1. Previous Participation Certifications
Form HUD-2530/APPS Submissions
Handbook Chapter 2.5FF

2. Purpose
To assure that participants in ORCF projects are responsible with regard to their participation in other governmental housing transactions

3. Filing the Previous Participation Certification
Electronic APPS (Active Partners Participation System) Submission OR
Paper Submission + BPRS (Business Partners Registration System) Registration
Participants do NOT need to complete the Previous Participation section of the Consolidated Certifications

4. Who must File a 2530/APPS Submission?
Borrower
Operator
Master Tenant
Management Agent
General Contractor
Principals of These Entities

5. Principals for 2530/APPS Purposes

6. Organization Chart Example

7. 223(a)(7) Projects
APPS/2530 Submissions are only required on 223(a)(7) projects if principals have not previously been approved.

8. Organization Charts
Organization charts are a visual representation of the ownership structure of an organization
An organization chart must be submitted for each entity that submits an APPS or submission
The organization chart must match the APPS or 2530 submission

9. Organization Charts (continued)
The organization chart must include the following:
Clearly show all tiers of the ownership structure
Show all participants, not just those the Lender considers to be principals
Show percentages of ownership and role in the entity (e.g., Limited Partner, General Partner, Managing Member, etc.)

10. Organization Charts (continued)
Include a natural person/people, and not just entities
Each entity must be shown on a separate organization chart (e.g., Borrower, Operator, Management Agent, Master Tenant, etc.)
The key is to provide a clear, succinct chart that someone unfamiliar with the transaction can quickly understand.

11. APPS Submissions

12. Filing an APPS Submission
Follow instructions on the HUD website for submitting an APPS Submission:
Include the signed signature pages in the Firm Application
ORCF staff need the Submission ID numbers to review and approve the submissions

13. Paper 2530 Submissions

15. Page 1: What to Review
Block 7: Do the participants match the organization chart?
Are all participants listed in Block 7 also on the signature page?
Have principals signed the submission?
If certifications have been struck through, are the strikethroughs initialed? Have you included a signed letter of explanation?

17. Schedule A: What to Review
Column 1: Are all principals shown in Block 7 listed?
Column 4: Are any defaults or foreclosures listed?
Column 5: If applicable, was the default or foreclosure during the principal’s participation?
Column 6: Are there any projects listed with REAC scores below 30?

18. Key Items to Review on 2530 Form

19. BPRS Registration

20. BPRS Registration
The lender must check each principal listed on the Form HUD-2530 to assure that they are registered in BPRS
A principal may not be registered in BPRS even though they have participated in previous HUD projects, so it is important to check each time you submit a 2530
Lenders are NOT required to check BPRS registration for APPS submissions

21. Flags in the APPS System

22. Flags in the APPS System
Flags are placed on participants in the APPS system for things such as:
Failure to File Financial Statements
REAC Scores below 30
Violations of Business Agreement
Claims/Defaults

23. Flags in the APPS System (continued)
When there is a flag in the APPS system there are two ways a participant can be approved:
Reason for the flag is remedied (e.g., missing Annual Financial Statements are filed or subsequent acceptable REAC score)
Lender researches the flag and provides convincing documentation explaining the flag and why approval of the participant is warranted