Legislative Updates
The BULLETIN
reproduced from www.irem.org with permission
June 2001
IREM MAKES A DIFFERENCE ON CAPITOL HILL
IREM’s Capitol Hill Visit day was a huge success! More than 215 members stayed an extra day after the conclusion of the Legislative and Leadership Summit to lobby their members of Congress. Over breakfast, IREM Legislative Staff from Chicago and Washington DC provided information to members on the general legislative process, how to lobby members of Congress, and a detailed presentation on the issues of concern.
IREM members met with over 400 Members of Congress during the Capitol Hill Visit day. IREM lobbied on 6 issues of primary concern to the property management industry. The biggest direct impact was felt on the issues of Accessibility and the Federal Reserve Proposal. Rep. Mark Foley (R-FL) and Senator Daniel Inouye (D-HA) have introduced the ADA Notification Act. This legislation will allow businesses to spend their money correcting violations of the law, instead of in court, benefiting only the legal profession. It would require that commercial facilities and places of accommodation be given 90 days notice before a lawsuit is filed for alleged violations of the ADA. They would then be allowed to correct any deficiencies before having to go to court. Following visits by IREM, 7 members of the House of Representatives immediately cosponsored this bill (HR 914). Dozens of members also have signed onto a number of letters opposing the Federal Reserve Proposal. HR 1030, the Tenant Leasehold Improvements bill, reduces the cost recovery (depreciation) period from 39 years to 10 years for leasehold improvements. After IREM's Capitol Hill Visit Day, 20 Members of Congress agreed to cosponsor this legislation. Other issues that IREM spoke to were Energy, Brownfields, and Bankruptcy Reform.
All those that participated in the Hill Visits met at the foot of the Capitol for group photos and to present Rep. Foley with the "Legislator of the Year" award for his work on HR914. Members then enjoyed a reception in Senate Committee chambers to discuss their visits with Congress and recap the day’s events.
CAPITOL HILL PHOTOS AVAILABLE
Pictures of the Capitol Hill Visits and others from the Legislative and Leadership Summit can be viewed and purchased at www.pgphotography.net Please use the password "IREM".
FEDERAL RESERVE BOARD/DEPARTMENT OF TREASURY PROPOSED RULE STATUS
The comment period for the Federal Reserve Board/Department of Treasury proposed rule allowing banks to engage in real estate brokerage and management activities ended on May 1, 2001 with 41,095 letters and e-mails received and recorded by the Federal Reserve. In addition to those letters and e-mails sent by REALTORS®, CCIMs, CPMs and federal banking institutions, a bipartisan letter was sent to the Agencies with 47 Congressional signatures. This letter expressed concern with the Agencies exploring the mixture of banking and commerce in detail.
On May 2, 2001, NAR President Richard Mendenhall, CCIM, presented the REALTORS® case against the Agency’s regulatory proposal before the House Financial Services Financial Institutions Subcommittee. Chairman Spencer Bachus (R-AL) convened the hearing to explore the issues raised by the Agencies. If you would like to read President Mendenhall’s testimony and that of other witnesses, please click here.
Due to the additional questions and concerns regarding congressional intent that came up during debate in the May 2nd hearing, Reps. Bob Riley (R-AL) and Paul Kanjorski (D-PA) are seeking consignors for a letter addressed to House Financial Services Committee Chairman Mike Oxley (R-OH) and Financial Institutions Subcommittee Chairman Spencer Bachas (R-AL) requesting additional hearings on the Agency’s proposed rule. The letter currently has over 60 signatures and NAR will be working with the state and local REALTORS® during the month of June (before Congress adjourns for the July 4th recess) to encourage additional members of Congress to sign the letter. If you are interested in assisting NAR and IREM with these efforts, please contact Katherine Broemmel, IREM Legislative Analyst, at 312-329-6021 or at kbroemme@irem.org The letter will be delivered to Reps. Oxley and Bachus after Congress reconvenes.
IREM FIGHTS FEDERAL RESERVE/TREASURY PROPOSAL
IREM filed a comment letter with the Federal Reserve and Treasury Department on May 1st, opposing their proposal to expand banking powers into property management. IREM opposed the proposal for four main reasons. First, we believe that banks’ ownership of property management firms creates a conflict of interest. Banks have access to financial information about a property (which would be disclosed during the loan application process), that could be used by a financial institution’s affiliate management company to undermine the leasing and marketing of the property by the private management firm. Banks could also use predatory pricing tactics, by offering property management services as a loss leader to gain control of the demand deposit accounts of income producing property owners.
Second, banks involvement in property management would create an unfair competitive environment for real estate management firms not affiliated with banks. Banks’ access to credit would place them in a far more favorable financial position. Requiring private property management firms to compete with an industry that receives unique governmental protections would create a wholly unleveled playing field. Third, The safety and soundness of the U.S. economy should not be put at risk by an untested regulation. Real estate development, management, and leasing are significantly different from banking and financial related activities, requiring considerable expertise and full accountability for distinctive economic and business risks. Last, property management is not a financial activity. Property management is the physical, fiscal and operational management of a real estate asset. The only activity incidental to financial services is cash management, and to argue therefore, that property management is a banking related activity would open the door to include any business that maintains bank accounts as a banking related activity.
STATEMENTS OF POLICY
At the May Legislative and Leadership Summit, two additional statements of policy were passed by the Governing Council. All IREM Statements of Policy can be found on the IREM website, in the "Government Relations" section.
ENERGY (replaces existing policy on Electric Deregulation. Previous policy on "Energy" is now titled "Energy Conservation".)
Background and Objective:
Many parts of the country are now facing an energy crisis. Poorly planned deregulation of electricity and gas in some communities and lack of adequate supplies and generation to meet demands has caused prices of these commodities to soar, and delivery of these services to be unstable. Rolling blackouts have occurred in California for months, and experts report that similar service and cost issues are expected to hit New York and New England over the summer. In those areas affected by escalating prices, the cost of utilities has become a major expenditure for both residential and commercial users nationwide.
As of January 2001, twenty-four states (AR, AK, CA, CT, DE, DC, IL, ME, MD, MA, MI, MT, NE, NH, NJ, NM, OH, OK, OR, PA, RI, TX, VA, WV) have restructured their electric power markets. For natural gas, eleven states have either unbundled their market completely (NJ, NM, NY, WV) or are in the process of implementing unbundling (CA, CO, GA, MD, MA, OH, PA).
As electricity and gas are a necessity rather than a luxury, discussion has surfaced regarding creating a free market to encourage competition, which in turn should bring lower utility rates. It should be noted, however, that electricity's elements are different from the other utilities in its generation, transmission, and distribution. While the transmission and distribution costs are somewhat fixed and may remain regulated, the generation of electricity may provide for the most competition and benefit for consumers.
In considering the impact of competition on the energy industry, one must also consider the type of consumers affected by deregulation. Industrial consumers consisting of large factories and manufacturing plants, generally get the best rates. Commercials users, consisting of retail centers and small stores, and the residential customer, are other consumer types. Which of these two consumer types receive a better rate may vary. As the demand for electricity and gas continue to increase, energy efficiency and conservation are sorely needed.
IREM Policy:
The free market system is the most appropriate means of attaining energy conservation and production goals. Increased conservation and domestic expansion are essential to our nation's security and economic prosperity. The nation must strive for greater energy self-sufficiency through further development of existing sources, decontrol of energy prices and the development of all new sources of domestic energy to reduce our dependence on foreign energy supplies.
We support the concept of conservation policies and the use of energy efficient technology. However, we strongly oppose mandatory national standards for building energy conservation. Specifically, IREM opposes mandatory installation, purchase, or usage guidelines for energy conserving products. Instead, we encourage positive incentives for conservation activities such as energy tax credits and an increased emphasis on energy efficient technology by the nation's building industry.
Furthermore, IREM appreciates the need to restructure the electric and gas power industries and believes it must be done carefully to ensure that all parties involved (present providers, future providers and all consumer types, including multifamily and commercial property owners) are treated fairly in the deregulation of this utility. While industry and some commercial consumers may benefit from the increased competition as a result of deregulation of electricity and gas, smaller consumers, such as multifamily and commercial property owners and residential consumers may not benefit as much considering the volume they consume.
Energy system reliability should not be compromised by deregulation, therefore, adequate safeguards should be included in deregulation plans to ensure the integrity of the generation, transmission, and local delivery systems. Deregulation should also allow for long-term energy contracts, to allow consumers to lock in prices on utilities.
The costs of deregulation should not be borne by the consumer. Although some states and municipalities could feel some loss in tax revenue, any shortfall resulting from deregulation should not be passed onto the property owner in the form of higher property taxes or other taxes or fees. Since electricity deregulation would not allow electricity producers to recover capital costs (previously considered stranded costs), recovery of these costs should be paid for by all rate payer categories on an equal basis. Deregulation plans should also allow power production facilities to retain their ownership rights, when they meet deregulation requirements. Lastly, deregulation plans should include short-term price controls so that energy costs cannot be substantially raised simply as a result of deregulation.
While states should carefully control local deregulation of energy, the federal government also has a role to play with a National energy policy. IREM believes the federal government should work to identify reliable sources of domestic and renewable energy, and strongly encourage development of these energy sources by reducing regulatory burdens and long-term price restrictions, that would chill the development of new energy sources. Furthermore, in the absence of competitive market forces, the federal government may need to step-in to protect consumers.
It is vital that consumers (both individual and business) have access to reliable, reasonably priced energy. IREM encourages its members to conserve energy and reduce demand in their facilities, and be proactive in educating tenants on programs and practices that they can do to conserve energy. We encourage voluntary participation in programs such as EPA’s Building Program, Green Lights Program, and Energy Star Program.
TOXIC MOLD ( to be added to the existing statement of policy on Indoor Air Quality)
Fungi are present almost everywhere in indoor and outdoor environments. Concern about indoor exposure to toxic mold has been increasing as a few well publicized cases have increased public awareness that exposure to toxic mold may cause a variety of health effects and symptoms, including allergic reactions. However, there have only been a limited number of documented cases of health problems from indoor exposure to fungi. We encourage all governmental bodies to conduct vigorous scientific study of indoor mold, prior to promulgating any regulations or legislation on toxic mold.
SENATE AND HOUSE AGREE ON TAX RELIEF PACKAGE
In late May, the House and Senate gave final approval to the $1.35 trillion tax cut package which is the largest tax cut approved by Congress in two decades. Some of the tax cuts will be retroactive, allowing the Treasury Department to begin sending refund checks to taxpayers this summer (single taxpayers will receive up to $300 each, while heads of households will receive up to $500 and married couples up to $600). The Treasury will begin mailing the checks in the third week of July (issued in order of the last two digits of a person’s Social Security number starting with 00) and hopes to have them all distributed by early October. Taxpayers who filed their 2000 returns will be eligible.
The key provisions of the bill are as follows:
Estate and Gift Taxes
Estate taxes are reduced gradually until their repeal in 2010. Gift taxes will remain, but the top rate drops to 45 percent.
Lowest Income Tax Bracket – Lowest rate drops to 10 percent next year. This year, a one-time credit will be paid by check. The rate applies to the first $6,000 of a single filer’s taxable income and the first $12,000 of a married couple’s income.
Income Tax Rates – Most tax rates will drop by about 3 percentage points until 2006. Beginning in 2006, income limits on itemized deductions will rise, and phase-outs of personal exemptions will gradually be repealed.
Child Tax Credit – The credit increases to $600 per child this year, rising gradually to $1,000 by 2010. Taxpayers with earned income above $10,000 may qualify for a refund if the credit is larger than their tax due.
Married Couples – The standard deduction for married couples’ filing jointly gradually becomes twice that of singles. The marriage penalty will be further mitigated by lowering marginal tax rates, which will reduce the portion of the marriage penalty that is derived from the current rate structure.
The IREM will continue to work with NAR in lobbying for business tax relief during the 107th Congress.
MODEL AGREEMENT FOR TELECOMMUNICATIONS DEALS RELEASED
In late May, the Real Access Alliance, of which IREM is a founding member, released the final version of the model license agreement for commercial office space. The prototype contract is designed to speed up the delivery of telecommunications services to office building tenants. The agreement fulfills promises made by the Alliance to the FCC last year. IREM members were given the opportunity to comment on the draft agreement until April 8. All comments received by that date were incorporated in the final document. Copies of the agreement are available at http://www.realaccess.org/
BANKRUPTCY BILL LIKELY HELD UP
With the transfer of power in the Senate to the Democrats, the future of the bankruptcy reform bill is more certain. The bill, passed by both the House & Senate early this year, contains three IREM-supported provisions – eliminates the cap on single asset bankruptcies, closes the loophole that allows for rental tenant abuse of bankruptcy to avoid eviction, and provides for protections for shopping center owners. IREM strongly favors the House-passed language, because it is much stronger on the rental housing issue. Senator Thomas A. Daschle of South Dakota has said he will act quickly to organize a conference committee to move a bill to President Bush’s desk. President Bush has already signaled that he will sign whatever bill is agreed upon by the House and Senate.
BROWNFIELDS SLOW TO MOVE IN THE HOUSE
When the Senate passed S. 350 by a 99-0 vote in April, it was expected the House would be eager to take up the issue. However, to date no companion bill has been introduced in the House. There are several brownfields bills before the House, but none are similar to the measure passed by the Senate. S.350 would amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to promote the cleanup and reuse of brownfields, to provide financial assistance for brownfields revitalization, and to enhance State response programs. The bill also clarifies that prospective purchasers, innocent landowners, and contiguous property owners, are not responsible for paying cleanup costs. Finally, this legislation offers finality by precluding EPA from taking an action at a site being addressed under a state cleanup program unless there is an "imminent and substantial endangerment" to public health or the environment, and additional work needs to be done.
CONGRESS BEGINS DEBATING HUD BUDGET
The Bush Administration has proposed $30.4 billion for HUD’s FY02 budget, a 6.6% increase over FY01. The House Appropriators are expected to increase this amount by another $1.1 billion. The budget request includes $15.1 billion for Section 8 contract renewals, as well as 34,000 new vouchers. In a very controversial move, the Administration has proposed eliminating the Drug Elimination Grant program. Many in Congress have questioned this move, and there is expected to be a great deal of contention over this issue. The Administration has proposed an additional $6m for the 202 program (a total of $783m), and $217m for Section 811, keeping it flat from FY01. The Bush proposal also includes a significant cut in the Public Housing Capital Fund (reduced by $700m). The Administration believes that the huge backlog of unspent funds will accommodate any capital needs for FY02. Hearings have just begun in the House, and the Senate is expected to start their hearings in the coming weeks.
FHA MULTIFAMILY LOAN PROGRAM SUSPENDED
In late April, HUD suspended the multifamily mortgage programs under the GI/SRI when the credit subsidy ran out. Programs effected include 221(d)(3), 221(d)(4), 241 supplemental loans, and 223d operating loss loans. Last year, Congress appropriated an additional $40 million for these programs, but the Administration refused to call the crisis an "emergency", as is required for the funding. HUD has now agreed to request $40 million (non-emergency) funds to restart the programs, but has also instituted a 30 basis point increase to the premiums. IREM is working with NAR and other housing groups to oppose the premium increase, and request additional funding for GI/SRI credit subsidy for FY01 and beyond. HUD’s Mortgagee letter 01-10 is available at www.hudclips.org
MARK-TO-MARKET MAKING THE TRANSITION BACK TO HUD
The Office of Multifamily Housing Assistance Restructuring (OMHAR) was created by the Multifamily Assisted Housing Reform and Afford ability Act of 1997 (MAHRAA) to administer the Mark-to-Market program. The legislation expires at the end of the fiscal year. While the underlying Mark-to-Market program is expected to be reauthorized, Congress has indicated its intent to abolish OMHAR. In preparation, HUD has now begun working on the transition of the Mark-to-Market responsibilities. The office of multifamily housing is expected to take over the administration of the program formally on October 1, but HUD staff are now working to make sure the transition is seamless.
HUD ISSUES RULE ON TENANT SCREENING AND EVICTION
On May 24, HUD published a final rule that implements requirements included in the Quality Housing and Work Responsibility Act (QHWRA), relating to better screening and denial of housing to individuals and families with specific types of criminal activity in their history. The rule also requires eviction for the same. Targeted individuals are: current illegal drug users, sex offenders, or persons who have criminal records related to drugs or violence. The requirements apply to both public and privately assisted housing. PHAs and State Housing Finance Agencies have been tasked with providing background checks and similar information. This rule is effective June 25, 2001. A copy of the notice is available at www.hudclips.org.
SENATE APPROVES FOUR NOMINEES TO HUD
On May 24, the Senate approved four HUD appointees. John Weicher will serve as Assistant Secretary for Housing/FHA Commissioner. Weicher has extensive experience at HUD, servicing under Jack Kemp, as well as holding positions in HUD during the Ford and Sr. Bush administrations. Alphonso R. Jackson will become the new Deputy Secretary of HUD. Jackson has administered three housing authorities – in Dallas, St. Louis, and Washington, DC. Richard Houser, former White House Counsel for Reagan will serve as General Council at HUD. Lastly, Ray Bernadi, the Mayor of Syracuse, NY, has been selected as the Assistant Secretary for Community Planning and Development. With the change in the Senate, it is expected additional Bush nominees will have a tougher time making it through the appointment process.
STATE AND MUNICIPAL ACTIVITY
The State and Municipal Affairs Committee had another productive meeting in May. The committee members discussed a variety of issues concerning telecommunications, security deposit fees, the new International Building Codes and community association management certification.
As a way to keep membership informed, some IREM chapters have regular electronic newsletters that are distributed to their membership via email. If your chapter has newsletters (or similar publications) that are distributed via email, IREM National is asking to be added to the distribution list. This is a great method to track the issues that are of importance to our membership, and to expand the sharing of information between National and our chapters. Newsletters should be sent to Katherine Broemmel, Legislative Analyst, at kbroemme@irem.org Please call Katherine at 800-837-0706 ext. 6021 with any questions.
ENERGY PRICE CONTROLS FOR CALIFORNIA
Commissioners from the Federal Energy Regulatory Commission agreed on April 25 to impose price controls on electric sales in California. They agreed to a price cap that would go into effect whenever electric power supply in the state falls to within 7.5 percent of demand. These price controls will go into effect on May 1, 2001 and remain in place for one year. This price cap may benefit those real estate industries in California who have reported that electric power price volatility is slowing their business.
HOW THE PRIVACY PROVISIONS OF THE GRAMM-LEACH-BLILEY ACT AFFECT YOUR BUSINESSAs of July, 1, 2001 the Gramm-Leach-Bliley Act ("Act") will require financial institutions to make certain privacy disclosures to consumers. These requirements will not apply to real estate brokerage services and property management activities, but will likely apply to real estate brokers who involve themselves in the mortgage loan process. Appraisers have disclosure obligations when they have been hired directly by a consumer to conduct an appraisal. Appraisers are not covered by the Act when performing an appraisal at the request of a lending institution. This article will discuss who is required to make privacy disclosures, when the disclosures need to be made, and how the disclosures should be made.
The Act's Implementing Regulations
The Act governs the collection, use, and disclosure of nonpublic personal information by financial institutions. Financial institutions are involved in several aspects of the real estate transaction, chief among those being the mortgage loan. The parties involved with mortgage loans must comply with the terms of the regulations.
Briefly stated, the regulations implementing the Act require the newly-authorized combination of banking, securities, and insurance businesses to disclose to consumers their policy regarding the disclosure of nonpublic personal information to unaffiliated third parties. Consumers are defined as those persons seeking a financial product or service for their personal, family, or household use. Consumers have the option to prevent disclosure of their personal information.
Brokers and Property Managers
The regulations apply to all businesses that are described by the regulations as engaging in a "financial activity." Financial activities are defined in the regulations as those activities described in Section 4(k) of the Bank Holding Company Act, including those which the Federal Reserve finds to be "closely related to banking." Although the Federal Reserve uses the term "real estate settlement services" in its regulation to describe activities "closely related to banking," for purposes of this regulation, real estate settlement services do not include real estate brokerage services and property management activities.
How the regulations will likely apply to the following:
Appraisers
The disclosure obligations of real estate appraisers is determined by the status of the person contracting for the appraisal. Appraisers who deliver their service through a bank, for example, are not covered because there is no consumer or customer relationship created with the appraiser. On the other hand, an appraiser doing the same appraisal for an individual would be included under the regulation.
Other Activities
Real estate brokers who are involved in other ancillary services related to the transaction will have to consider the application of the regulations to those other services. Those involved in mortgage lending or mortgage brokering are covered because they are engaged in the lending functions. Members engaged in the mortgage loan process are encouraged to consult with an attorney on the affect of the regulation.
What Disclosures Need to Be Made
If the disclosure obligation arises, the discloser must inform its consumers and customers about how their "nonpublic personally identifiable information" will be used. Nonpublic personally identifiable information is any information collected, either directly or indirectly, from the consumer in connection with the providing of a financial product or service. While information available from a public source is not included in this definition, it is the responsibility of the business to assure that any information it classifies as publicly available is in fact available. When the disclosure obligation arises, it is recommended that those parties consult closely with their attorney about the type of disclosure that needs to be made and when this disclosure needs to be made.
The regulations state that a consumer must receive an initial disclosure notice (defined below) if the business intends to share any nonpublic personally identifiable information with unaffiliated third parties. The consumer must also be given the ability to opt out. No notice is required for a consumer when the business does not share the nonpublic personally identifiable information. However, once a consumer establishes a "customer relationship" with the business, the customer must be provided at the outset of the customer relationship with a copy of the privacy policy notice of the business and annually thereafter until the customer relationship terminates, regardless of whether the information is being shared with unaffiliated third parties or not.
Type of Disclosure Form
The regulation makes the preparation of the form needed to accomplish the disclosure a complicated task. There is no standard form that will work for everyone. While the regulations contain some example clauses, they also make it clear that compliance requires the covered financial institution to review its own policies and practices concerning nonpublic personal information and tailor its disclosure form to reflect those practices.
Nine points must be covered in the disclosure form, when applicable. These nine items are:
(1) the categories of nonpublic personal information that are collected;
(2) the categories of nonpublic personal information that are disclosed;
(3) the categories of affiliated and nonaffiliated third parties (unless one of the exceptions applies) to whom nonpublic personal information is disclosed;
(4) the categories of nonpublic personal information disclosed about former customers, and the categories of affiliated and nonaffiliated third parties (unless one of the exceptions applies) to whom it is disclosed;
(5) if nonpublic personal information is disclosed to a nonaffiliated third party who provides services or function on behalf of the business, the categories of information used must be disclosed as well as the categories of nonaffiliated third parties with whom the business has contracted;
(6) an explanation of the consumer's right to opt out of the disclosure of nonpublic personal information to nonaffiliated parties and how the consumer may exercise that right;
(7) any disclosure required under the Fair Credit Reporting Act relating to the ability of a consumer to opt out of the disclosure of personal information to affiliated third parties;
(8) the policies and practices followed to protect the confidentiality and security of the nonpublic personal information collected; and
(9) notice of any disclosure of nonpublic personal information permitted under the exceptions contained in the regulations.
The regulations contain a couple of exceptions concerning the disclosure related to the processing and servicing of the customer's transaction. The exception most relevant to this discussion is the for a proposed or actual loan securitization, secondary market sale (including sales of servicing rights), or a similar transaction would qualify for the exception, when disclosure would otherwise be required. When this exception applies, the regulations require only that this form disclose to the customer that the business makes disclosures to other nonaffiliated third parties as permitted by law.
Conclusion
On July 1, 2001, the Act takes effect. Real estate brokerage services and property management will not be affected by the new regulations. Appraisers may be affected, depending on who contracts for the appraisal. A real estate broker or anyone else who involves themselves in a financial activity, as defined in the Act, will be required to make the privacy disclosures mandated by the Act.
For more detailed information on any of the above log onto IREM’s website at www.IREM.org and click on Legislation.
• • •
October 2000 Legislative Updates
July 2000 Legislative Updates
December 1999 Legislative Updates
September 1999 Legislative Updates• • •
INSTANTANEOUS ACCESS TO THE LEGISLATIVE BULLETIN NOW AVAILABLE!
IREM members will now have the capability of accessing the legislative Bulletin publication via the Internet. Every edition of the Bulletin will be posted on IREM's web site, www.irem.org, under the "Members Only" section under the heading "Legislative and Regulatory News". Members will be able to have an E-mail message sent to them, automatically, when the new edition of the Bulletin is posted on the web. Participation in this service is encouraged, as it provides IREM's membership with the latest legislative news quickly and hassle-free!
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IREM NATIONAL LEGISLATIVE STAFF: Charles Achilles, Staff Vice President; Megan Booth, Legislative Analyst Washington D.C.; Karen Larkin, Administrative Assistant Chicago; Kristin Harrelson, CIREI Legislative Analyst Chicago. For more information contained in The Bulletin, contact Charles Achilles, 430 North Michigan Avenue, Chicago, IL 60611; Phone 312/329-6020; fax 312/661-1786 or E-mail cachille@irem.org • • • • • • • • • •
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