At 02:18 PM 1/8/02 -0500, Richard_E._Dunne@HUD.GOV wrote:
Robert:

Did you get your answer on this? If not, let me clarify the meaning of HUD's guidance that your general counsel, Ms. Salemi noted below. The Flint, Grand Rapids and Michigan State Offices all require the removal of doors from refrigerators / freezers and to leave the doors in the property. Since there is no qualifier indicating only those appliances left on the interior or exterior only must have there doors removed, it can be interpreted to mean that all doors on refrigerators or freezers-regardless of where they are located on the property-must have their doors removed.

From: Robert Klein
To: Richard_E._Dunne@hud.gov
12/10/01 08:59 AM
Subject: HUD Michigan State Guidelines

Richard,

Recently the issue has come up with a number of our clients whether, in the Michigan State Office, it is a requirement to remove doors from refrigerators and freezes only if they are on the exterior of the property or whether this is also required if they are on the interior of the property. I received the following update from my staff on this issue.

I have also been asked whether, if this issue is a safety issue, does it only apply to the state of Michigan.

Any guidance you can provide would be greatly appreciated.

Sincerely,

Robert

From: General Counsel <alexandria.salemi@safeguardproperties.com>
To: Robert Klein

Per your request please see the following.

There are three FHA regional offices that state a requirement to remove doors from appliances and leave them in the property. The Flint and Grand Rapids Area Offices provide a cost allowable for this, the Michigan State Office does not.

If you note, these are all Michigan offices. This may be required in these areas due to Michigan law. Section 750.493d of Chapter 75 of the Michigan Penal Code provides as follows:

Any person who knowingly leaves, in a place accessible to children, any abandoned, unattended or discarded icebox, refrigerator or other container of a kind and size sufficient to permit the entrapment and suffocation of a child therein, without first removing the snaplock or other locking device from the lid or cover thereof, is guilty of a misdemeanor.

This, however, does not answer the immediate question of whether it includes the interior of a vacant property that has been secured. Caution would dictate the assumption that it does.

Following please see the pertinent guideline provisions on this matter.

FHA Mortgagee Letter 97-31; 00-26

Debris Removal/Attachment 5

Flint Area Office:
Mortgagees are not to perform any debris removal except for health hazards
(raw garbage, animal feces, etc.) without prior approval from the local HUD
office.

Remove doors from refrigerators/freezers left in property.

$15 per appliance to remove doors.

Grand Rapids Area Office:
Mortgagees are not to perform any interior debris removal except for health
hazards (raw garbage, animal feces, etc.) without prior approval from the local HUD office.

Remove doors from refrigerators/freezers and leave in property.

Mortgagees must remove all exterior debris.

$15 per appliance to remove doors.

Michigan State Office:
Mortgagees must remove all exterior debris.
Remove doors from refrigerators/freezers and leave in property.