19.4.11.3 Borrower's Attorney's Opinion (Tax Credits)

A. All LIHTC transactions require opinion 11 of the Opinion of Borrower's Counsel. Borrower’s counsel may rely on a tax credit counsel opinion that provides opinion 11 if, and only if, the tax credit counsel opinion uses the Opinion of Borrower’s Counsel’s definitions of Primary Loan Documents and Source Documents, and a copy of the tax credit counsel opinion is provided to HUD. If the tax credit counsel opinion does not provide opinion 11 in the form described above, Borrower’s counsel must undertake its own due diligence and independently provide form opinion 11.