19.2.2.4 Procedures for Final Closings

A. The RC Director will notify DBLS of a pending Final Closing as soon as practicable, and no later than 1 business day after the date the RC Director finalizes the Maximum Insurable Mortgage (form HUD-92580).

• B. The RC Director will obtain a written determination from DBLS confirming either that:

1. All labor relations issues are resolved; or,

2. Appropriate mitigants are established to resolve outstanding issues.

C. The RC Director will obtain clearance for Final Closing from DBLS at least 5 business days in advance of a confirmed final closing date. The RC Director will immediately provide a copy of said clearance to the HUD Closing Attorney.

• D. The DBLS clearance for Final Closing may be qualified:

1. If the DBLS clearance is conditional, the RC Director will ensure that the closing clearance includes notification of what, if any, documentation must be provided, or actions taken, to clear the conditions for Final Closing.

2. If issues remain that cannot be resolved in advance of Final Closing, the RC Director will ensure that the closing clearance includes either:

   • A deposit to the U.S. Treasury of an amount sufficient to meet any wage restitution and/or liquidated damages that have been or may be found due; or

   • A completed deposit agreement (Labor Standards Deposit Agreement (form HUD-4732)), a schedule for the deposit, and wire transfer instructions for the depositor’s financial institution.

3. If the DBLS clearance for Final Closing is qualified, either by conditions or a deposit requirement, the RC Director will include a description of the applicable limitations in the RC Director’s administrative clearance to close the Loan.