Attachment to IRS Form 1023

XXXXXXXXXXXX, Inc.
EIN: 22222222222
Part IV. Narrative Description of Your Activities


The Applicant was created by XXXXXXXX, Inc., a Florida not for profit corporation recognized as exempt under Section 501(c)(3) of the IRS Code. Part of that organization's charitable purpose is to assist low income persons to become homeowners. They do this, in part, by helping such buyers gain access to affordable purchase financing and by providing them with a program of home buyer education. The Applicant's bylaws give XXXXXXXX, Inc. the exclusive power to appoint and remove directors from its governing board.

South Florida has experienced high rates of home foreclosure. Low income neighborhoods are destabilized as they become pock-marked with vacant and abandoned structures. Banks often end up holding title to the foreclosed properties. The United States Department of Housing and Urban Renewal (HUD), through its Neighborhood Stabilization Program (NSP), has made funding available to local governments and others for the purpose of stabilizing communities that have suffered from foreclosures and abandonment. NSP funds can be used to purchase and rehabilitate foreclosed and abandoned homes and other residential properties.

Several units of local government in South Florida are soliciting the collaboration of nonprofits. They will make NSP funds available for use in the acquisition, rehabilitate and resale foreclosed properties. The Applicant has been created to participate in such collaborations (and in similar non-NSP funded neighborhood stabilization efforts that fall within its charitable purpose).

The Applicant's sole activity will be acquiring, rehabilitating and reselling residential dwelling units to low and moderate income persons. The activity involves the acquiring of previously foreclosed properties using NSP and, at times, other sources of financing. The Applicant may, from time to time, acquire non-foreclosed residential properties that are in danger of being foreclosed. The only properties that will be acquired are those that can feasibly be resold to buyers that are qualified under the federal NSP guidelines. The Applicant will rehabilitate the acquired properties as needed so as to cure code violations and make any necessary repairs. To pay for the rehabilitation and repairs the Applicant may use lines of credit supplied by lenders and/or grant funds (provided through local NSP programs and other sources).

Most of the buyers are expected to be graduates of XXXXXX's homebuyer education program. That organization will assist such buyers obtain and close on the the necessary financing for the purchase.

This activity will further the Applicant's exempt charitable purpose of providing relief for the poor and distressed in that it will be conducted in conformance with the "safe-harbor” for developing housing described in IRS Rev. Proceeding 96-32.

In addition, this activity will further the Applicant's exempt charitable purpose of lessening the burdens of government in that (a) there is an objective manifestation by government that it considers the activities of the Applicant to be the government's burdens, and (b) the Applicant's activity will actually lessens the government's burdens.

In addition, this activity will further the Applicant's exempt charitable purpose of combating community deterioration in that (1) the Applicant will operate in an area with actual or potential deterioration, and (2) the Applicant's activity will directly prevent or relieve that deterioration.

The affairs of the Applicant will be managed by XXXXXXX in furtherance of that organization's exempt purpose. That organization shall provide each buyer with a free educational program and assistance in obtaining affordable purchase financing.