The CDC ensures the interim financing is fully disbursed and the project completed before the debenture is sold, except a minor portion escrowed with SBA's approval (held by the CSA, title company, CDC attorney or bank, liens obtained first, releases approved by CDC and SBA against invoices by joint check, and funds unused after a year applied to the Third Party Loan), and that the interim lender can give its SBA Form 2288 certifications. The CDC is responsible for the 504 loan closing and its compliance and, with SBA, the debenture closing: it prepares the documents, uses SBA Form 2286 for every closing and submits the listed items, the mandatory SBA forms, the Opinion of CDC Counsel (from a licensed attorney in good standing; a Priority CDC may not use in-house counsel as designated attorney or split closing and opinion except as allowed) and the SBA environmental indemnification agreement where used; its own lien instruments are state bar or SBA counsel approved and real estate liens contain a due-on-sale clause. ALP Express loans close only through a Designated Attorney under the expedited process with all 327 actions submitted.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.