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  • Comment Detail

  • Date: 01/19/17
    First Name: Blair
    Last Name: Sebastian
    Email: blairsebastian@gmail.com
    Organization Type: individual
    Organization: NYS Rural Advocates
  • Comment

    HI Ellie
    I had commented on the original proposed rule in the federal register and ended up on a committee working on the rural goals. I am also very much interested in the mobile home area. Its been a little while and i would have to dig back into things but as i recall, i was satisfied with the rural definition even though i am pretty sure that the rural areas they are interested in are in the Colonias and indian country... with areas of persistent poverty (the southern black-belt) added . None of those places are in new york.
    the mobile home area is interesting. originally they were most interested in financing acquisition and improvement of mobile home parks (not for profit owned i think) but after discussion they agreed to take on this "chattel mortgage" issue. I think they came to understand that fixing up the parks is important but if you can address the old units in the park, they really couldn't address the larger problem. I am not sure how they will accomplish mortgage financing of chattel but geez, if they can... what a great precedent and what a great tool!
    I will try to circle back and see if i have other notes. I am out of touch tomorrow but i would love to touch bases with you the first of the week.
    b