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					C I T Y OF B R OC K T ON , M A SSA C H USE T T S NSP S UB ST A NT I A L A M E NDM E NT
Jurisdiction(s): _City of Brockton, Massachusetts, Building a Better Brockton, Inc._____ (identify lead entity in case of joint agreements) Jurisdiction Web Address: www.brockton.ma.us (URL where NSP Substantial Amendment materials are posted) A. AREAS OF GREATEST NEED Provide summary needs data identifying the geographic areas of greatest need in the grantee’s jurisdiction. Note: An NSP substantial amendment must include the needs of the entire jurisdiction(s) covered by the program; states must include the needs of communities receiving their own NSP allocation. To include the needs of an entitlement community, the State may either incorporate an entitlement jurisdiction’s consolidated plan and NSP needs by reference and hyperlink on the Internet, or state the needs for that jurisdiction in the State’s own plan. The lead entity for a joint program may likewise incorporate the consolidated plan and needs of other participating entitlement jurisdictions’ consolidated plans by reference and hyperlink or state the needs for each jurisdiction in the lead entity’s own plan. HUD has developed a foreclosure and abandonment risk score to assist grantees in targeting the areas of greatest need within their jurisdictions. Grantees may wish to consult this data [LINK – to HUD USER data], in developing this section of the Substantial Amendment. Response: Brockton recognized the community’s growing foreclosure problem and provided for activities to address the related housing and community needs in its Five Year Plan for 2008-2012. However, it has become very clear that additional funds and a broader variety of stabilization activities will be needed to positively impact a problem that has gotten considerably worse over the past several months, and is likely to continue worsening over the months ahead. In an effort to prevent the growing number of foreclosures in Brockton from decreasing the supply of affordable housing and from destabilizing neighborhoods Revised 1 NSP Contact Person: Donald Walsh Address: 50 School Street, Brockton, MA 02301 Telephone: 508-586-0021 Fax: 508-587-1340 Email: dwalsh@brockton21.com

through the presence of deteriorating vacant homes, the City of Brockton will work closely with the Brockton Housing Partnership (a collaboration of financial local institutions, public agencies and community-based non-profits) and other parties to rescue foreclosed properties and return them to productive use and occupancy by low- and moderate-income families. CDBG and other funds will be used to acquire and rehabilitate foreclosed homes which will then be repaired and re-sold to lowand moderate-income families under existing First Time Home Buyer programs. The City of Brockton will also provide HOME funds for Down Payment Assistance for properly qualified and trained low- and moderate-income First Time Home Buyers. The City of Brockton will coordinate its efforts with other local and regional agencies and programs. At least a portion of the rehabilitation funds advanced will be in the form of deferred payment loans with annual declining balances and recapture provisions secured by lien. The homes sold will carry conventional mortgages, likely soft-second mortgages from the Massachusetts Housing Partnership and the aforementioned down payment assistance (ultimately forgiven) and rehab loans. Acquisition funds advanced will be repaid to the City of Brockton when conventional mortgages/Soft Second mortgages are placed. The City will use the repayment proceeds to acquire additional properties and start the process again. Additionally, the City of Brockton proposes to use Neighborhood Stabilization Program (NSP) funds for the full range of allowable activities, including, but not limited to establishing financing mechanisms for purchase and redevelopment of foreclosed homes and residential properties; purchasing and rehabilitating homes and residential properties abandoned or foreclosed; establishing a land bank for foreclosed homes; demolishing blighted structures; and/or redeveloping demolished or vacant properties. NSP funds would be supplemented with HOME, CDBG and other public and private funds to the greatest extent possible. Supply of Housing The chart below shows Brockton’s current housing supply and occupancy statistics, updated with the 2007 American Community Survey (ACS) statistics. It is notable that there has been a significant increase in vacancies, especially rental vacancies, since the 2006 American Community Survey, a disturbing trend that has worsened since the 3.34% vacancy rate reported in the 2000 U.S. Census. 2006 ACS (for comparison) 94,634 34,160 36,112 34,160 19,499 14,661 1,952 5.41%

2007 ACS 95,157 Population 32,523 Households 35,386 Housing Units 32,523 Occupied owner-occupied 19,153 renter-occupied 13,370 2,863 Vacant 8.09% Vacancy rate

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The Foreclosure Situation in Brockton In Massachusetts, Brockton is second only to Springfield -- and possibly Lawrence, depending on the criteria -- in the severity of its current and predicted foreclosure situation. At the end of October 2008, 2,194 properties (projected to encompass 4,000 units) were at some point in the foreclosure process from petition and public notice of intent to foreclose to foreclosure auction to REO (real estate owned, meaning the bank or other entity had purchased the property at the auction). Using data from the Mortgage Bankers Association National Delinquency Survey as of June 2008, HUD has calculated the approximate number of foreclosure starts for all of 2007 and the first six months of 2008 in Brockton to be 2,294 properties, meaning that over an 18-month period, 9% of all mortgaged properties in Brockton were at some point in the foreclosure process. According to data from the Federal Reserve Board1, Brockton is among the highest ranking communities in Massachusetts for number of foreclosures (and anticipated foreclosures) per total housing units. Brockton also has extraordinarily high numbers of subprime (high cost, high APR) and “Alt-A” (high cost, low documentation, often with unusual features) first mortgages that were issued in recent years – over 10.41% of Brockton’s total housing units are secured by subprime loans and an additional 2.64% are secured with Alt-A loans. These subprime and Alt-A mortgages are considered to be especially likely to be defaulted on and the properties are highly likely to be foreclosed on in the next few years as the borrowers’ interest rates increase from the low introductory rates to higher rates and borrowers are unable to refinance due to falling home values, limited property equity and poor personal credit. As of December 2007, Brockton had approximately 3,760 subprime and 954 Alt-A mortgages. Of these, 3,561 subprime and 792 Alt-A loans were on owner-occupied properties. Further, 2,683 subprime and 396 Alt-A mortgages were adjustable rate loans – it is believed that the adjustable rate loans are most likely to become problematic when their interest rates increase or reset. As of December 2007, approximately 1,863 of the owner-occupied subprime loans (52.31%) were 30+ days late, and of these, 811 properties (22.78%) were in foreclosure or already foreclosed on. Similarly, approximately 212 of the owneroccupied Alt-A loans (26.73%) were 30+ days late, and of these 83 properties (10.51%) were in foreclosure or already foreclosed on. The data that HUD is using to analyze the foreclosure situation and prioritize communities for assistance under the Neighborhood Stabilization Program reinforce the U.S. Department of Census and the Federal Reserve Board data – the total number of high cost loans issued between 2004 and 2006 in Brockton was 6,063 or 37.7% of all mortgages issued in Brockton during that time period.
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Calculations using Federal Reserve Board estimates based on data from First American LoanPerformance, December 2007.

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The additional indicators that HUD and others are considering in risk assessment: June 2008 unemployment, price changes from peak (in any previous June from 2000 on) and 90-day vacancies (from the U.S. Postal Service), all point to a significant problem in Brockton. At 6.8% unemployment is higher than the national and regional averages, combined with a 5.1% decrease in housing prices from peak and a 90-day vacancy rate of 3.1%, which follows the on-going vacancy rate increases since the 2000 Census. The various data sources and assessment tools agree – Brockton is among the top two or three communities in Massachusetts in the severity of its foreclosure problem. As a result, the City will need access to every available source of funding as well as the collaboration, support and assistance of all local and regional housing providers to begin addressing the problem. Target Area Using HUD’s Foreclosure and Abandonment Risk Scoring System, areas with an index score of ten (10) are at greatest risk and those with an index score of one (1) are at least risk for foreclosure and abandonment during the next 18 months. According to data from PolicyMap and others, nearly all of Brockton’s Census Tracts are at high risk for foreclosure and abandonment according to HUD’s scoring system, with more than half of Brockton’s Census Tracts rating a risk score of either nine (9) or ten (10). Of the 93 Census Blocks in Brockton’s 21 Census Tracts, only three (3) Census Blocks are ineligible due to slightly higher incomes in those areas, and only ten (10) Census Blocks have risk scores of less than seven (7). Estimated foreclosure and abandonment risk score from HUD 7 9 9 10 8 8 6 6 9 10 10 10 8 8 9

Census Tract

510100 510200 510300 510400 510501 510502 510503 510600 510700 510800 510900 511000 511100 511200 511301

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511302 511400 511500 511600 511701 511702

7 10 10 9 8 6

Brockton has six (6) Census Tracts with the highest score of ten (10); five (5) tracts with a score of nine (9); five (5) tracts with a score of eight (8); two (2) tracts with a score of seven (7); and three (3) tracts with a score of six (6). The following maps from the old Colony Planning Council and PolicyMap and Old Colony Planning Council demonstrate that some of the areas with the highest risk scores correspond with the City’s center, delineating a natural target area with the highest risk and the highest visibility, density and potential impact for positive change. The City will target this area (Census Tracts 510400, 510800, 510900, 511400 and 511500 – highlighted in yellow above), but will also explore and pursue opportunities in other Census Tracts with high risk scores and characteristics as opportunity and funding permit. Recent foreclosure data from Banker & Tradesman show many different lenders with properties at some point in the foreclosure process in Brockton. Currently Deutsch Bank National Trust Company and US Bank have very high numbers of properties at some point in the foreclosure process in Brockton, and hopefully they and other lenders will be willing to work with the City and its partners on some type of acquisition strategy that makes sense for the community. While it will be difficult to acquire properties because of the various out-of-state and even foreign investors, the City and its partners will have many opportunities to acquire properties within the proposed Target Area, and potentially beyond the Target Area.

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B. DISTRIBUTION AND USES OF FUNDS Provide a narrative describing how the distribution and uses of the grantee’s NSP funds will meet the requirements of Section 2301(c)(2) of HERA that funds be distributed to the areas of greatest need, including those with the greatest percentage of home foreclosures, with the highest percentage of homes financed by a subprime mortgage related loan, and identified by the grantee as likely to face a significant rise in the rate of home foreclosures. Note: The grantee’s narrative must address these three stipulated need categories in the NSP statute, but the grantee may also consider other need categories. Response: The City of Brockton will make NSP funds available to public and quasi-public instrumentalities and to local non-profit organizations and public service providers to concurrently carry out a variety of activities so as to best address pressing local needs stemming from high percentages of foreclosures, high percentages of subprime mortgage activities and to help stabilize those areas projected as facing substantial increases in the rate of foreclosure. The City of Brockton, acting through its sub-recipient, Building a Better Brockton, Inc. is issuing a Request for Proposals (RFP) to solicit proposals to deliver the services described more fully in the “Activity” descriptions to follow. The range of activities and funding to be provided will include support of existing programs operated by public, quasi-public and nonprofit agencies, and private development interests as well as new initiatives created specifically in response to this crisis. The following chart entitled: Brockton, MA Neighborhood Stabilization Program - Proposed Uses indicates the mechanisms for distributing NSP funds and the initial allocation of funds to those activities. Brockton will evaluate the progress of each of the identified activity areas every six months and may re-allocate NSP funds among the activity areas and among the providers if Brockton determines that insufficient progress has been made in accomplishing the stated goals and commitment of funds in compliance with NSP requirements and as detailed in proposals selected pursuant to Brockton’ s RFP process. Brockton may commit additional funds to these activities should it be awarded additional NSP funds for those purposes by the Commonwealth of Massachusetts under its NSP allocation. Brockton may also identify additional activities, consistent with the needs analysis and eligible uses, and may amend its NSP to incorporate such activities if funds can be obligated within the time required. Brockton’s NSP funds provided to local agencies must be targeted to the areas of greatest need as identified above. On a case by case basis, these agencies may be permitted to utilize limited NSP resources to areas (block groups) other than those identified in DHCD’s need analysis. Verifiable evidence of need in those areas must be provided in support of such requests and measurable impacts must still result for the originally identified block group(s).

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Brockton, MA - Neighborhood Stabilization Program Uses of Funds
Activity Acquisition, Homebuyer Assistance, Soft Seconds, Rehab Loans for IncomeEligible Households; Rehab. Grants; support of Receivership; Strategic Demolition/redevelopment Alternative Finance Mechanisms; loan pool/loan guarantees NSP Funding Eligibility (A), (B), (D), (E) Funding Vehicle Eligible Locations: Targeted high need census block groups in Brockton, particularly within the city core Targeted high need census block groups in Brockton, particularly within the city core e.g. staffing, administration, technical assistance and planning

$1,537,700 Building A Better Brockton, Inc. - subgrantees

(A), (B), (D), (E)

$400,000

Building A Better Brockton, Inc. – subgrantees

Administration and Technical Assistance

$ 215,279

Building A Better Brockton; Inc.

NSP Eligible Uses: (A) Establish financing mechanisms for purchase and redevelopment of foreclosed upon homes and residential properties, including such mechanisms as soft-seconds, loan loss reserves, and shared-equity loans for low- and moderate-income homebuyers; (B) Purchase and rehabilitate homes and residential properties that have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties; (C) Establish land banks for homes that have been foreclosed upon; (D) Demolish blighted structures; and (E) Redevelop demolished or vacant properties

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C. DEFINITIONS AND DESCRIPTIONS (1) Definition of “blighted structure” in context of state or local law. Response: Massachusetts General Laws (MGL) 121A and 121B provide guidance regarding the definition of blighted structures. Consistent with those statutes, the City of Brockton defines blighted structures for purposes of NSP as a building that by reasonable determination displays physical deterioration rendering the building unfit for human habitation, obsolete or in need of major maintenance or repair or lacks ventilation, light or sanitation facilities contributing to a condition that is detrimental to safety, health or morals.

(2) Definition of “affordable rents.” Note: Grantees may use the definition they have adopted for their CDBG program but should review their existing definition to ensure compliance with NSP program –specific requirements such as continued affordability. Response: “Affordable” means that (1) maximum rents, less an allowance for tenant-paid utilities, will not exceed the lesser of (a) “High Home Rent”, thirty percent (30%) of the monthly income of a household earning sixty-five percent (65%) of area median income adjusted for the number of bedrooms in the unit, or (b) the HUD Fair Market Rent; (2) selling prices in ownership projects will not exceed the guidelines in effect for the Massachusetts Department of Housing and Community Development’s Local Initiative Program.

(3) Describe how the grantee will ensure continued affordability for NSP assisted housing. Response: NSP-assisted housing must meet the affordability requirements for not less than the applicable period specified in the chart below, beginning upon project completion. The affordability requirements apply without regard to the term of any loan or mortgage or the transfer of ownership. They must be imposed by deed restrictions, covenants running with the land, or other mechanisms approved by Building a Better Brockton, Inc and must be consistent with mechanisms approved by the Massachusetts Department of Housing and Community Development under its NSP plan.

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Rental Housing Activity Rehabilitation or acquisition of existing housing per unit amount of NSP funds: Under $15,000 $15,000 to $20,000* Over $40,000 or rehabilitation involving refinancing New Construction or acquisition of newly constructed housing

Minimum period of affordability in years 5

10 15 20

Minimum period of affordability in years Homeownership assistance NSP amount per-unit Under $15,000 5 $15,000 to $20,000* 10 Over $40,000 15 * Building a Better Brockton, Inc. may increase its cap on per unit funding to $40,000 on a case by case basis for projects sub-recipients when adequate justification of rehabilitation costs or homeownership assistance need is provided by sub-grantees.

(4) Describe housing rehabilitation standards that will apply to NSP assisted activities. Response: NSP-funded housing rehabilitation must bring substandard housing units into compliance with Article II of the Massachusetts Sanitary Code, which sets minimum habitability standards for residential dwellings and all properties being rehabilitated must be abated of lead paint hazards. Both rehabilitation and new construction housing projects will also be required to use Energy Star building performance standards. Those standards are found at www.energystar.gov. Contracted Housing Rehabilitation Specialists will undertake inspections, prepare work write-ups, and ultimately inspect improved units and authorize payments. Housing Rehabilitation Specialists will interact closely with municipal code enforcement personnel.

D. LOW INCOME TARGETING Identify the estimated amount of funds appropriated or otherwise made available under the NSP to be used to purchase and redevelop abandoned or foreclosed upon homes or residential properties for housing individuals or families whose incomes do not exceed 50 percent of area median income: $550,000-600,000. Note: At least 25% of funds must be used for housing individuals and families whose incomes do not exceed 50 percent of area median income.

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Response: In keeping with NSP requirements, at least 25% of NSP funds will be allocated to benefit populations below 50% of medium income. Though this could conceivably be in the form of Homebuyer Assistance, Purchase/ Rehabilitation Assistance, Soft Second loans, and Rehabilitation Grants for low income buyers, it is more likely that low income renters will benefit from the various activities undertaken by Building a Better Brockton, Inc. and its NSP sub-grantees using these mechanisms to rescue, rehabilitate and preserve two, three, and four unit properties.

E. ACQUISITIONS & RELOCATION
Indicate whether grantee intends to demolish or convert any low- and moderate-income dwelling units (i.e., ≤ 80% of area median income). If so, include: • The number of low- and moderate-income dwelling units—i.e., ≤ 80% of area median income—reasonably expected to be demolished or converted as a direct result of NSP-assisted activities. • The number of NSP affordable housing units made available to low- , moderate-, and middle-income households—i.e., ≤ 120% of area median income— reasonably expected to be produced by activity and income level as provided for in DRGR, by each NSP activity providing such housing (including a proposed time schedule for commencement and completion).The number of dwelling units reasonably expected to be made available for households whose income does not exceed 50 percent of area median income.

Response: The City of Brockton may undertake strategic demolition of blighted properties in the target areas on an as needed basis. Identification of properties no longer suitable for rehabilitation and restoration will occur as sub-grantees carry out their programs and as Building a Better Brockton. Inc. gathers information on the true condition of foreclosed, vacant and abandoned properties. It is impossible at this point to determine the number of units expected to be demolished. Demolition per se is not the preferred alternative but rather a course of last resort. It is anticipated that approximately 22-24 units will be made available to persons/households earning below 120% of area median income through NSP-funded program activities under this allocation; it is expected that of these, six or seven units will be made available to persons/households earning below 50% of area median income.

F. P UB L I C C OM M E NT

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Provide a summary of public comments received to the proposed NSP Substantial Amendment. Response: The draft NSP plan will be posted on the City of Brockton’s website – www.brockton.ma.us - 15 days beginning November 14, 2008. Interested parties should feel free to submit comments, in writing or via email, directly to Building A Better Brockton, Inc. prior to the end of the comment period which is November 29, 2008. Comments may be directed to: Donald Walsh, Building A Better Brockton, Inc., 50 School Street, Brockton, MA 02301 or dwalsh@brockton21.com. As of the close of business on November 28, 2008, three public comments were received. See page 17A for the public comment from Norman Grenier, Executive Director of NHS of the South Shore and page 17B for the comment from Brian Moriarty, Director of the Brockton NeighborWorks HomeOwnership Center. Page 17C is a letter from Maureen Moriarty of MassHousing. All comments are well received by Brockton and certainly are consistent with the goals and activities outlined in our plan. We will be working with all three commenters as the program is implemented.

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Donald Walsh, CEO Building a Better Brockton Corporation 50 School Street Brockton, MA 02301 Public Comment for the City of Brockton Neighborhood Housing Services of the South Shore (NHS) is proposing to expand the City of Brockton’s successful “Buy Brockton” program. NHS’ Down-payment Assistance & Housing Rehabilitation Program would provide down payment & rehabilitation subsidies for individuals and families who choose to purchase a home in the City of Brockton. NHS is responding to Brockton’s growing vacancy crisis with an initiative geared toward reversing the negative housing market trend through an aggressive home ownership & rehabilitation program and marketing campaign. As the number of foreclosures continues to skyrocket, the number of vacancies will continue to climb. Vacant units are an issue for a variety of reasons, the most compelling being they effectively lower the value of surrounding units. They create costly problems for cities. They are a drain on city budgets. They detract from the quality of life, as well as the economic opportunities, of those living around them. They are an impediment to individual neighborhood redevelopment and, ultimately, to achievement of city-wide economic development goals. The Homeownership Down-Payment Assistance & Housing Rehabilitation Program’s objective is to extend the program by creating 24 new homeowners who will receive assistance in the form of a $10,000 deferred loan down payment (at 0% interest) and up to $30,000 in the form of a deferred 0% loan, both repayable to the Program upon resale or refinancing. Through this program buyers can purchase an abandoned or foreclosed home within the City of Brockton and rehabilitate the existing housing stock. By bringing homes into compliance with HQS (Housing Quality Standards), the Program will improve existing housing stock and, more importantly, play a key role in stabilizing neighborhood housing prices by filling vacant units with new, educated and qualified homeowners. The Program proposes the rehabilitation of twenty-four (24) units city wide, through use of deferred payment and permanent loans and will require, on a unit by unit basis, compliance with Article II of the State Sanitary Code, de-leading, and asbestos removal, in addition to general rehabilitation. NHS of the South Shore feels the Buy Brockton program is a successful model and with its expansion and the proper outreach we can have a serious impact in filling vacant homes with the City of Brockton. Normand Grenier Executive Director NHS of the South Shore

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From: Brian Moriarty To: Don Walsh@Brockton21.com Subject: Receivership Hi Don, Per our discussion during today’s Brockton Housing Partnership meeting, Neighborhood Housing Services respectfully requests that the Brockton 21st Century Corporation looks into using Neighborhood Stabilization Program funds for supporting a receivership program for foreclosed properties in Brockton. Perhaps an organization like Self help Inc. could possibly help in establishing this program. Regards, Brian Brian W. Moriarty, Director Brockton Neighborworks Home Ownership Center 68 Legion Parkway Brockton, MA 02301 (508) 895-1783 Email: b.moriarty@neighborhoodhousing.org

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From: Maureen Moriarty To: Don Walsh at Brockton 21st Century Corporation Subject: Comments to the Brockton NSP Substantial Amendment Draft Plan Don, As promised our discussion at the BHP meeting last week, I have read through the NSP and it seems a great job has been done covering the many issues at hand. I know this is a very cumbersome process and I commend folks on the work that has been done on this draft plan to date. There are a few comments/suggestions that I offer: (1) In section (B) there is no reference to using the Homebuyer Assistance in conjunction with the Buy Brockton Program – perhaps you do not want to be that specific, but the Worcester proposal is very clear about the use of these funds with Buy Worcester. (2) In section (B) again you might want to address the need for rehabilitation that includes money from the NSP funds for lead paint abatement as no federal funds can be used by a borrower purchasing a home unless any lead paint in the home is abated. Currently the state has no lead paint abatement funds available and there is no other funding source for lead paint abatement. When I met with Worcester, they said their purchase and rehab funds through the state and federal grants allow them to abate lead paint. (3) I also noticed in some of the other cities NSP plans, money from this fund is included for a rehabilitation specialist to be funded. If Brockton plans to do rehab or oversee rehab jobs on some of the cities distressed properties, this will likely be a necessity. NHS (when only in Quincy and in years gone by – I am not sure about now) had a rehab specialist for this type of work. A rehab specialist in Brockton may now be needed or may be helpful, and perhaps consideration should be given to using NSP funds towards this persons salary/compensation. MassHousing has a P&R program, but some Brockton area lenders do not participate as they are concerned they do not have the qualified staff to oversee rehab. The MassHousing P&R Program would allow the lender to contract an approved non-profit Rehab Specialist, but currently there is no one in Brockton to contract with for this type of work. If there was a person in Brockton, they would likely see business through Buy Brockton and the MassHousing P&R Program. (4) Last, in our discussion I mentioned that you may want to include monies in the NSP Substantial Amendment for demolishing “blighted structures” that are beyond repair and detrimental to the neighborhoods that Brockton is looking to stabilize. Thanks, Maureen Moriarty Relationship Manager MassHousing

One Beacon Street Boston, MA 02188 17C

G. NSP I NF OR M A T I ON B Y A C T I V I T Y (C OM PL E T E F OR E A C H A C T I V I T Y ) (1) Activity Name: Homebuyer Assistance, Purchase/Rehabilitation Assistance, Down payment assistance/Soft Second loans, Rehabilitation Grants

(2) Activity Type: (include NSP eligible use & CDBG eligible activity) Sec. 2301 (c) (3) (A): Establish financing mechanisms for purchase and redevelopment of foreclosed upon homes and residential properties, including such mechanisms as soft-seconds, loan loss reserves, and shared-equity loans for low- and moderate-income homebuyers. 24 CFR 570.202 (b) Types of assistance. CDBG funds may be used to finance the following types of rehabilitation activities, and related costs, either singly, or in combination, through the use of grants, loans, loan guarantees, interest supplements, or other means for buildings and improvements described in paragraph (a) of this section, except that rehabilitation of commercial or industrial buildings is limited as described in paragraph (a)(3). (1) Assistance to private individuals and entities, including profit making and nonprofit organizations, to acquire for the purpose of rehabilitation, and to rehabilitate properties, for use or resale for residential purposes; (2) Labor, materials, and other costs of rehabilitation of properties, including repair directed toward an accumulation of deferred maintenance, replacement of principal fixtures and components of existing structures, installation of security devices, including smoke detectors and dead bolt locks, and renovation through alterations, additions to, or enhancement of existing structures and improvements, abatement of asbestos hazards (and other contaminants) in buildings and improvements that may be undertaken singly, or in combination; Sec. 2301(c)(3)(B): Purchase and rehabilitate homes and residential properties that have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties. 24 CFR 570.202: Eligible rehabilitation and preservation activities for homes and other residential properties.

(3) National Objective: (Must be a national objective benefiting low, moderate and middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median income). Provides or improves residential structures that will be occupied by a household whose income is at or below 120% of area median income (LMMH).

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(4) Projected Start Date: January 15, 2009

(5) Projected End Date: January 14,, 2013

(6) Responsible Organization: (Describe the responsible organization that will implement the NSP activity, including its name, location, and administrator contact information) The City of Brockton will make NSP funds available to public and quasi-public instrumentalities and to local non-profit organizations and public service providers to concurrently carry out the activities described herein so as to best address high foreclosures rates and the threat from high percentages of subprime mortgages so as to stabilize the most negatively impacted areas of the City. The City of Brockton, acting through its sub-recipient, Building a Better Brockton, Inc. is issuing a Request for Proposals (RFP) to solicit proposals to deliver the services described herein. The range of activities and funding to be provided will include support of existing programs operated by public, quasi-public and non-profit agencies, and private development interests as well as new initiatives created specifically in response to this crisis. The Mayor of Brockton and Building a Better Brockton Inc., will confer with the Brockton Housing Partnership – a collaboration of local financial institutions, public agencies, and community based non-profits – in selecting among respondents to this RFP, those programs and projects to be funded under this and any subsequent NSP or related funding allocation. Brockton will evaluate the progress of each of the identified activity areas every six months and may re-allocate NSP funds among the activity areas and among the providers if Brockton determines that insufficient progress has been made in accomplishing the stated goals and commitment of funds in compliance with NSP requirements and as detailed in proposals selected pursuant to Brockton’ s RFP process. Brockton may commit additional funds to these activities should it be awarded additional NSP funds for those purposes by the Commonwealth of Massachusetts under its NSP allocation. Brockton may also identify additional activities, consistent with the needs analysis and eligible uses, and may amend its NSP to incorporate such activities if funds can be obligated within the time required. Donald Walsh Building a Better Brockton, Inc. 50 School Street Brockton, MA 02301 Telephone: 508-586-0021 Fax: 508-587-1340 Email: dwalsh@brockton21.com

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(7) Location Description: (Description may include specific addresses, blocks or neighborhoods to the extent known.) According to data from PolicyMap and others, nearly all of Brockton’s Census Tracts are at high risk for foreclosure and abandonment according to HUD’s scoring system, with more than half of Brockton’s Census Tracts rating a risk score of either nine (9) or ten (10). Of the 93 Census Blocks in Brockton’s 21 Census Tracts, only three (3) Census Blocks are ineligible due to slightly higher incomes in those areas, and only ten (10) Census Blocks have risk scores of less than seven (7). Brockton has six (6) Census Tracts with the highest score of ten (10); five (5) tracts with a score of nine (9); five (5) tracts with a score of eight (8); two (2) tracts with a score of seven (7); and three (3) tracts with a score of six (6). As previously demonstrated in Section A., some of the areas with the highest risk scores correspond with the City’s center, delineating a natural target area with the highest risk and the highest visibility, density and potential impact for positive change. The City will target these NSP funds to this area (Census Tracts 510400, 510800, 510900, 511400 and 511500), but will also explore and pursue opportunities in other Census Tracts with high risk scores and characteristics as opportunity and funding permit.

(8) Activity Description: Include a narrative describing the area of greatest need that the activity addresses; the expected benefit to income-qualified persons; and whether funds used for this activity will be used to meet the low income housing requirement for those below 50% of area median income. Rescue of Foreclosed Homes: Building a Better Brockton, Inc. acting through its sub-grantees will use NSP funds in target areas to supplement $279,873 in CDBG funding set aside in Brockton’s FY2008 Action Plan specifically for the purpose of rescuing foreclosed/vacant housing units, acquiring and rehabilitating and returning them to useful life as owner-occupied homes for income eligible persons and families. NSP funds may also be used to acquire and rehabilitate housing units to be made available as rental units for low and moderate income persons and families. Also included may be the use of receivership as a method for maintaining and stabilizing properties in high need areas. Brockton will encourage sub-grantees to leverage these funds to the greatest extent possible by accessing all available mechanisms. This would include such tools as the Neighborhood Stabilization Loan Fund administered by Massachusetts Housing Investment Corporation (MHIC) which makes loan funds available to for-profits or non-profit organizations that have clear plans to acquire vacant, abandoned or foreclosed properties in troubled neighborhoods. Local non-

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profits and public agencies carrying out programs under this Substantial Amendment will also be encouraged to explore the use of Fannie Mae’s Community Express loan tool to support their efforts. Down payment Assistance: Building a Better Brockton, Inc. and its sub-grantees may make subordinate deferred loans/grants to enable individuals to purchase a foreclosed, abandoned, or otherwise eligible property in designated high-foreclosure areas; may be used in conjunction with the Massachusetts Housing Partnership’s SoftSecond Loan Program. NSP funds will supplement some of the $100,000 in HOME funding set aside in Brockton’s FY2008 Action Plan to provide First Time Homebuyer Assistance. The funding may be structured as a deferred, declining balance loan or recoverable grant, consistent with standards established under the City of Brockton’s CDBG and HOME Consolidated and Action Plan(s) as well as the Commonwealth on Massachusetts’ NSP Plan. Funds may also be provided as SoftSecond interest subsidies, and loan loss reserves in lieu of private mortgage insurance. Purchase/Rehabilitation Grants for Income Eligible Families: Building a Better Brockton, Inc. acting through its sub-grantees will as needed make rehabilitation grants available to income-eligible households who qualify for established homebuyer assistance programs consistent with standards established under the City of Brockton’s CDBG and HOME Consolidated and Action Plan(s) as well as the Commonwealth on Massachusetts’ NSP Plan. Activity would be restricted to the rehabilitation of foreclosed or abandoned properties within the target areas. Strategic Demolition: The City of Brockton may undertake strategic demolition and/or redevelopment of blighted properties in the target areas on an as needed basis. Identification of properties no longer suitable for rehabilitation and restoration will occur as subgrantees carry out their programs and as Building a Better Brockton. Inc. gathers information on the true condition of foreclosed, vacant and abandoned properties. It is impossible at this point to determine the number of units expected to be demolished or units to be constructed in their place. Demolition per se is not the preferred alternative but rather a course of last resort.

Specific Activity Requirements: For acquisition activities, include: • discount rate - TBD For financing activities, include:

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•

range of interest rates - TBD

For housing related activities, include: • tenure of beneficiaries--rental or homeownership; - TBD • duration or term of assistance; - TBD • a description of how the design of the activity will ensure continued affordability. – TBD

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G. NSP I NF OR M A T I ON B Y A C T I V I T Y (C OM PL E T E F OR E A C H A C T I V I T Y ) (1) Activity Name: Alternative Financing Mechanisms (2) Activity Type: (include NSP eligible use & CDBG eligible activity) Sec. 2301 (c) (3) (A): Establish financing mechanisms for purchase and redevelopment of foreclosed upon homes and residential properties, including such mechanisms as soft-seconds, loan loss reserves, and shared-equity loans for low- and moderate-income homebuyers. 24 CFR 570.201 (a) Acquisition (b) Disposition (n) Direct homeownership assistance to persons whose incomes do not exceed 120% of median income. (3) National Objective: (Must be a national objective benefiting low, moderate and middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median income). Purchase/Rehab: Providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income (LMMH). Acquisition/Disposition: Benefiting all the residents of a primarily residential area in which at least 51% of the residents have incomes at or below 120% of area median income (LMMA). (4) Projected Start Date: January 15, 2009 (5) Projected End Date: January 14, 2013 (6) Responsible Organization: (Describe the responsible organization that will implement the NSP activity, including its name, location, and administrator contact information) The City of Brockton will make NSP funds available to public and quasi-public instrumentalities and to local non-profit organizations and public service providers to concurrently carry out the activities described herein so as to best address high foreclosures rates and the threat from high percentages of subprime mortgages so as to stabilize the most negatively impacted areas of the City. The City of Brockton, acting through its sub-recipient, Building a Better Brockton, Inc. is issuing a Request for Proposals (RFP) to solicit proposals to deliver the services described herein. The range of activities and funding to be provided will include support of existing programs operated by public, quasi-public and non-profit agencies, and private development interests as well as new initiatives created specifically in response to this crisis. The Mayor of Brockton and Building a Better Brockton Inc., will confer with the Brockton Housing Partnership – a collaboration of local

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financial institutions, public agencies, and community based non-profits – in selecting among respondents to this RFP, those programs and projects to be funded under this and any subsequent NSP or related funding allocation. Brockton will evaluate the progress of each of the identified activity areas every six months and may re-allocate NSP funds among the activity areas and among the providers if Brockton determines that insufficient progress has been made in accomplishing the stated goals and commitment of funds in compliance with NSP requirements and as detailed in proposals selected pursuant to Brockton’ s RFP process. Brockton may commit additional funds to these activities should it be awarded additional NSP funds for those purposes by the Commonwealth of Massachusetts under its NSP allocation. Brockton may also identify additional activities, consistent with the needs analysis and eligible uses, and may amend its NSP to incorporate such activities if funds can be obligated within the time required. Donald Walsh Building a Better Brockton, Inc. 50 School Street Brockton, MA 02301 Telephone: 508-586-0021 Fax: 508-587-1340 Email: dwalsh@brockton21.com

(7) Location Description: (Description may include specific addresses, blocks or neighborhoods to the extent known.) According to data from PolicyMap and others, nearly all of Brockton’s Census Tracts are at high risk for foreclosure and abandonment according to HUD’s scoring system, with more than half of Brockton’s Census Tracts rating a risk score of either nine (9) or ten (10). Of the 93 Census Blocks in Brockton’s 21 Census Tracts, only three (3) Census Blocks are ineligible due to slightly higher incomes in those areas, and only ten (10) Census Blocks have risk scores of less than seven (7). Brockton has six (6) Census Tracts with the highest score of ten (10); five (5) tracts with a score of nine (9); five (5) tracts with a score of eight (8); two (2) tracts with a score of seven (7); and three (3) tracts with a score of six (6). As previously demonstrated in Section A., some of the areas with the highest risk scores correspond with the City’s center, delineating a natural target area with the highest risk and the highest visibility, density and potential impact for positive change. The City will target these NSP funds to this area (Census Tracts 510400, 510800, 510900, 511400 and 511500), but will also explore and pursue opportunities

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in other Census Tracts with high risk scores and characteristics as opportunity and funding permit.

(8) Activity Description: Include a narrative describing the area of greatest need that the activity addresses; the expected benefit to income-qualified persons; and whether funds used for this activity will be used to meet the low income housing requirement for those below 50% of area median income. Establishment of alternative financing mechanisms including loan guarantees and loan loss reserves to encourage private financing of efforts by for-profits, nonprofits and individuals to acquire and rehabilitate foreclosed and abandoned properties so as to stabilize neighborhoods. Brockton may also identify additional financing activities and mechanism, consistent with the needs analysis and eligible uses, and may amend its NSP to incorporate such activities if funds can be obligated within the time required. For acquisition activities, include: • discount rate For financing activities, include: • range of interest rates - TBD For housing related activities, include: • tenure of beneficiaries--rental or homeownership; • duration or term of assistance; • a description of how the design of the activity will ensure continued affordability.

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G. NSP I NF OR M A T I ON B Y A C T I V I T Y (C OM PL E T E F OR E A C H A C T I V I T Y ) (1) Activity Name: Administration and Technical Assistance (2) Activity Type: (include NSP eligible use & CDBG eligible activity) Sec. 2301 (H) (3) National Objective: (Must be a national objective benefiting low, moderate and middle income persons, as defined in the NSP Notice—i.e., ≤ 120% of area median income). N/A (4) Projected Start Date: January 15, 2009 (5) Projected End Date: January 14, 2013 (6) Responsible Organization: (Describe the responsible organization that will implement the NSP activity, including its name, location, and administrator contact information) Donald Walsh Building a Better Brockton, Inc. 60 School Street Brockton, MA 02301 Telephone: 508-586-0021 Fax: 508-587-1340 Email: dwalsh@brockton21.com

(7) Location Description: (Description may include specific addresses, blocks or neighborhoods to the extent known.) N/A (8) Activity Description: Include a narrative describing the area of greatest need that the activity addresses; the expected benefit to income-qualified persons; and whether funds used for this activity will be used to meet the low income housing requirement for those below 50% of area median income. Building a Better Brockton, Inc will use up to 10% of this NSP allocation to support its own needs in administering the NSP, including: staffing; training; technology acquisition; necessary equipment; technical assistance; consultant services;

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planning; and reasonable overhead/office expenses. Building a Better Brockton, Inc. may at its discretion and on a case by case basis provide some funding to subgrantees for operational needs that cannot be directly attributed to program delivery under HUD regulations.

Specific Activity Requirements: - – N/A

For acquisition activities, include: • discount rate For financing activities, include: • range of interest rates For housing related activities, include: • tenure of beneficiaries--rental or homeownership; • duration or term of assistance; • a description of how the design of the activity will ensure continued affordability.

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I . Total Budget: (Include public and private components) NSP Budget NSP CDBG FY08 HOME (08) $1,537,700 $279,873 $100,000

ACTIVITY Homebuyer Assistance, Purchase/Rehabilitation Assistance, Down payment assistance/Soft Second loans, Rehabilitation Grants Alternative Financing Mechanisms Administration and Technical Assistance TOTAL

OTHER TBD

$400,000 $215,279 $2,152,979

0 N/A $279,873

0 N/A $100,000

TBD N/A TBD

J. Performance Measures (e.g., units of housing to be acquired, rehabilitated, or demolished for the income levels of households that are 50 percent of area median income and below, 51-80 percent, and 81-120 percent): It is anticipated that approximately 22-24 housing units will be made available to persons/households earning below 120% of area median income through NSPfunded program activities under this allocation as described above; it is expected that of these, at least six or seven units will be made available to persons/households earning below 50% of area median income.

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CERTIFICATIONS
(1) Affirmatively furthering fair housing. The jurisdiction will affirmatively further fair housing, which means that it will conduct an analysis to identify impediments to fair housing choice within the jurisdiction, take appropriate actions to overcome the effects of any impediments identified through that analysis, and maintain records reflecting the analysis and actions in this regard. (2) Anti-lobbying. The jurisdiction will comply with restrictions on lobbying required by 24 CFR part 87, together with disclosure forms, if required by that part. (3) Authority of Jurisdiction. The jurisdiction possesses the legal authority to carry out the programs for which it is seeking funding, in accordance with applicable HUD regulations and other program requirements. (4) Consistency with Plan. The housing activities to be undertaken with NSP funds are consistent with its consolidated plan, which means that NSP funds will be used to meet the congressionally identified needs of abandoned and foreclosed homes in the targeted area set forth in the grantee’s substantial amendment. (5) Acquisition and relocation. The jurisdiction will comply with the acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended (42 U.S.C. 4601), and implementing regulations at 49 CFR part 24, except as those provisions are modified by the Notice for the NSP program published by HUD. (6) Section 3. The jurisdiction will comply with section 3 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701u), and implementing regulations at 24 CFR part 135. (7) Citizen Participation. The jurisdiction is in full compliance and following a detailed citizen participation plan that satisfies the requirements of Sections 24 CFR 91.105 or 91.115, as modified by NSP requirements. (8) Following Plan. The jurisdiction is following a current consolidated plan (or Comprehensive Housing Affordability Strategy) that has been approved by HUD. (9) Use of funds in 18 months. The jurisdiction will comply with Title III of Division B of the Housing and Economic Recovery Act of 2008 by using, as defined in the NSP Notice, all of its grant funds within 18 months of receipt of the grant. (10) Use NSP funds ≤ 120 of AMI. The jurisdiction will comply with the requirement that all of the NSP funds made available to it will be used with respect to individuals and families whose incomes do not exceed 120 percent of area median income.
(11) Assessments. The jurisdiction will not attempt to recover any capital costs of public improvements assisted with CDBG funds, including Section 108 loan guaranteed funds, by

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assessing any amount against properties owned and occupied by persons of low- and moderate-income, including any fee charged or assessment made as a condition of obtaining access to such public improvements. However, if NSP funds are used to pay the proportion of a fee or assessment attributable to the capital costs of public improvements (assisted in part with NSP funds) financed from other revenue sources, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than CDBG funds. In addition, with respect to properties owned and occupied by moderateincome (but not low-income) families, an assessment or charge may be made against the property with respect to the public improvements financed by a source other than NSP funds if the jurisdiction certifies that it lacks NSP or CDBG funds to cover the assessment.

(12) Excessive Force. The jurisdiction certifies that it has adopted and is enforcing: (1) a policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non-violent civil rights demonstrations; and (2) a policy of enforcing applicable State and local laws against physically barring entrance to or exit from, a facility or location that is the subject of such non-violent civil rights demonstrations within its jurisdiction. (13) Compliance with anti-discrimination laws. The NSP grant will be conducted and administered in conformity with title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d), the Fair Housing Act (42 U.S.C. 3601-3619), and implementing regulations. (14) Compliance with lead-based paint procedures. The activities concerning leadbased paint will comply with the requirements of part 35, subparts A, B, J, K, and R of this title. (15) Compliance with laws. The jurisdiction will comply with applicable laws.
_________________________________ Signature/Authorized Official James E. Harrington__________ Title Mayor _____________ Date

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