HomeMy WebLinkAboutR-98-0588J-98-566
05/15/98
RESOLUTION NO. 9 8 -
A RESOLUTION, WITH ATTACHMENT, APPROVIN
CITY OF MIAMI'S HOUSING LOAN COL ION
PROCEDURES AND POLICIES IN CONNECTION H T
CITY'S HOUSING LOAN PORTFOLIO CONSISTING -
INTEREST LOANS WHICH HAVE BE R D
THROUGH THE CITY' S CDBG-FUNDE
AND MULTI -FAMILY REHABILITATI0 AN PR
RENTAL REHABILITATION GRAN OGRAM, ME
INVESTMENT PARTNERSHIP G AND ATE
HOUSING INITIATIVES PAR S P ;
AUTHORIZING AND DIRECTING T Y Y TO
COORDINATE A LOAN CE WITH
THE DEPARTMENT F VELOPMENT
WHICH WILL INCL ND CERTIFIED LETTERS TO
ALL DELINQUENT DE S TO AGGRESSIVELY
PURSUE ALL L TI TIONS AGAINST ALL
LOAN ACCO S WHICH A DEFAULT IN EXCESS OF
120 DAYS; THORIZ DIRECTING THE CITY
ATTORNEY PROVIDE CITY COMMISSION WITH
QU TS OF ALL DEPARTMENT OF
CO NT DELINQUENT LOANS
&D,LN;4ATTORNEY
' S OFFICE.
dated March 26,
's District Office of the Inspector General ("OIG'), cited several
relative to the City's housing loan portfolio; and
WHEREAS, in an effort to address the OIG's concerns with respect to the collection
practice regarding the defaulted loans in the City's loan portfolio, it is necessary that the City
establish a loan collection procedure; and
WHEREAS, it is recommended by the Economic Development and
Committee that the City Attorney's Office coordinate a collection procedure
of Community Development which will include sending certified
WHEREAS, it is further recommended that the
debtors which are in default in excess of 120 days,
assets, by initiating foreclosure actions, enforcing the a&nenIqqWts, pursuing personal
guarantees, and through the engagement
WHEREAS, it is recommended'I%Lhe M&mic Development and Transportation
Committee that the City AttoAry provide the Commission with quarterly reports of all
Department of Community DelLopment delin'ent loans referred to the City Attorney's Office;
OF MIAMI,
VED BY THE COMMISSION OF THE CITY
and findings contained in the Preamble to this Resolution are
reference thereto and incorporated herein as if fully set forth in this Section.
City Commission hereby adopts the attached Housing Loan Collection
which delineates the roles and responsibilities of the Department of
Development and the City Attorney's Office, in carrying out the loan collection
with respect to the City's housing loan portfolio.
2
98- 588
Section 3. The City Attorney is hereby authorized and directed to coordinate the
collection procedure with the Department of Community Development, which will include
sending certified letters to all delinquent debtors.
Section 4. The City Attorney is further authorized and directed to pro City
Commission with quarterly status reports of all Department of
delinquent loans referred to the City Attorney's Office.
Section 5. This Resolution shall become effective immedi,a
PASSED AND ADOPTED this 9th
in atcordance with Miami
phis legislation by
becomes effective with
regarding sgjgjWut I
WALTER J. FOEMAN,
CITY CLERK'S OFFI-C
DEVELOPMENT
, DIRECTOR
LAITY DEVELOPMENT
ILL MtIY
yor e8 no nd6cI
a e approve-1 of
provided, said iegi<, at c 7
the date of Commissicn ,.. n
oeman, City Clerk
3 98- 588
PREPARED AND APPROVED BY:
- - zk,,
LIND L Y SON
ASSISTANT CITY ATTORNEY
ri
CITY OF MIAMI
INCO16 9BATED
Department of Community
Development/Housing Division
Housing Loans
Collection Procedures and Policies
98- 588
DEPARTMENT OF COMMUNITY DEVELOPMENT/HOUSING DIVISION
HOUSING LOAN(S) COLLECTION PROCEDURES AND POLICIES
In response to the shortcomings and deficiencies which were identified by the District Inspector
General for Audit in the audit report, dated March 26, 1998, the Department of Community
Development will be charged with the sole responsibility of performing the collection activities
associated with the management of various housing loans which have been provided through the
CDBG-funded Single -Family and Multi -Family Rehabilitation Loan Programs, HOME Program,
State Housing Initiatives Partnership Program (SHIP) and any other housing programs which are
administered by the Department. As part of the City's Corrective Action Plan and the
Departmental Reorganization Plan, an in-house Finance Unit will be charged with the day-to-day
responsibility of collections and oversight of the City's housing loan portfolio. This course of
action will eliminate the lack of communications and misunderstandings which may have
occurred in the past, relative to the roles of other City departments, namely, the Finance and Law
departments.
The Department of Community Development, through its Finance Unit will be responsible for
receiving all loan payments submitted by the borrowers and the initial booking of the payments
received from each borrower. Through the implementation of a mortgage tracking system, the
Finance Unit will be able to determine whether a borrower is current, 30 days, 60 days and 12b _
days past due on his/her loan. Appropriate late notices will be forwarded to the borrower, along
with follow-up telephone calls to the borrower(s) to bring the loan current and/or to establish the
problem area associated with the delinquent account.
After a loan is in default for ninety (90) days, the Department of Community Development will
be responsible for notifying the City Attorney's Office to send certified delinquency letters to all
borrowers who are delinquent on their loan account. If the borrower contacts the Department of
Community Development and/or the City Attorney's Office, and is desirous of correcting the
delinquency, no further legal action will be pursued by the City.
After a loan is in default for 120 days, the Department of Community Development in
conjunction with the City Attorney's Office will continue through appropriate written
correspondences and telephone calls, attempt to notify the borrower(s) to bring his/her delinquent
loan account current or enter into a stipulation of settlement agreement with the City Attorney's
Office. If there is no response from the borrower(s), the Department of Community
Development will be responsible for referring the matter to the City's Attorney's Office for
foreclosure action.
Any multi -family loan(s) that is delinquent in excess of 120 days, and the borrower(s) has
responded to the appropriate notices forwarded by the Department of Community Development
and/or City Attorney's Office and requires a restructuring of the loan or stipulation of settlement
98- 588
agreement, will require that the Department of Community Development submit said request to
the City's Housing Loan Committee for approval/disapproval. Such action will also require
approval from the Miami City Commission and U.S. HUD. Once approval has been received
from the City Commission and U.S. HUD, all loan restructuring plans must also receive final
approval from the State Oversight Review Board.
The Department of Community Development will be responsible for performing the appropriate
project analysis to determine whether foreclosure is the proper remedy. This project analysis
will take certain factors into consideration which include:
1. The assessed value of the property.
2. The amount of superior lien holders (i.e., mortgages, tax certificates).
3. The condition of the property and liability associated with same.
4. The cost of maintaining the property.
5. The marketability of the property.
6. The loss in tax revenue once the property becomes exempt.
Should the Department of Community Development decide that foreclosure is economically
feasible, a Foreclosure Referral will be executed and forwarded to the Office of Asset
Management and the City Manager's Office for approval/disapproval. Once approval has been
secured from the City Manager's Office, the completed foreclosure referral form will be
forwarded to the City Attorney's Office for legal action against the borrower(s). In the event that
the Department of Community Development makes a determination that it is not economically
feasible to foreclose and take title to the property, the Department of Community Development
will refer the case to the City Attorney's Office for other legal remedies which may include a suit
on the promissory note and/or personal guarantees. In addition, in those instances whereby the.
City has utilized every available legal remedy to address a defaulted loan account, the City plans
to utilize the services of a private debt collection agency to pursue all funds which remain
outstanding.
The Department of Community Development will be responsible for working with the City
Attorney's Office in tracking the status of the foreclosure case from the filing of the complaint,
summary judgment, foreclosure sale, temporary management of the property(ies) by a private
management firm, and disposition to a new property owner. A new position, Default/Loan
Workout Specialist will be assigned the responsibilities of monitoring default loans, make
recommendations with regard to payment stipulations and loan workout agreements.
In addition to the foreclosure actions, the City Attorney's Office will be charged with pursuing
all legal remedies to cure loan defaults, to safeguard the City's assets and to recover losses by the
City. These remedies shall include collecting rents through the assignment of rent agreements,
and pursuing personal guarantees to recover losses. Moreover, through the utilization of the
City's newly established Housing Loan Recovery Fund, the City will make every attempt to
satisfy any superior lien holders which may be ahead of the City's loan, in order to safeguard the
City's asset when possible.
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The City Attorney's Office will be responsible for the preparation of a quarterly status report on
the status of all legal actions against all borrower(s) for dissemination to the appropriate
Department, in addition to providing a quarterly status report to the City Commission regarding
the status of each foreclosure case.
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CITY OF MIAMI, FLORIDA
INTER -OFFICE MEMORANDUM 2 71*
TO : The Honorable Mayor, Joe Carollo and DATE May 11, 1998 FILE
Members of the City Commission
SUBJECT : Resolution Establishing the City's
Housing Loan Collection Policies
--- FROM 0 H. Warshaw REFERENCES and Procedures
City Manager ENCLOSURES: City Commission Agenda Item
May 26, 1998
RECOMMENDATION:
It is respectfully recommended that the City Commission adopt the attached resolution, establishing
the City's Housing Loan Collection Procedures and Policies. The attached document delineates the
roles and responsibilities of the Department of Community Development and the Law Department
in carrying out the overall loan collection process to substantially safeguard the City's housing loan
portfolio.
BACKGROUND:
In March of 1998, the U.S. Department of Housing and Urban Development's District Office of the
Inspector General, in its audit report dated March 26, 1998, cited weaknesses in the City's loan
collection procedures, and recommended a strategy to aggressively pursue legal actions against all
delinquent loan accounts in the City's housing loan portfolio. As a part of the City's corrective
action plan relative to this finding, the City Administration is recommending the adoption of the
attached Housing Loan Collection Procedures and Policies. The attached plan delineates the roles
and responsibilities of the Department of Community Development and the Law Department, in
carrying out the overall loan collection process, to include aggressively pursuing all delinquent
debtors through legal actions to safeguard the City's assets.
JGP/CMC/GCW/JBH:vh
c: Gwendolyn C. Warren, Director
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