National Low Income Housing Coalition Memo
Memo to Members, Vol. 14, No. 8 National Low Income Housing Coalition ***President Requests $1 Billion for NHTF THE ADMINISTRATION ***President Outlines FY10 Budget Request CAPITOL HILL ***Budget Committees, Advocates Gear Up for FY10 Budget Resolution *** ***Sen. Menendez to Chair Housing Subcommittee; Sen.Vitter to be Ranking Member ***Bill Would Help Localities with Vacant Properties
NATIONAL HOUSING TRUST FUND
THE FORECLOSURE CRISIS
***House Considers Legislation to Help Troubled Borrowers
HUD
***HUD Announces Allocation of Stimulus Funds
HURRICANE RECOVERY
***Senate Subcommittee Releases Report of Housing Response in Wake of 2005 Hurricanes
***Gulf Coast
FROM THE FIELD
***NM Advocates Initiate Campaign for Housing Trust Fund Dedicated Source
RESOURCES
***Renters in Foreclosure: A Legal Review of the Rights of Tenants
***Review of Homelessness Prevention Programs
FACT OF THE WEEK
***Tenants’ Rights in Foreclosure Proceedings Vary by State
NLIHC NEWS
***HUD Secretary Donovan and House Financial Services Chairman Frank to Headline at NLIHC’s 2009 Conference
***NLIHC Board of Directors Seeks Nominations
***NLIHC Seeks Spring and Summer Interns
NATIONAL HOUSING TRUST FUND
***President Requests $1 Billion for NHTF
President Barack Obama’s FY10 budget request includes $1 billion for the National Housing Trust Fund. The budget request calls for providing the first funds into the housing trust fund to finance the development, rehabilitation and preservation of affordable housing for extremely and very low income households. Indeed, these would be the first federal funds for extremely low income housing production since 1974.
President Obama’s request notes that the housing trust fund, which was enacted in July 2008, was originally authorized with a dedicated funding stream from assessments on Fannie Mae and Freddie Mac but that these assessments were indefinitely suspended by the Federal Housing Finance Agency.
“NLIHC is especially pleased by inclusion in the budget of inaugural funding for the National Housing Trust Fund,” NLIHC President
The $1 billion request is on the mandatory side of the budget, which means that these funds would come from a dedicated revenue source that is separate and apart from the appropriations process. The President’s budget request does not identify the dedicated revenue source; that information is expected in the more detailed budget request the president will make to Congress in April.
During the February 26 Senate Committee on Banking, Housing and Urban Affairs hearing on HUD’s home foreclosure avoidance programs, Senator Jack Reed (D-RI), a champion of the eight-year effort to establish a National Housing Trust Fund, remarked on his pleasure over the $1 billion funding request to HUD Secretary Shaun Donovan, the hearing’s witness.
Senator Reed said that, when reviewing the budget request, he was particularly thankful for the $1 billion to launch the affordable housing trust fund included in the budget. “It sends a signal,” Senator Reed said, “that our housing policy cannot rest simply on homeownership, that there are scores of American families whose best and wisest course of action is to be in affordable rental housing because of their family situation or their economic situation.”
The National Housing Trust Fund campaign is gearing up to make sure funds for the National Housing Trust Fund are included in the FY10 Congressional budget resolution.
Link to NLIHC’s statement on the President’s budget request at http://www.nlihc.org/detail/article.cfm?article_id=5850&id=48
Read more about what the President’s request means for housing programs in the following article.
THE ADMINISTRATION
***President Outlines FY10 Budget Request
President Barack Obama released an overview of his FY10 budget request on February 26. Advocates were pleased with the budget request would mean for housing programs. Funding for HUD would increase from $41.1 billion, the amount the House and Senate are considering in the FY09 omnibus spending bill for HUD (see related article), to $47.5 billion. Only a few details were released beyond the top-level number; specific program-level funding requests are expected in a more detailed budget to be released in April.
In addition to requesting $1 billion for the National Housing Trust Fund (see previous article), the budget request includes increases for the Community Development Block Grant program and increases for the renewals of existing project-based and tenant-based contracts.
“This budget signals a refreshing and much-needed change of direction for the country’s housing policy, and offers hope for the millions of low income families who struggle to find decent homes they can afford,” NLIHC President
The budget request would fund the Community Development Block Grant program at $4.5 billion, up from about $3.6 billion in FY09. According to the request, the President will also seek “a more effective formula, appropriate incentives and accountability measures.” In addition, he calls for creating within the CDBG program a new Sustainable Communities Initiative to better target CDBG funds to distressed communities and promote sustainable and economically viable communities.”
White House staff, in a February 26 budget teleconference on the FY10 request, said that the CDBG reform proposal will “hold harmless somewhat more affluent communities but create benefits for more vulnerable communities.” NLIHC’s long-standing position is that the most effective way to reform the CDBG program is to more deeply target CDBG’s resources to very- and extremely low income groups.
The President’s request will also increase funding for the Housing Choice Voucher program. While White House staff say it is unlikely the more detailed April request will seek new, incremental vouchers, the administration will introduce legislative reforms to increase the program’s efficiency, “alleviate the administrative burdens on Public Housing Authorities, and establish a funding mechanism that is transparent and predictable in order to serve more needy families.” White House staff referred to vouchers as a key tool for preventing homelessness.
The request also speaks to the President’s commitment to preserve approximately 1.3 million affordable rental units through increased funding for contacts with owners of multifamily projects, calling this a “critical investment.”
White House staff said the request will “tak[e] care of public housing” as well, although no details were available. The request also mentions increased funding for fair housing enforcement.
In addition to the Sustainable Communities Initiative, the request outlines a new Choice Neighborhoods Initiative with an unspecified amount of funds for HUD “to support a range of transformative interventions in neighborhoods of concentrated poverty.” In addition, a new Energy Innovation Fund would be created to support the creation of an energy-efficient housing market, including retrofitting older housing and instigating private-sector lending in the residential sector.
The request would zero-fund HUD’s Section 108 Loan Guarantee Program and the American Dream Downpayment Initiative. The Section 108 program, funded at $6 million in the House’s FY09 omnibus spending bill, allows a community to pledge up to five years of its CDBG funding as collateral for a larger loan. If estimated revenues from the new project fall short of expectations, the community’s future CDBG allocations must be used to repay these loans. The American Dream Downpayment Initiative began in the Bush administration as a set-aside within the HOME program to facilitate increased homeownership rates.
“From providing shelter to those displaced by Katrina to giving help to those facing the loss of a home to revitalizing our cities and communities, HUD’s role has never been more important,” HUD documents quoted President Obama as saying upon release of the budget request. “Since its founding, HUD has been dedicated to tearing down barriers in access to affordable housing -- in an effort to make
Access the White House’s FY10 budget documents at www.omb.gov.
Link to NLIHC’s updated FY10 budget chart at http://www.nlihc.org/doc/FY10-presidents-request.pdf
Link to NLIHC’s statement on the budget request at http://www.nlihc.org/detail/article.cfm?article_id=5850&id=48
CAPITOL HILL
***Budget Committees, Advocates Gear Up for FY10 Budget Resolution
The President’s FY10 budget request (see previous article) is expected to provide just enough detail for the House and Senate to begin work on their joint FY10 budget resolution, which is generally set by April 15. The resolution, while not mandatory, can be a critical document, as it sets overall spending guidelines for all mandatory and discretionary spending and is the precursor to the appropriations process. As in past years, advocates will work to try to influence the resolution.
Work on the budget resolution this year will include seeking dedicated funding for the National Housing Trust Fund (see article above).
The Congressional budget resolution provides an overall framework that includes the total anticipated costs of federal programs, revenues, and the surplus or deficit. It sets limits for annual discretionary spending, places limits on the amount of spending that authorizing committees can approve, and establishes a revenue target for the tax-writing committees.
The budget resolution allows Congress to make a statement of its major priorities by choosing to focus resources among different areas of the budget, known as functions. There are about 20 budget functions, including three that are of interest to housing advocates. Function 600, Income Security, includes HUD’s housing assistance programs. Function 450, Community and Regional Development, includes the Community Development Block Grant and other community development programs, USDA rural development programs and FEMA and other disaster mitigation programs. Function 370, the Commerce and Housing Credit, includes Federal Housing Administration programs, Census funding and USDA rural housing programs.
Both the House and Senate Committees on the Budget will hold hearings on March 3 to discuss the President’s FY10 request and short- and long-term budget challenges. The House hearing is at 10 am in room 210 of the Cannon House office building. The Senate hearing is at 10 am in room 608 of the Dirksen Senate office building.
In the next few weeks, advocates will focus especially on members of the House and Senate who are part of each chamber’s budget committees. The names of members can be found at http://budget.senate.gov/ and http://budget.house.gov/
***
As the President and Congress moved forward on the FY10 spending bill (see related articles), the House voted 245-178 on February 25 to pass its FY09 omnibus spending bill. The House-passed bill includes funding for the Transportation-HUD appropriations bill as well as eight other unfinished FY09 spending bills. The Senate is expected to take up the measure, H.R. 1105, the week of March 2. In September 2008, President Bush signed a continuing resolution to keep federal programs funded through March 6.
The bill, which increases HUD’s overall funding by about 10% compared to FY08, was welcomed by advocates as further evidence of a new direction on housing issues at the federal level. The bill includes $20 million for approximately 2,800 new vouchers under the Family Unification Program, $75 million for approximately 7,500 new vouchers in the HUD-Veterans Administration Supportive Housing program and $30 million for approximately 4,000 new vouchers for non-elderly disabled families.
In addition, HUD programs that will see increases if the omnibus spending bill is enacted include public housing, voucher, project-based housing, homeless assistance grants, HOME, Community Development Block Grant, Housing for Persons with AIDS, Native American Housing Block Grant, fair housing, Section 202 Supportive Housing for the Elderly and Section 811 Housing for Persons with Disabilities, Native Hawaiian Housing Block Grant, and research programs. The bill includes about $183 million in earmarks under the economic development and neighborhood initiatives programs.
The bill also includes various housing policy provisions, including some important housing preservation tools. As has been included in recent appropriations bills, the bill would allow the transfer of some or all project-based assistance from one multifamily project to another for preservation purposes and would require HUD to maintain project-based Section 8 contracts when selling properties at foreclosure or from the HUD inventory. The bill would also require that the cost of repair needs and the cost of maintaining the building’s affordability restrictions be taken into account when HUD determines the market value of any multifamily foreclosed properties it sells to state or local governments.
The bill also includes a provision that would allow Section 202 Supportive Housing for the Elderly owners to refinance their loans for the purposes of meeting the building’s repair needs, even if the refinancing does not result in lower debt service, if the refinancing meets a cost-benefit analysis done by the HUD Secretary.
The bill would also require the HUD Secretary to increase the number of public housing agencies participating in the Moving to Work deregulation demonstration program by three. The three PHAs must be high performers under HUD’s public housing assessment system, must be HOPE VI grantees, and must not administer more than 5,000 total units combined of public housing and vouchers. NLIHC opposes the expansion of the Moving to Work program before this demonstration is fully evaluated and lessons learned from potential harmful impacts on residents, such as increased rents, loss of assistance and relaxed income targeting, are addressed. Three more participating PHAs would represent a 10% increase in the number of agencies currently participating in this program.
Link to NLIHC’s updated FY10 budget chart at http://www.nlihc.org/doc/FY10-presidents-request.pdf
***Sen. Menendez to Chair Housing Subcommittee; Sen.Vitter to be Ranking Member
New Jersey Senator Robert Menendez (D) is expected to become the Chair of the Senate Banking, Housing and Urban Affairs Subcommittee on Housing, Transportation, and Community Development. He will replace Senator Charles Schumer (D-NY).
Senate Majority Leader Harry Reid (D-NV) is enforcing a “two-gavel” rule that says that full committee chairmen are not allowed to chair more than one subcommittee. Senator Schumer is the new chair of the Senate Committee on Rules and Administration and will also hold the chairmanship of the Senate Judiciary Subcommittee on Immigration, Border Security and Citizenship, meeting his two-gavel limit. Senator Schumer will remain a member of the Senate’s housing subcommittee.
Senator Menendez has a strong history of supporting public and assisted housing programs. Elected to the House in 1992, he was appointed to the Senate in 2006 to fill the remaining term of Senator Jon Corzine (D-NJ) who had been elected Governor of New Jersey. Senator Menendez then successfully ran for the Senate seat later in 2006.
“Let me just say how excited I am to work with you as the new Chairman of the subcommittee. I will miss Senator Schumer … but your intelligence around these issues, your commitment to housing … I am very, very excited to work with you,” HUD Secretary Shaun Donovan said to Senator Menendez during a Senate Committee on Banking, Housing and Urban Affairs February 26 hearing on HUD’s mortgage foreclosure mitigation plans.
Senator Menendez describes his commitment to housing issues on his website. “I have consistently worked to ensure that public housing is available to people who need it, often as their last resort. I have also been a strong supporter of community development and revitalization programs that create affordable housing opportunities,” he writes. “For many families across the nation, public housing programs have served as a saving grace.”
During his time in the Senate, Senator Menendez has spearheaded and supported a variety of efforts to increase funding for, and improve, HUD programs including fair housing, public housing, voucher, community development block grants, elderly housing, veterans’ housing, housing for persons with AIDS, homeless assistance, housing counseling and HOME.
Senator Menendez has also worked to ensure HUD’s programs take reasonable steps to provide meaningful access to families who speak languages other than English, and he has suggested improvements to HUD’s Limited English Proficiency guidance.
The new ranking Republican on the housing subcommittee will be Senator David Vitter (R-LA). Senator Vitter has served in the Senate since 2004 and is new to both the Senate Committee on Banking, Housing and Urban Affairs and its Subcommittee on Housing this year.
According to Senator Vitter’s website, he is “focused on putting
Unfortunately,
In addition to Senators Menendez and Vitter, the other Subcommittee members are Senators Tim Johnson (D-SD), Jack Reed (D-RI), Charles Schumer (D-NY), Daniel Akaka (D-HI), Sherrod Brown (D-OH), Jon Tester (D-MT), Herbert Kohl (D-WI), Mark Warner (D-VA), Jeff Merkley (D-CO), Kay Bailey Hutchison (R-TX), Robert Bennett (R-UT), Mike Johanns (R-NE), Michael Crapo (R-ID), Mel Martinez (R-FL) and Jim DeMint (R-SC).
***Bill Would Help Localities with Vacant Properties
Senator Charles Schumer (D-NY) introduced on February 23, S. 453, the Community Regeneration, Sustainability, and Innovation Act of 2009. The bill would establish a ‘Regeneration Communities’ demonstration program at HUD to encourage and test innovative vacant property reclamation and urban infrastructure renewal strategies in older industrial cities, suburbs of such cities and metropolitan areas that have a history of severe population and employment loss, blight, and decay caused by vacant properties. Assistance would be provided through grants and technical support. The bill would spur innovation by supporting sustainable and green infrastructure programs.
The bill would also create the Federal Interagency Regeneration Communities Coordinating Council, which would develop support plans for the communities receiving the new funds.
The bill calls for authorizing $300 million over the next three fiscal years for the Regeneration demonstration program and $24 million each year for the next three fiscal years for the Federal Interagency Regeneration Communities Coordinating Council.
S. 453 is cosponsored by Senator Sherrod Brown (D-OH), and was referred to the Senate Committee on Banking, Housing and Urban Affairs.
THE FORECLOSURE CRISIS
***House Considers Legislation to Help Troubled Borrowers
On February 26, the House began consideration of H.R. 1106, the “Helping Families Save Their Homes Act of 2009.” This bill was introduced February 23 and is comprised of four bills.
One bill contained in the larger bill is H.R. 200, the Helping Families Save Their Homes in Bankruptcy Act of 2009, which passed the House Judiciary Committee on January 27. This bill amends federal bankruptcy law to grant a judge the ability to modify the terms of a mortgage for a homeowner in chapter 13 bankruptcy. This process, commonly referred to as “cramdown,” continues to be opposed by the banking community. NLIHC supports such a provision, and joined with other organizations on a letter of support organized by the Center for Responsible Lending.
H.R. 1106 also contains three bills passed by the Committee on Financial Services on February 4. H.R. 788 would shield mortgage servicers who engage in specified mortgage loan modifications from liability to the holder of the mortgage. H.R. 787 would make improvements in the Hope for Homeowners Program, including providing for a payment of up to $1,000 to servicers for loan modifications. H.R. 786 would make permanent the temporary increase in deposit insurance coverage from $100,000 to $250,000.
The House is likely to continue debate and vote on the bill on March 3.
HUD
***HUD Announces Allocation of Stimulus Funds
HUD announced on February 25 the allocation of 75% of the funds provided in the recent economic recovery legislation, the American Recovery and Reinvestment Act of 2009 (ARRA), for HUD programs. The remaining 25% of funds will be awarded via competition in the coming months.
The ARRA, which was signed by President Obama on February 17 (see Memo, 2/20), included $13.61 billion for projects and programs administered by HUD. Programs receiving funds include the Emergency Shelter Grant Program, the Public Housing Capital Fund, and the Community Development Block Grant program. The Low Income Housing Tax Credit program will also receive funds, which will be distributed through the HOME program.
The speed with which HUD made this announcement, just eight days after the legislation was signed into law, is indicative the urgency of putting the recovery dollars to work rapidly to create jobs and help people hurt most by the economic crisis.
More information about the allocations, including a breakdown of the funds by state and a list of programs receiving funds, can be found at http://www.hud.gov/recovery/index.cfm.
HURRICANE RECOVERY
***Senate Subcommittee Releases Report of Housing Response in Wake of 2005 Hurricanes
The Senate Subcommittee on Disaster Recovery, chaired by Senator Mary Landrieu (D-LA), released on February 26 a report it had been working on for the last nine months. The report, “Far From Home: Deficiencies in Federal Disaster Housing Assistance After Hurricanes Katrina and Rita and Recommendations for Improvement,” describes in detail the response by FEMA in the wake of hurricanes Katrina and Rita, and the power struggle of determining which agency would take the lead role in administering housing assistance between HUD or FEMA. Many members of the Katrina Housing Group, including NLIHC, were interviewed for the report.
In a press release touting the release of the report, Senator Landrieu said, “After more than $15 billion spent on disaster housing, multiple pieces of legislation, and five public hearings, FEMA is still resisting change, rejecting innovation and unprepared to plan for housing during a catastrophic disaster. This is really a tragic indictment of the previous administration's failure to recognize that government does need to work. In times of catastrophe and great challenges, government must do its part. This report shows that when people on the Gulf Coast were working to reestablish their lives, their livelihood and their communities, government failed to adequately provide the key to recovery -- housing."
The report offers insight into White House decisions and arguments on how best to address the housing situation in Katrina’s aftermath. In fact, it illustrates just how incapable of responding FEMA truly was, as they scrapped the housing plan they had in place in favor of an incoherent ad hoc plan.
That plan entailed responding with temporary shelter assistance, placing people in hotel rooms, and sending trailers and mobile homes in the tens of thousands. “Purchase trailers until I say stop,” one FEMA official is quoted as saying in the report. Even though zoning laws would not allow for a number of the trailers from being used, and despite the health risks the trailers posed because of high level of formaldehyde in the materials, FEMA still views trailers as a viable response in future disasters.
The report states the importance of HUD taking the lead in offering housing assistance in the wake of a natural disaster, and the subcommittee makes seven recommendations for responding to future disasters. Those recommendations are: to establish a rental repair program and reform of the Stafford Act that will allow HUD to increase the rental and affordable housing stock in disaster response; require HUD to develop and prepare a National Post-Disaster Housing Plan, similar to what FEMA submitted in July of 2008 and January of 2009; enhance the ability of FEMA and the Army Corps of Engineers to deploy teams to restore repairable property in an expedited time frame; reform the Stafford Act to allow for longer assistance; FEMA must complete its housing plan outlined in the National Disaster Housing Strategy; FEMA and HUD need to improve assistance to special needs and low-income populations; and develop, implement and test a post-disaster housing strategy.
A copy of the full report can be found here: http://landrieu.senate.gov/news/Disaster_Housing_Investigation.pdf
***Gulf Coast
The National Low Income Housing Coalition, the Equity and Inclusion Campaign, Amnesty International USA, Oxfam
Over the two days, advocates met with officials from the Office of Management and Budget, the Domestic Policy Council, HUD, FEMA, and the Gulf Coast Recovery Coordinator, as well as Members of the Louisiana, Mississippi, and Alabama Congressional delegations, staff from key Senate and House committees with oversight of HUD and FEMA, and staff for Senate Majority Leader Harry Reid (D-NV), Senate Minority Leader Mitch McConnell (R-KY), and House Majority Leader Steny Hoyer (D-MD).
FROM THE FIELD
***NM Advocates Initiate Campaign for Housing Trust Fund Dedicated Source
More than 70 people joined the New Mexico Coalition to End Homelessness (NMCEH), an NLIHC State Partner, for its third annual lobby day in January, more than three times as many as had attended the group’s first lobby day. The focus of this year’s event was the kickoff of the Campaign for a Dedicated Funding Source, aimed at securing permanent funding for the New Mexico Housing Trust Fund. The fund was created in 2005, but is dependent upon annual appropriations from the General Fund. After an initial appropriation of $10 million for the housing trust fund in 2005, amounts have dwindled to only $1 million or $2 million in subsequent years.
The goal of the Campaign is to secure $20 million each year through dedicated sources. Working with Mary Brooks of the Center for Community Change, the Campaign devoted a year to assessing dedicated source options. They decided to pursue an additional $30 document recording fee, primarily for real estate transactions. County clerks would collect the added fee, keeping $5 for the county’s general fund and directing $25 to the housing trust fund. NMCEH estimates that the additional fee could generate $10 to $12 million annually for housing.
As part of this year’s lobby day, teams of advocates met with Senators to talk about the nature and extent of need for affordable housing in the Senator’s district, and they stressed how many units of affordable housing had been built or rehabbed with the $15 million available to the housing trust fund since 2005. Following the lobby visits, a rally was held outside the Capitol, at which the keynote speaker was Senator Jerry Ortiz y Pino, who would later introduce SB 244, the funding bill. Later, a debriefing session revealed that many Senators grasped the extent of need for affordable housing and expressed interest in the concept of a dedicated source of funding for the housing trust fund, especially one that would not further stress the state’s general fund.
Since lobby day and formal introduction of the bill to establish the dedicated source, SB 244 has cleared the Senate Public Affairs Committee – but by a vote of 5-4. A primary objection expressed by some legislators is the belief that the $30 additional fee (on top of the current fee of $9 for the first page and $2 for each subsequent page) is an onerous “tax” on real estate. The next stop for SB 244 is the Senate Finance Committee. Advocates are hopeful that the bill will squeak through the Finance Committee and make it to the floor of the Senate before the mid-March end of the legislative session. This constraint may also make it difficult for the bill to clear the House in time.
The Campaign has understands it has embarked on a multi-year advocacy endeavor. After mid-March, the Campaign plans ongoing informational meetings with elected officials to build support for the dedicated source.
“Over the last four years, the New Mexico Housing Trust Fund has proven to be a very powerful tool for creating affordable homes for low and moderate income residents throughout the state,” said NMCEH Policy and Advocacy Director Lisa LaBrecque. “But without a dedicated funding source, it will be hard to maintain the success of the program. We believe that during this economic and housing crisis, an investment in the New Mexico Housing Trust Fund is one of the best things we can do to prevent homelessness and help our economy.”
To view a Campaign video making the case for SB 244 click here: http://www.youtube.com/watch?v=AT890nfKt6w For more information, contact NMCEH Policy and Advocacy Director Lisa LaBrecque at Lisa-L@nmceh.org.
RESOURCES
***Renters in Foreclosure: A Legal Review of the Rights of Tenants
The
The study concludes that in the majority of states, a renter’s tenancy would be automatically terminated following a foreclosure; however, the circumstances vary greatly. For example, 17 states require some form of notice of the foreclosure prior to an eviction. In 12 of these states, the new owners can terminate tenancy fairly rapidly after a foreclosure, but only if the tenant has been joined in the foreclosure proceedings. Fourteen states and the
In general, the study finds that there are three ways in which the interplay between foreclosure and eviction occurs within states. First, there are states that have an integrated process that notifies tenants of any foreclosure proceedings and may require them to be joined as parties in the foreclosure in order to be evicted. The second group of states has completely independent foreclosure and eviction processes. In these states the status of tenancy is often unclear after foreclosure and left to a separate eviction process. Finally, there are hybrid models in which state law offers some specific guidance on tenancy after foreclosure, but a significant lack of clarity often remains regarding rights of possession.
The report recommends that in order to stem renter eviction and the subsequent rise in homelessness, the federal government needs to take immediate action to protect tenants in cases of foreclosure. Recommendations include requiring fair notice to tenants, preserving existing tenancies, and providing renters with legal assistance.
The report includes an appendix with state-by-state policy descriptions.
The report, Without Just Cause: A 50-State Review of the (Lack of) Rights of Tenants in Foreclos
