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4350.1 Re-write: Subordinate Debt, LIHTC and Subsidy Layering, and Commercial and Ground Leases

HUD has released the next three draft chapters from its 4350.1 Asset Management Handbook rewrite. They are:

· Chapter 3.2 Commercial and Ground Leases;

· Chapter 8.1 Subordinate Debt; and

· Chapter 12.10 Tax Credits and Subsidy Layering.

According to HUD, these draft documents are:

“…being sent to you for feedback on content, clarity of instructions, and user friendliness.  The final version will be edited to ensure consistency among all chapters in format, tone, voice, and style. Whether a revised version of an existing chapter or a new chapter, the draft chapter may contain policies and procedures that differ from those currently in effect. Until this chapter has been approved and published by the Department, the policies and procedures currently in effect remain in effect.

The attached draft ‘4350.1 Re-write Guide to Units, Chapters,…’ shows that the revised Handbook will be organized into numbered Units.  Chapters related to each Unit are numbered sequentially.  Each chapter begins with a Table of Contents.  All chapters for a Unit are not attached for comment at this time.  You will receive the remaining chapters as we complete them over the coming weeks.


We request that you use the attached ‘Comments Form’ and provide only one set of comments per company.  Please submit your comments to the Office of Asset Management at with the chapter title on the subject line by Monday, March 17th.”

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