203K Loan HUD Consultants and General Contractor Conflicts

Quick tip on 203k loans in regards to HUD Consultant and general contractor conflictsAs a potential home buyer, make sure that the HUD Consultant and the General Contractor who is doing the repairs and upgrades to the property, are not the same person.  The HUD Consultant is supposed to be an independant third party who keeps the General Contractor in check.

I’ve ran into a few people and have seen some blogs out there recently that state that the HUD Consultant steered the home buyer, or so they say, toward a certain General Contractor to do the work on the home.  As a home buyer please understand that this is not necessarily a bad thing but you do need to do your own due diligence in checking into the relationship between the HUD Consultant and the General Contractor.  Make sure and Google the HUD Consultant and the General Contractor. Ask for references from past jobs from both the HUD Consultant and the GC and call the past clients.  This is no different from any other business you contract with.

The HUD Consultant is used on the 203k loan, the 203k Standard loan in particular, and part of their job is that they are supposed to serve as a buffer of sorts between the homeowner and the General Contractor and make sure that the materials and labor charged by the GC are fair and at market rate which protects both the lender and homeowner.  Their relationship at times can be testy because the HUD Consultant may be making some adjustments to the General Contractor project(s) or maybe the HUD Consultant is wanting the GC to do more work before they ask the lender to advance the GC more money to finish or start another project which is being financed by the 203k loan.  The process works, but you want to make sure that the HUD Consultant and GC relationship isn’t compromised in any way and the best way to make sure of that is to do your own due diligence before you agree to do work with either of them, and that goes for Loan Originators too!

As I previously mentioned in a past article, make sure and get your General Contractor selected early, before you make an offer on a home, and make sure they have worked with the 203k loan in the past.  There are several 203k loan directories for contractors out there on the web.  Check out a few of them for contractors in your area.  These contractors have gone out of their way to learn about the 203k loan and its nuances.

Unfortunately there are unscrupulous people in every profession.  Just like anything else you have to look out for yourself.  I as a Loan Originator am looking after your best interests as well, but ultimately it’s the home owner’s name that goes on the offer contract, the loan documents, the HUD Consultant contract and the General Contractor’s contract.  Take the time to look out for yourself and check everyone out you are working with and you’ll be on your way to a successful transaction.

If anyone has a question on this article or on 203k loan HUD Consultants and general contractor conflicts, please let me know by clicking here!

Best,

Kevin Walton

203k Loan Advice, Get A Contractor Bid Before You Write An Offer

In regards to the 203k loan advice, I don’t know everything and I don’t pretend to, but I know more than most.  However lately I’ve been receiving calls from troubled borrowers who have started a 203k loan with another lender and it’s falling apart and they need help keeping their deal together.

One of the main issues on the Standard 203k, (the one that does the bigger jobs such as adding on a room), I’ve been hearing about is that the home buyers got their home looked at by a contractor AFTER they made an offer to buy a home.  This can cause huge headaches.

It’s best to have a contractor, who is experienced with the 203k loan and it’s nuances, look at the property before you make your offer.  Give your contractor your wish list on what improvements you want to do and get a bid as to how much these upgrades are going to cost.  You need to know this upfront!

Also keep in mind if there are any health and safety issues such as dry rot damage, or a broken HVAC unit, broken windows and such, the lender will demand these items to be fixed before any of your requested repairs are to be done, so your repair amount may be increased to take care of these items.  This is where a trained 203k loan experienced contractor comes into play.  They may have an idea of what these health and safety items are or better yet have a HUD Consultant view the property before you make an offer as well, especially if the home has apparent damage. It doesn’t matter if the loan is to be a 203k Streamline (where a HUD Consultant isn’t required but is suggested to protect the homeowner) or a 203k Standard. There could be more damage than what it seems and if they are deemed health and safety issues, these fix it items will need to be added to the remodel/repair project.

Another reason why a contractor bid is needed upfront before you qualify for a 203k loan is that the repairs are part of the formula which calculates your final loan amount.  It’s best to get an idea on how much of a loan you qualify for, including the repairs as early in the process as possible.  It’s common sense, and you would think the lender would be guiding the home buyer on this, but many times they don’t.

To summarize, have your contractor selected before you make an offer on a home.  Walk thru the property and check it out thoroughly with the contractor and go back to the property if necessary a few times before you make the offer and don’t forget about having a HUD Consultant look over the property as well.  Look at it as a pre-inspection.

Also make sure the lender does both the 203k Standard loan as well as the 203k Streamline loan.   The 203k Streamline loan only gives $30-35k in funds for repairs and upgrades and if you are doing the 203k Streamline and if you go over budget and your lender only does the 203k Streamline loan, your home purchase is in serious jeopardy because you’ll have to switch lenders and possibly have to pay for a new appraisal since the appraisal may not be able to be transferred from one lender to another.

If you have any questions in regards to 203k loan advice feel free to email me your scenario and I would be glad to help!

Best

Kevin Walton

 

 

Can The 203k Loan Be Used For Conventional Financing?

Pic credit to jscreationz

Can the 203k Loan Be used For Conventional Financing?The quick answer is no.  The 203k loan is an FHA loan product and can not be used for conventional loan financing. There are other financing options for conventional financing such as the FNMA Homepath Renovation loan.  The 203k loan is basically a modified FHA loan.  It is an added feature to a normal FHA loan and the 203k loan is underwritten using the same underwriting criteria as a regular loan.  If a property for sale is eligible for FHA financing than it “should” be eligible for 203k financing as well.  If this is not the case, than the Realtor/Asset Manager and seller need to be educated on the 203k loan and it’s close relationship to the normal FHA loan.If the 203k loan is put together correctly upfront, it may only take an additional week to get the loan closed, so again if the property is FHA financing friendly, than 203k financing should be approved as well.  If you have a question in regards to the content of this article or whether or not can the 203k loan can be used for conventional financing, please let me know by clicking here.Best,Kevin Walton

Realtors And The 203k Loan. Why Do They Dislike It?

The 203k loan is like taboo to some Realtors, they dislike it.  To the 20 year experienced Realtor the 203k loan may be looked at as a loan that is problematic and associated with fraud.

Realtors who have been in business for 10 years or more may have never seen the need for the 203k loan because there were home equity loans available to fix up homes or in many parts of the country FHA financing was an after thought due to the maximum  FHA loan amount being too low compared to home selling prices.

To a Realtor licensed 5 years or less the 203k loan may be a loan they have heard about, but most of what they have heard has been not so good, or to just stay away from it and wait for the cash offer to roll in from an investor.

In all fairness, the 203k loan earned this reputation years ago but it has had a makeover and if structured correctly can become a big player in the pursuit in rebuilding America and helping first time home buyers and repeat buyers compete with the cash investors when buying properties that need some TLC.

Educating Realtors and the general public is key when it comes to the 203k loan.  Most of the fraud on this loan happened well over 20 years ago when HUD didn’t have a handle on the investor and contractors who were using this loan.  That’s right the 203k loan used to be allowed for investors, but than that went away many years ago.  HUD has Consultants who oversee the standard 203k loan to make sure fraud is at a minimum and for the most part they have done a good job in protecting the home buyer.

The 203k Streamline loan was introduced within the last decade, but truthfully it should have been renamed to stay away from the 203k loan stigma that existed from the standard 203k loan.  So this cloud of sorts hangs over both loans in the form of a bad reputation.

Home equity loans are now a thing of the past unless you have 25% equity to begin with, and now that FHA has raised it’s maximum loan limits to be more in line with conventional lending, the FHA 203k loan is now poised in becoming a hero in this real estate market.

But why aren’t Realtors more receptive to the 203k loan?  Here’s a list of reasons I’ve heard from Realtors as to why they don’t like this loan as well as my response to their reasoning.

“It takes too long to get a 203k loan done”.  This can be true if it’s not structured correctly upfront, but typically it may take 10 days longer to close, but they can close just as fast as a conventional loan again if structured correctly and proper expectations have been set.

“I’ve heard horror stories about the 203k loan”.  Again true but that story may have come from the 20 year veteran Realtor who remembers the fraud days of the 203k loan.  Structuring the loan upfront with an experienced 203k loan agent, a contractor who is familiar with the 203k loan process and a HUD Consultant who is dually licensed as a home inspector can iron out most of the wrinkles up front.

“The asset manager (of the REO lender) doesn’t accept 203k financing”.  But why is that?  When I asked for more information I found out it was the Realtor who wasn’t familiar with the 203k loan and didn’t want to take the time to learn the program and ask for the 203k loan financing option to be allowed.  They would both rather just wait for the low ball cash investor.  This attitude doesn’t help first time home buyers.  I do understand not wanting to make waves with the asset manager but there is a bigger picture here.

“Why would someone want to use the 203k loan to buy a fixer when they can just buy a move in ready property”.  A home may be be ready to move into, but numbers prior to the home equity meltdown showed the average home buyer put up to $10,000 into their newly purchased home in the first year they bought the home.  Homeowners want to be able to pick their colors, appliances, and put their touches on a property.  So even though there is a nice bland color carpet and neutral paint colors and it looks nice doesn’t mean that’s what’s going to stick and with the home equity loan being all but extinct, the 203k loan is one of the only options left to obtain funds to do home improvement/remodeling.

“I can’t get a preapproval letter with the 203k loan”.  This is partly true because the final loan amount on the 203k loan isn’t determined until after the appraisal is done.  That’s one of the differences with the 203k loan.  The loan amount is determined on the after improved value, not the as-is value.  So how to get around this?  Just pad the loan amount.  If the property is for sale for $300,000 and they want to put in $30,000 in repairs/remodeling, than a $330,000 prequalification (not a preapproval) letter should do the trick.  Show all parties that you are padding the loan amount as well as showing the automated underwriting approval and list of improvements and bids by the contractor to demonstrate due diligence has been done.

“I’m not comfortable with the way this loan works and it puts my client (seller) in jeopardy”.  Seriously?  Obtaining a conventional loan approval is more difficult than obtaining an FHA 203k loan approval.  FHA loan underwriting guidelines are more lax than conventional underwriting.  This is simply someone who hasn’t gone the extra mile to educate themselves on the 203k loan.

This last Realtor reason for not liking the 203k loan came from a Realtor on my street who was selling a home with an illegally converted garage.  ” I don’t need the hassle of the 203k loan. Besides the home will sell quickly and we’ll get close to market value since it’s in a good location”  The house sat for 8 months before it sold, and a cash investor came in and bought it at a low ball price and killed our neighborhood values.  It would have cost roughly $10,000 to reconvert the garage and why not entice the buyer with the 203k loan funds to use to do this and get a higher sales price? It boggles my mind.  Now the investor is attempting to re-sell the same property, didn’t reconvert the garage back, and guess what?  8 months later it hasn’t sold either and he’s going to have to take a deep discount to dump it.

I do understand the Realtor hesitance on the 203k loan.  However, it needs to be understood that the 203k loan can solve a myriad of problems and create a win-win for all involved.  The 203k loan just isn’t for foreclosures.  The 203k loan can help create a vision for home buyers who want to use the loan for remodeling purposes on a property that needs updating and it’s comforting to know that you have a loan that can both buy a home and carry financing for upgrades all in one.

If you have any questions in regards to this article, or have questions as to why Realtors dislike the 203k loan please click here and let me know your scenario!

Best Kevin Walton

203k Loans Do It Yourself Fix-Its Not Always Allowed

A 203k loan may be alluring to a do it yourself handyman.  You get buy a home in need of repair and get a fixer upper home loan, the 203k loan, and receive funds within the loan to fix up the home or remodel it to your liking.

It is within the FHA rules to allow do it yourself work on the 203k Streamline loan and the 203k Standard loan.  However just because FHA has this guideline doesn’t mean a lender may not put an additional overlaying guideline on top of that to not allow it.  Lenders who offer the 203k loan can put any overlay on the the product that they want.  Lenders are increasingly shying away from do it yourself work on the both 203k loans.  Why?  It gets sticky.  There is a myriad of forms that have to be explained to the do it yourselfer on how to fill them out ledgibly and correctly.  This causes frustration and delays on both ends of the process.  Fraud is another possibility.  The do it yourselfer must also demonstrate that they are a master at the project they are working on.  They may need to demonstrate that they have an active license as a contractor, and possibly show proof of past clients work, and if they have a crew working on the project have ample workmans compensation insurance.  If the lender ends up foreclosing on the property they want to make sure the work done is up to code and in a worksmanlike manner.  This is now the mentality of a lender in todays market.

So now several 203k loan lenders are putting an additional overlay on these loans to the effect that no do it yourself work can be done.  Some are even going as far as stating that all work must be done by one contractor.  It makes it easier for the lender this way.  Instead of having to deal with several contractors and explaining the 203k loan process to them, they just have one.  Taking it even a step further, some 203k big box lenders have a deal set up with Lowes, or Home Depot to do all the work which in my opinion is not good.  It limts your choices.

The 203k loan is not your everyday loan.  It does require some knowledge regardless on if you do the repairs yourself or if you hire a contractor to do the repairs.  203kcontractors.com have contractors who have been trained on the nuances of the 203k loan.  This is worth checking out to save you time and frustration on finding a contractor who is willing to accept the terms of the 203k loan.  Contractors don’t get paid right away on this loan which means they may have to float money until the entire rehab on the property is done.  This is not popular with contractors!

Just make sure that if you are a do it yourselfer and want to use the 203k loan to buy and rehab a home, that your lender of choice allows you to do the work yourself, and if they do, what parameters must be followed.  Do this upfront before applying for the loan to save yourself some headaches but either way the 203k loan is viable way to buy and rehab a home all in one low fixed rate loan.

If you have a question in regards to this article please click here and let me know your scenario!

The Appraisal Came in Low-What Now? This Can Fix The Problem

You are buying a fixer home that needs updating and your home loan is preapproved, you have your proof of funds squared away and than bam….the home doesn’t appraise for the agreed upon purchase price.  So how do you fix a low appraisal problem?

The seller is willing to renegotiate and meet you halfway on the difference but that money was to be used for home improvements and now your plans are in shambles. Now what?

There is another way here that no one seems to be talking about.  Change the loan to an FHA 203k!  Add some home improvement items that need updating ie..carpet, countertops, cabinets and paint, get a bid for the work and have the home re-appraised by another appraiser.  The FHA 203k allows for a 10% “fudge factor” so if the appraised value vs. purchase price is less than a 10% difference you can possibly save a deal especially on a fixer home where the homebuyer needs to keep as much personal funds as possible for home improvements.

Here’s how it works.  The 203k Streamline loan allows for up to $35k in repairs to be added to the purchase price of the home for remodeling purposes.  You obtain the purchase loan and remodeling funds all in one loan . The 203k loan has two appraisal figures on it’s appraisal instead of just one like a normal appraisal.  One value is the “as-is” value.  The other is a value including the repairs you are going to do to the home.

Let’s take a purchase price of $275,000.  The home appraisal comes in low at $268,000 using a conventional loan appraisal.  Flipping the loan to a 203k Streamline loan would trigger a new appraisal.  Let’s say the new 203k loan appraisal comes in at $268,000 as well,  that’s the “as-is” value. The seller will renotiate down to $271,00 and you’re left with coming up with $4,000 and you’re willing to do that since it’s a good deal, but now you’re also $4,000 short on home improvement funds. You can qualify for a slightly mortgage payment but you’re short on repair funds and you’re operating on a dime.  But with the 203k Streamline loan adds funds to your loan balance to do repairs and home improvements.  So now you’ve decided to add new countertops, cabinets, carpet and paint.  The total of updated improvements comes out to $20,000 which is double the home improvement budget you were planning to use (your own funds) and you can now hang on to that money.  The appraiser takes these improvements into account, and gives an after improvement value of $275,000.  Problem solved!

Granted the borrower is going to have to requalify for a higher loan amount.  If they were putting forth a down payment of 10% on the initial offer of $275,000 that would be $27,500 and a loan amount of $247,500.  On the 203k loan, the new loan amount is $259,200 ($268,000, new as-is appraised value + $20,000 in remodeling= $288,000 -10% down payment $28,800).  So the monthly payment may be $65.00 higher per month but……….they got upgrades financed into their loan at a low fixed rate, AND where else would they find a way to finance remodeling these days with having 10% equity/down payment?  HELOC lenders now require 25% equity before they’ll talk to you.

It’s a win-win for all involved.  Keep this option in mind when you have a low appraisal issue.  The seller sells their home and doesn’t have to relist it, and if that buyer really wants that house and they don’t have or want to come up with the full cash difference out of pocket to make it happen, think of the 203k Streamline. It can be used for remodeling financing and a deal saver at the same time.

If you have a question in regards to this article please click here and let me know your scenario!

Best,

KW

Buying A Home In As-Is Condition

Buying a home in as-is condition to many home buyers is scary thing.  Many people want homes in move in ready condition and make things simple.  But what if you get a good value on an as-is property?  Maybe there’s a broken window, or missing toilets or holes in the wall?  A lender will not normally loan on that property at all, those are health and safety issues.   But what if everything is in tact but the house looks like a scene from an old 1950’s t.v. show?  What if you are getting a good deal but just don’t have the funds to update the home?

Fortunately the 203k loan is available for both of these situations. Whether you have broken windows, or an undesirable yellow kitchen the 203k Streamline gives you up to $35k in remodeling funds to update/remodel and fix the health and safety issues.  You can even get new appliances with the funds as well.  You receive these funds in addition to your purchase loan it’s all included in one low 30 year fixed rate loan.  The 203k Streamline loan is an FHA loan and is not meant to fix structural issues, it’s meant for more cosmetic items.  But cosmetic covers a wide variety of things including electrical problems, appliances, countertops, cabinets, carpet, paint, roofing, air conditioning units and the like.

The 203k Standard loan does the bigger jobs.  Maybe you want to add a bathroom or a bedroom or garage.  Those items are structural in nature but they can be handled by the 203k Standard loan, and again the repair funds are added to your purchase money loan as well so it’s all in one 30 year fixed rate low rate.

All the repairs and remodeling projects are done after escrow closes, so you can buy the home in as-is condition.  It’s one of the only loans available that does this and in our current real estate market, the 203k loan is gaining in popularity and is helping cash strapped home buyers acheive their dreams of owning a home.

If you have a question in regards to the content of this article please let me know by clicking here!

Best

KW

Structuring An Offer With A 203k Loan

Pic Credit to jscreationz’s

 

OK, I’ve heard many reasons why a Realtor or REO lender won’t accept a 203k loan contract offer.  How do we combat this?  We have a qualified homebuyer but their choice of financing is an issue.  The main roadblocks are that the loan takes too long to fund, and that Realtors have heard nightmares about past attempted 203k loan fundings.

These are both valid issues.  As far as taking too long, if put together correctly from the start, an additional 7 business days should not be enough to kill a deal.  Heresay from another fellow Realtor should not keep you from accepting a 203k contract offer either.  Have we heard nightmares about BofA, Wells Fargo, Chase and Citi and how they are on their normal conventional loans?  Absolutely.  The 203k loan is no different.  Draw upon your own experiences on this loan on whether or not it’s a viable loan.  Give it a chance.

Making an offer to buy a home using a 203k loan, whether it’s the 203k Streamline loan, or the 203k Standard loan, needs to be done differently than an offer to purchase using a conventional loan.

Here’s a few tips on how to present an offer using the 203k Standard loan.  1.  Submit a copy of an inspection report or a feasibility report prepared by a certified HUD 203k  Consultant.  2.  Include a detailed scope of work and repair estimate prepared by your 203k loan HUD Consultant.  3.  Get an Automated Underwriting Approval for an FHA 203k loan.   4.  Submit an offer with comps to support your offer.  My thanks to www.203kforum.com and member Vito Simone who is an experienced 203k loan Consultant and outlined these tips.

Submit the above four items listed above along with your purchase contract, which should also specify you are using an FHA 203k loan for financing.  This should demonstrate that you have done your homework and due diligence, and that there is no guessing on your part on how this loan works.

In regards to item one above, submitting an inspection report/feasibility report, in my opinion is key.  Getting this done up front takes away the guess work when buying an as-is property.  Could you submit your offer with an inspection contingency and not pay for the inspection upfront?  Sure.  But if it’s evident that the property needs work, usually your main competition is going to be investors buying cash.  Your offer should be better than a low ball cash offer, so spending the extra upfront money on the upfront inspection/feasibility report via the HUD Consultant would be worthwhile.

It’s also possible that if you lose out on your offer, the HUD Consultant may not charge you for your next home inspection if you lost out on your previous offer.  There may be room for negotiation there, and the  HUD Consultant for their intial home inspection/ feasibility report, charges about the same for their fee as a normal home inspector and they are highly qualified and understand the 203k loan nuances and know if the property will fit the 203k loan specifications which in general are pretty broad.  A normal home inspector can not do this, they look for different things than the HUD Consultant even though their jobs are similar.

Using people familiar with the 203k loan process is vital and that goes for contractors as well, but I’ll save that commentary for my next post.  This isn’t the only way to submit a 2o3k loan contract offer, but it’s a start in the right direction to show both the lender and listing Realtor you mean business and understand the process and hopefully they do some research on their own to understand this is a viable loan option that is only growing in popularity and needs to be accepted by all involved in the real estate process.

If you have a question in regards to the 203k loan or content of this letter, please let me know by clicking here!

The Investor 203k. It May Be Coming Back In The Future.

Salvatore Vuono Picture Credit

If you are an investor and have been buying homes cash and using your own money to fix up homes and resell them, you know that if you have multiple projects going at one time, that this can be trying.
What if you could use someone else’s money to do this? Would it reduce your risk exposure?
Yes it would. You may not have full control over the funds, but it can make sense for the many investors.

The 203k loan at one time allowed for investors. But due to fraud and a lack of oversight by HUD in general, the investor option was taken away and we are now left with the 203k Standard and the 203k Streamline for owner occupants.

However, there is a chance in the future that this may change. A key group of 203k Consultants went head to head with HUD late last year to present ideas on how to further update the 203k loan programs that would modernize things as well as fix some glaring problems.

One of the ideas of modernizing the 203k loan, was to once again allow investors to use the product.
Other ideas such as allowing for greater repair amounts for pools, more streamlined contractor approval rules, and possibly cutting back the 203k Streamline loan amount from $35,000 to $15,000. There were many other ideas discussed and we should know by March of 2011 if any or all the ideas are approved by HUD. We have to remember we are dealing with the government here so maybe it may be mid summer.

What other rules were attached to the investor 203k loan option? We won’t know until HUD roles out the updated 203k loan guidelines. But hopefully the government recognizes the fact that investors can help fix up some homes that aren’t in lending condition due to health and safety conditions or other damage.
It would help move housing inventory and improve neighborhoods.

It could be a win-win for all involved. So stay tuned and you want to find out if HUD has approved the 203k loans for investors, subscribe to my RSS Feed, and when I find out, I’ll post it and it’ll go straight to your inbox.

If you have a question in regards to this article please let me know by clicking here.

Best,
KW

PMI Is A Tax Deduction. Who Knew?

 

Pic Credit to Arvind Balaraman

PMI, also known as private mortgage insurance, is that pesky insurance that homeowners have to pay that protects the lender whether or not you are refinancing or buying a home and your first mortgage is greater than 80% of the appraised value.

For the better part of the last 10 years borrowers selected the first and second mortgage combination to finance their loan balances since the interest paid on the second mortgage could qualify as a tax deduction whereas PMI wasn’t deductible.

However, this is no longer true and hasn’t been since December 31st, 2006.  At first the tax break was to sunset December 31st, 2007, than it got extended through December 31st, 2010 and again it’s been extended through December 31st, 2011. The tax deduction isn’t available to all PMI insurance paying borrowers, there are income limitations.

Qualifying for the full deduction, would require a couple or a single taxpayer to have AGI of $100,000 or less and no more than $109,00 to get a partial deduction. A married individual who files separately must have AGI of $50,000 for the full deduction, or no more than $54,500 for a partial deduction.

In our existing lending environment PMI now plays a larger role since the second mortgage/HELOC market has contracted.  I have recently seen refinance borrowers, who want to take advantage of the low mortgage rates have to pay PMI on their new loan even though their previous loan(s) didn’t have PMI.  Why?  Low appraisals.  If the new loan is more than 80% of the appraised value, PMI is required.  Sometimes it makes sense to pay the PMI on a refinance, sometimes it doesn’t.

Turbo Tax states that the “typical” homeowner may realize a $350.00 tax deduction if they meet the income requirements as mentioned above. Typical is a rather general term but as long as the PMI or private mortgage insurance payer income falls under the income guidelines as noted above, they may be eligible for the tax deduction.

It’s important for current homeowners and future 203k loan applicants to know that FHA mortgage insurance is also eligible for the tax deduction.  PMI, private mortgage insurance, and FHA mortgage insurance both cover lender interests but are used in different loan scenarios.  FHA mortgage insurance is used in conjunction with FHA loans which includes the 203k.  PMI is used in conjunction with non-FHA loans such as conventional.

Will the PMI tax deduction carry over to 2012 and beyond?  Only time will tell and as usual as long as the government is making the decision, we won’t find out until December 31st of 2011.

Best KW