reduction in interest rate may be waived if the reduction in total payments is beneficial to the client as determined by the Division; and  Closing costs are reasonable as determined by the Division; and  The proposed transaction does not include a prepayment penalty.  Property being refinanced must be the borrower’s principal residence. The following documents must be submitted to our office in order to process a subordination request: 1. Subordination Request form (attached). 2. Signed and executed Loan Estimate; and 3. Signed and executed mortgage/loan application; and 4. Preliminary Closing Disclosures; and 5. Copy of title commitment 6. Copy of Appraisal (if applicable) Please allow 20 business days for processing from the date the request is submitted to our office. If approved, the Division will notify the lender and title company to prepare the Subordination Agreement. If we are unable to approve the request, a payoff letter will be issued. EMAIL THE SUBORDINATION REQUEST FORM ALONG WITH THE DOCUMENTS 2-6 TO: CollierCountySHIP@colliergov.net 16.D.5.a Packet Pg. 839 Attachment: Subordination Policy 2017 (2896 : SHIP Subordination Policy) Revised 03/2017 For additional questions contact: Donald Luciano, Grant Support Specialist Phone: 239-252-2509 Email: DonaldLuciano@colliergov.net 16.D.5.a Packet Pg. 840 Attachment: Subordination Policy 2017 (2896 : SHIP Subordination Policy) Revised 03/2017 Subordination Request Form To be completed by the Financial Institution processing refinance on behalf of clients listed below Borrower (s) name: ______________________________________________________________ Borrower (s) address: ______________________________________________________________ Financial Institution: ________________________________________________________________________ Address: __________________________________________________________________________________ Email: _______________________________________________Phone: _______________________________ Current Mortgage Information Principal Balance: ______________________ Interest Rate: ___________________ Monthly Payment (PITI): _______________________ Loan Term: ___________________ New Mortgage Information Loan Amount: _____________________ Interest Rate: _____________________ Monthly Payment (PITI): _____________________ Loan Term: _____________________ Closing Agent/Title Company Information Name: ____________________________________________ Contact Person: _________________________ Phone: _____________________ Email Address: _____________________________________ I certify that the above information is correct. I certify that there will be no cash out to the borrower, and no other unsecured debt will be paid off (i.e., credit cards, automobile loans, etc.). I understand that the subordination document prepared by Collier County will be invalid if that is the case. _________________________________ _________________________________ ____________ Lender/Broker Signature Lender/ Broker Name Printed Date ___________________________________________ _________________________________ Email address Phone 16.D.5.a Packet Pg. 841 Attachment: Subordination Policy 2017 (2896 : SHIP Subordination Policy) Revised 09/2016 Collier County Community and Human Services Department STATE/FEDERAL LOAN SUBORDINATION POLICY Requests for subordination must be approved in advance by the Community and Human Services Division (“Division”). We may consider subordinating our loan if the following factors are present:  The proposed transaction is a rate and term refinance (less than $500.00 to borrower at closing); and  The new interest rate is a least one percent less than the current interest rate; or any combination of Interest Rate reduction plus Mortgage Insurance reduction that would be the equivalent of a one percent interest rate reduction; and  The new principal and interest payment is lower than the current total payment(s) as evidenced by the closing disclosure Loan Application or Loan Estimate; or if the new monthly payment is increased due to a reduction to the term of the loan, the Division will determine if the new payment is reasonable and beneficial to the client; and  The proposed transaction only includes the current first mortgage payoff and reasonable closing costs; The proposed transaction may include the current first mortgage plus other purchase related grants and/or financing (ie, USDA Subsidy, etc.) and  The proposed transaction may also include post-purchase Home Equity Loans or Home Equity Lines of Credit, provided the Combined Loan-To-Value (CLTV) ratio of the new mortgage plus the SHIP Second Mortgage does not exceed 80% of the current appraised value for the subject property. In this instance, the one percent reduction in interest rate may be waived if the reduction in total payments is beneficial to the client as determined by the Division; and  Closing costs are reasonable as determined by the Division; and  The proposed transaction does not include a prepayment penalty.  Property being refinanced must be the borrower’s principal residence. The following documents must be submitted to our office in order to process a subordination request: 1. Subordination Request form (attached). 2. Signed and executed Loan Estimate and Truth in Lending statement; and 3. Signed and executed mortgage/loan application; and 4. Preliminary Closing Disclosures; and 5. Copy of title commitment 6. Copy of Appraisal (if applicable) Please allow 20 business days for processing from the date the request is submitted to our office. If approved, the Division will notify the lender and title company to prepare the Subordination Agreement. If we are unable to approve the request, a payoff letter will be issued. EMAIL THE SUBORDINATION REQUEST FORM ALONG WIT H THE DOCUMENTS 2-56 TO: 16.D.5.b Packet Pg. 842 Attachment: Proposed Subordination Policy 2017 (2896 : SHIP Subordination Policy) Revised 09/2016 CollierCountySHIP@colliergov.net For additional questions contact: Donald Luciano, Grant Support Specialist Phone: 239-252-2509 Email: DonaldLuciano@colliergov.net 16.D.5.b Packet Pg. 843 Attachment: Proposed Subordination Policy 2017 (2896 : SHIP Subordination Policy) Revised 09/2016 Subordination Request Form To be completed by the Financial Institution processing refinance on behalf of clients listed below Borrower (s) name: ______________________________________________________________ Borrower (s) address: ______________________________________________________________ Financial Institution: ________________________________________________________________________ Address: __________________________________________________________________________________ Email: _______________________________________________Phone: _______________________________ Current Mortgage Information Principal Balance: ______________________ Interest Rate: ___________________ Monthly Payment (PITI): _______________________ Loan Term: ___________________ New Mortgage Information Loan Amount: _____________________ Interest Rate: _____________________ Monthly Payment (PITI): _____________________ Loan Term: _____________________ Closing Agent/Title Company Information Name: ____________________________________________ Contact Person: _________________________ Phone: _____________________ Email Address: _____________________________________ I certify that the above information is correct. I certify that there will be no cash out to the borrower, and no other unsecured debt will be paid off (i.e., credit cards, automobile loans, etc.). I understand that the subordination document prepared by Collier County will be invalid if that is the case. _________________________________ _________________________________ ____________ Lender/Broker Signature Lender/ Broker Name Printed Date ___________________________________________ _________________________________ Email address Phone 16.D.5.b Packet Pg. 844 Attachment: Proposed Subordination Policy 2017 (2896 : SHIP Subordination Policy)