The local economic development corporation : legal and financial guidelines

목차 (Table of Contents)

• CONTENTS
• PART Ⅰ. ORGANIZING AN LEDC
• LEDCs MAY TAKE VARIOUS FORMS = 1
• Bibliography = 1
• THE LEDC AS BROKER-SPONSOR FOR LOCAL ECONOMIC DEVELOPMENT = 3
• The LEDC's Role as Broker-Sponsor = 3
• Checklist of activities = 3
• Alternative forms of organization = 4
• Bibliography = 4
• THE LEDC AS A SOURCE OF FINANCIAL ASSISTANCE = 5
• The Concept of Leverage = 5
• Local Development Companies(Section 502) = 5
• Small Business Investment Companies = 6
• Comparison of SBIC and Local Development Companies = 7
• Bibliography = 8
• LEDC AND OTHER SOURCES OF TECHNICAL AND MANAGERIAL ASSISTANCE AND MANPOWER TRAINING = 9
• Need for Assistance = 9
• Assistance for Minority Business Enterprise = 9
• Federal programs = 10
• National private sector commitments = 10
• Developing the local package = 10
• State OMBEs = 10
• Technical and Management Assistance = 10
• Small Business Administration = 11
• Economic Development Administration = 11
• Department of Labor = 11
• Department of Agriculture = 11
• Business Counseling = 11
• Establishment of a management assistance program by an LEDC = 11
• Complete supervision by a management firm = 13
• Professional businessmen's associations = 13
• On-The-Job Training for Managers =13
• Establishing a new business = 13
• Purchasing an existing business = 14
• Managerial training in larger businesses = 14
• Classroom Instruction for Managers = 14
• Federal Manpower Training = 15
• Bibliography = 16
• HOW AN LEDC MAY QUALIFY FOR TAX-EXEMPT STATUS = 17
• Steps in Qualifying Under Section 501(c)(3) = 17
• Organizational test = 17
• How to obtain IRS determination = 18
• Permissible Activities = 18
• IRS rulings = 19
• Prohibited Activities = 20
• "Action" organizations = 20
• "Public" charities and private foundations = 20
• Prohibited transactions = 21
• Other Tax Aspects = 22
• Form 990A(annual report) = 22
• Unrelated business income = 23
• Social Welfare Organizations = 23
• Bibliography = 23
• PRESERVING ARMS-LENGTH RELATIONSHIP BETWEEN NONPROFIT AND PROFITMAKING ENTITIES = 24
• Restrictions = 24
• Guidelines for avoiding potential conflicts of interest = 24
• ORGANIZING AN LEDC AS A NONPROFIT MEMBERSHIP CORPORATION = 26
• Shaping of Corporate Papers = 26
• Articles of incorporation = 26
• By-laws = 26
• Patterns for Participation = 27
• Membership restricted to residents = 27
• Alternatives to restricting membership to residents = 28
• Directors, advisory committees, employees = 28
• Role of Members in Policymaking = 28
• Election of directors = 28
• Other voting rights = 29
• Rights of inspection and other rights = 29
• Bibliography = 29
• PROFITMAKING CORPORATIONS IN WHICH EARNINGS ARE SHARED BY COMMUNITY RESIDENTS = 30
• Use of Stock Corporation Format = 30
• Choice of State of incorporation = 30
• Organizational papers = 30
• Potential Classes of Ownership Interest = 31
• Management personnel and other employees = 31
• Sponsoring organization or community action group = 31
• Members of the "poor" community = 31
• Other investors = 32
• Voting Control Within the Corporation = 32
• Community control of decisions = 32
• Liability of Directors and Officers = 33
• Community Advisory Groups = 33
• Bibliography = 33
• SETTING UP A COMMUNITY TRUST TO DISTRIBUTE PROFITS FROM AN LEDC-SPONORED BUSINESS = 34
• How Shall Profits Be Allocated? = 34
• Form of organization to be chosen = 34
• Checklist of factors to consider = 34
• Setting up a Community Trust = 34
• PART Ⅱ. KINDS OF LEDC-SUPPORTED ENTERPRISES
• SMALL BUSINESS INVESTMENT COMPANIES(SBICs) = 36
• What Is an SBIC? = 36
• Ownership and Control of SBICs = 36
• Leveraging the SBIC = 36
• The SBIC record = 37
• Types of SBIC Investments = 37
• Size of small businesses = 38
• Long-term loans = 38
• Equity and venture capital financing = 39
• Other permissible financings = 40
• Restrictions on SBIC Investments = 40
• Prohibited uses of funds = 40
• Conflicts of interest = 41
• Formation of an SBIC = 41
• Incorporation under State law = 42
• SBIC licensing procedures = 45
• Managerial requirements = 45
• Bibliography = 46
• ADVANTAGES AND DISADVANTAGES OF PROPRIETORSHIPS, PARTNERSHIPS, AND CORPORATIONS = 47
• Choice of Business Form = 47
• Sole Proprietorship = 47
• Partnership = 47
• Corporation = 48
• Tax Considerations = 48
• Fringe Benefits = 49
• Bibliography = 49
• PRESERVATION OF CORPORATE CONTROL BY MINORITY ENTREPRENEUR = 50
• The Problem of Control = 50
• Methods of Allocation = 50
• Classes of securities and voting rights = 50
• Stock options = 51
• Preemptive rights = 51
• Certificate of incorporation and by-laws = 51
• Community control of profit distribution = 51
• Bibliography = 51
• ACQUISITION OF EXISTING FIRMS = 52
• Problems Faced by the Buyer = 52
• Putting Together a Negotiating Team = 52
• Determining Whether the Acquiree Is a Good Business To Buy = 52
• Financial statements = 52
• Analyzing financial statements = 53
• Initial evaluation of the acquiree = 54
• Determining What Is a Fair Price = 54
• Structuring the Purchase(Non-Tax Considerations) = 55
• Advantages of stock acquisition approach = 55
• Disadvantages of stock acquisition = 55
• Advantages of asset acquisition approach = 55
• Disadvantages of asset acquisition = 55
• Structuring the Purchase(Tax Considerations) = 55
• Seller's profit as ordinary income or capital gains = 56
• Seller's tax basis for assets sold = 56
• Tax aspects of purchase of various business entities = 56
• Financing the Purchase = 57
• The down payment-the LEDC's role = 57
• Using notes in structuring a purchase = 58
• Contingent payouts = 58
• Bootstrap financing = 58
• Ensuring That the Acquiree Is What It Is Represented To Be = 59
• The purchase agreement = 59
• Representations and warranties = 59
• Seller's affirmative and negative covenants = 61
• Conditions precedent to the buyer's obligation to close = 61
• Closing = 61
• Indemnification and damages = 61
• Miscellaneous clauses = 62
• Handling Breach of Contract = 63
• Matters discovered prior to closing = 63
• Breach of contract after closing = 63
• Labor-Management Questions = 64
• Landlord's Right To Cancel Lease if Stock Ownership Changes Substantially = 64
• Retaining Existing Management Expertise = 64
• Retaining the seller as a co-owner = 64
• Use of an employment agreement = 65
• Relationship with the seller = 65
• Other management problems = 65
• Bibliography = 65
• FRANCHISED BUSINESSES = 66
• What Is Franchising and How Do You Use It? = 66
• LEDC should consider opportunities = 66
• Basic franchising relationships = 66
• Advantages of a franchise for the minority businessman = 66
• Disadvantages of a franchise for the minority businessman = 67
• Stimulating Establishment of Minority-Owned Franchises = 67
• Locating, Selecting, and Qualifying for the Franchise = 68
• Sources of information and their use = 68
• Initial communications with the franchisor = 69
• Selecting the franchise = 69
• Checklists for Selecting the Franchise = 69
• Cost of a Franchise = 70
• Financing the Franchise = 71
• Negotiating Key Contract Terms = 71
• Cancellation or termination of the franchise = 71
• Sale or transfer of the franchise : limitation, valuation, and taxation = 72
• Bibliography = 73
• COOPERATIVES = 74
• What is a Cooperative = 74
• Co-ops compared with corporations = 74
• Rochdale principles = 74
• Changes in usage for the low-income co-op = 74
• Forms of Cooperatives = 75
• Consumer cooperatives = 75
• Producer cooperatives = 76
• Service cooperatives = 76
• Operational Attributes and Problems of Cooperatives = 76
• Incorporation = 77
• Out-of-State cooperatives = 78
• Roles of board and management = 78
• Taxation of cooperatives = 78
• Distribution of earnings = 79
• Initial capital = 79
• Bibliography = 80
• THE CHAIN-INDEPENDENT RETAIL STORE = 81
• The Concept = 81
• The Structure = 81
• The technical assistance organization = 81
• Wholesaler = 81
• Management company = 81
• Local development company = 83
• Retailer = 83
• Advantages to the Parties = 83
• Retailer = 83
• Wholesaler = 84
• Technical assistance organization = 85
• Community = 85
• Comparison With Other Forms of Business Operation = 86
• Expansion of the Concept Into Other Fields = 86
• SHOPPING CENTERS = 88
• The Opportunity = 88
• Types of Shopping Centers = 88
• Economics of Shopping Centers = 88
• The prime factor-location = 88
• Initial financing needs = 89
• Local Financing Source To Be Considered = 90
• Putting the Tenants Together = 90
• Legal Pitfalls in Acquiring the Site = 90
• Zoning = 90
• Utilities = 90
• Building and fire codes = 91
• Test borings = 91
• The Mortgage Application = 91
• The Shopping Center Lease = 91
• Where To Seek Help = 91
• International Council of Shopping Centers = 91
• Urban Land Institute = 92
• Joint venture with experienced developer = 92
• Tie-in with major chain = 92
• Bibliography = 92
• HOUSING PROJECTS = 93
• The Impact of Housing Projects on the Community = 93
• How To Develop a Housing Project = 93
• The development team = 93
• The need for seed money = 94
• The project site = 94
• Selection of financing program and sponsor = 95
• Mortgage processing = 96
• Federal Financing Programs Under HUD = 98
• "Workable program" prerequisite = 98
• Public housing for low-income families = 98
• Housing for middle-, moderate-, and lower-income families = 99
• FHA programs = 99
• Rehabilitation loans = 103
• Other housing programs = 103
• Urban renewal = 103
• State and Local Programs = 105
• Real property tax abatement = 106
• Land acquisition and write-down = 106
• Seed money and technical assistance = 106
• Below-market interest rate mortgage loans = 107
• Rehabilitation process = 107
• Housing development corporations = 107
• Special assistance program = 107
• Opportunity for Local Contractors = 107
• Legislative and other support = 108
• Bonding programs = 108
• Bibliography = 109
• INDUSTRIAL PROJECTS INVOLVING OUTSIDE CORPORATIONS = 110
• Role of the LEDC = 110
• Projects may take several forms = 110
• Subsidiary or Division Approach = 110
• Organization = 110
• Qualification = 110
• Minority representation = 111
• Taxation = 111
• Outside financing = 111
• Management = 111
• Liability of parent for subsidiary's obligations = 111
• Joint Ventures = 111
• Organizational formalities = 112
• Limitation of liability = 112
• Continuity and permanence of enterprise = 112
• Transferability of interests = 112
• Availability of financing = 113
• Ownership and control = 113
• Tax considerations = 114
• Contract Approach = 116
• Guaranteed market = 116
• Subcontracts = 117
• Rendering managerial, marketing, financial, or technical assistance = 117
• Loans and guarantees = 117
• Additional Considerations = 118
• Ultra vires and corporate waste = 118
• Restrictions in corporate legal documents = 118
• Labor relations problems = 118
• Reverse discrimination = 118
• Property acquisition = 119
• Bibliography = 119
• PLAN FOR EMPLOYEE PARTICIPATION IN OWNERSHIP OF A LARGE CORPORATION = 120
• The LEDC as Sponsor of the Plan = 120
• Assumptions = 120
• Benefits to the employer = 120
• Who contributes to the plan? = 120
• The risk of loss = 120
• Qualifying for tax advantages = 121
• When are benefits vested and distributed? = 121
• Employee participation in plan management = 121
• Who manages the plan? = 121
• Leveraging by an Employee Plan = 122
• Choosing the Plan = 122
• Alternative plans for distribution = 123
• Stock bonus plan = 123
• Stock option plan = 123
• Donative transfer of stock = 123
• Profit-sharing plan = 124
• Employee savings plan = 124
• PART Ⅲ. FINANCING THE LEDC AND RELATED ORGANIZATIONS
• ELEMENTS OF SOUND FISCAL MANAGEMENT NEEDED TO OBTAIN FINANCING = 126
• Requirements of Sound Fiscal Management = 126
• Planning = 126
• Budgeting = 126
• Controlling = 126
• Reporting = 127
• Financial Statements = 127
• The Importance of Fiscal Management = 127
• Bibliography = 127
• TAX ASPECTS OF SEEKING FUNDS FOR LEDC ACTIVITIES = 128
• Tax Aspects of Seeking Funds That Need Not Be Repaid = 128
• Tax savings as an inducement for contributions = 128
• Business deductions as an inducement for contributions = 128
• Tax Aspects of Seeking Repayable Funds = 129
• Bibliography = 132
• FOUNDATIONS AS A SOURCE OF INITIAL GRANT FINANCING = 130
• Grant Funds = 130
• Sources of Information on Foundations = 130
• How To Draft a Proposal = 130
• Form of the proposal = 130
• Sample checklist for grant proposals = 131
• Management Evaluation = 131
• Multiplier Effect of Grant = 131
• Follow-Ups = 132
• Foundation Diversity = 132
• Bibliography = 132
• FOUNDATIONS AS A SOURCE OF LOANS AND EQUITY CAPITAL = 133
• Basis for Investment by Foundations = 133
• Examples of Foundation Activity = 133
• Evaluation of Potential Investments = 133
• Relationship to program goals = 133
• Financial criteria = 134
• Terms of Investments = 134
• Specific charitable purpose of investment = 134
• Restrictions on use of funds = 134
• Requirements for reports = 134
• Some Guidelines for Preparing Investment Proposals = 134
• CHURCH GROUPS AS A SOURCE OF FUNDS = 135
• Church Activity = 135
• Analysis of Existing Investment Programs = 135
• Criteria for investment = 135
• Loans = 136
• Loans combined with equity = 136
• Other forms of investment = 137
• Efforts by Individual Churches = 137
• Combination grant and equity = 137
• Housing sponsorship = 137
• New Organizations Channeling Interfaith Efforts = 137
• FEDERAL SOURCES OF FINANCIAL ASSISTANCE = 138
• Sources of Information on Federal Programs = 138
• OEO Special Impact Grants = 138
• Qualification for special aid = 138
• Operation of the Special Impact program = 139
• Use of Special Impact funds = 139
• Assistance Under the Public Works and Economic Development Act = 139
• Redevelopment areas = 140
• Title I areas = 140
• Loans from EDA in Redevelopment Areas = 140
• Grants and loans for public works and development facilities = 141
• Technical assistance = 141
• Model Cities Program = 141
• SBA Loan and Guarantee Programs = 141
• Local development companies(Section 502) = 141
• Small Business Investment Companies(SBICs) = 141
• SBA regular business loan program = 141
• Economic Opportunity Loans = 142
• SBA lease guarantees = 143
• Veterans Administration Loan Guarantees = 143
• Bibliography = 143
• Annex-Opportunity Funding Corporation = 143
• STATE AND LOCAL GOVERNMENTAL SOURCES OF FINANCING = 145
• Access to Funds Tied to a Public Purpose = 145
• Federal restrictions on the use of industrial revenue bonds = 145
• Use of tax-exempt bonds to finance local economic development = 145
• Uses of the Funds = 145
• Improvement of basic facilities in the community = 146
• Attracting private industry into the community = 146
• Redeveloping land use in the community = 146
• Redevelopment of new communities = 146
• Legal Approaches to the Issue of Tax-Exempt Bonds = 147
• Issue of bonds by public development corporations = 147
• Issue of bonds by political subdivision = 148
• Issue of bonds by a State industrial development authority = 148
• Other State Sources of Financing for Business Operation and Plant Construction = 148
• State-chartered business development corporations = 148
• State industrial development authorities = 149
• STOCK ISSUES AS A SOURCE OF FUNDS = 150
• Sale of Stock To Finance LEDC Activities = 150
• Disclosure problems regarding the high-risk situation and unsophisticated investors = 150
• SEC and blue sky law requirements = 150
• Exemptions Under the Securities Act = 150
• Private placement of an issue = 150
• Intrastate offering exemption = 151
• Securities issued by nonprofit corporations = 152
• No sale distribution of corporation's stock = 152
• Use of Regulation A by an LEDC = 152
• Advantages of a Regulation A offering = 153
• Filing requirements = 153
• Sale of securities by corporation = 153
• Simplified registration for smaller offerings = 153
• Sanctions = 154
• Methods of marketing and costs of placement of Regulation A issues = 154
• Application of the Securities Exchange Act = 155
• Antifraud provisions = 155
• State Regulation of Stock Issues = 156
• Broker-dealer registrations = 156
• Securities registration exemptions = 157
• Registration procedures = 158
• Bibliography = 158
• INSTITUTIONAL SOURCES OF LONG-TERM LOANS = 159
• Private Sources of Long-Term Financing = 159
• Types of Institutions = 159
• The Insurance Industry Commitment = 160
• Participating companies = 160
• Forms of investment = 160
• Procedures that induce insurance company investment = 161
• Security and Collateral Requirements = 162
• Real property = 162
• Personal property = 162
• Legal Restrictions on Institutional Loans = 162
• Federal banking law = 162
• Federal Home Loan Bank = 163
• New York State restrictions on bank loans = 163
• New York State restrictions on loans of insurance companies = 163
• Legal Steps in Securing Financing = 164
• Terms to be discussed = 164
• Provisions in loan agreement = 164
• Procedural steps in obtaining financing from lender = 165
• COMMERCIAL BANKS AS A SOURCE OF SHORT-TERM AND MEDIUM-TERM LOANS = 166
• Use of Commercial Bank Financing = 166
• Forms of financing available = 166
• Necessity for guarantee = 166
• Setting Up a Bank Pool Arrangement = 167
• Establishing a service organization to make a commercial cooperative loan fund work = 167
• Implementing the concept = 167
• Agreement by commercial banks to pool losses = 167
• Interest rates and term of loan = 167
• Sources of funds for JLC operations = 167
• Forms of community representation on board and staff of corporation = 168
• Day-to-day operations = 168
• Rejection of loan application = 168
• Delinquency and defaults = 168
• Business assistance = 168
• Long-term commercial mortgages = 169
• Commercial real estate mortgage lending procedure = 169
• JLC fulfills a temporary need = 169
• Setting Up a Group of Outside Guarantors = 169
• 501(c)(3) organization = 169
• Credit pool = 170
• Commercial bank or banks = 170
• Use of guarantee between 501(c)(3) organization, credit pool, and bank = 170
• Loan Guarantee Approaches for an LEDC = 170
• Provision of a guarantee by an LEDC = 170
• Terms of a gurantee by an LEDC = 171
• SBA Loan Gurantee Program as Community Model = 172
• Closing of loan transaction = 172
• Servicing of loan = 172
• Guarantee fee = 172
• Payment upon default = 172
• FINANCING WITH COMPANY ASSETS = 174
• Sources of Short-Term Credit = 174
• Commercial banks = 174
• Finance companies = 174
• Seller credit = 175
• Factors = 175
• SBlCs, the SBA, and other government agencies = 175
• Participations and multiple financing = 175
• Elements Common to All Forms of Secured Credit = 175
• Amount of credit and terms of repayment = 175
• Finance charge = 176
• Other charges = 176
• Usury = 176
• Disclosure statutes = 176
• Restrictive covenants = 177
• Guaranties, endorsements, and comakers = 177
• Debt subordination = 177
• Purchase money financing = 177
• Real Estate Financing = 177
• Second mortgage financing = 177
• Leasehold financing = 178
• Equipment Loans = 178
• Requirements for closing of typical equipment loan = 178
• Form of security agreement for equipment loan = 179
• Perfection of the lender's security interest = 179
• Accounts Receivable Financing = 179
• Factoring = 179
• Commercial financing = 180
• Intangibles Financing = 181
• Installment Purchase of Equipment = 181
• Inventory Financing = 182
• Leasing = 182
• Lease vs. conditional sale contract = 182
• Accounting practice = 182
• Investment tax credit = 183
• The true cost of leasing = 183
• Sale and leaseback = 183
• USE OF LEASE GUARANTEES = 184
• Need for Lease Guarantees = 184
• Beneficiaries of lease guarantees = 184
• SBA Lease Guarantee Program = 184
• Participation by private insurance companies = 185
• Eligibility of Tenants = 185
• Landlord-tenant relationship = 185
• Qualifications for determining specific tenant eligibility-risk rating system = 185
• Terms of Program = 186
• Procedure for coverage = 187
• Bibliography = 187
• APPENDIXES
• THE LEDC AS BROKER-SPONSOR FOR LOCAL ECONOMIC DEVELOPMENT
• Sample Loan Agreement Between an LEDC and a Sponsored Business = 190
• LEDC AND OTHER SOURCES OF TECHNICAL AND MANAGERIAL ASSISTANCE AND MANPOWER TRAINING
• Volunteer Consultant Registration Form = 192
• General Information and Instructions for the Volunteer Consultant = 192
• Checklist for Preliminary Interview : Information Required = 193
• Description of Company and Purpose of Loan = 193
• HOW AN LEDC MAY QUALIFY FOR TAX-EXEMPT STATUS
• Sample Certificate of Incorporation of an LEDC = 194
• Exemption Application(IRS Form 1023) = 196
• IRS Determination Letter Issued by District Director = 200
• ORGANIZING AN LEDC AS A NONPROFIT MEMBERSHIP CORPORATION
• Certificate of Incorporation Under the Model Non-Profit Corporation Act = 202
• Certificate of Incorporation Under Present N.Y. Membership Corporation Law = 202
• Certificate of Incorporation for a Local Development Corporation Formed Under the N.Y. Not-For-Profit Corporation Law, Effective September 1, 1970 = 204
• Articles of Incorporation of a Job Development Corporation Pursuant to the California Job Development Corporation Law = 205
• Certificate of Incorporation of a Local Development Corporation Formed Under Section 1411 of the N.Y. Not-For-Profit Corporation Law = 205
• PROFITMAKING CORPORATIONS IN WHICH EARNINGS ARE SHARED BY COMMUNITY RESIDENTS
• Agreement To Form a Corporation = 206
• Suggested Form of Certificate of Incorporation for a Local Development Company Eligible To Apply for a Loan Under Section 502 of the Small Business Investment Act of 1958, as Amended = 207
• SMALL BUSINESS INVESTMENT COMPANIES(SBICs)
• Questionnaire for Borrower = 209
• Checklist for SBIC Staff = 212
• Small Business Administration License Application = 213
• Minutes of Organization Meeting = 218
• Minutes of First Meeting of Directors = 219
• THE CHAIN-INDEPENDENT RETAIL STORE
• Checklist of Terms of Lease Purchase Agreement Between Local Economic Development Company(Landlord) and Individual Member Store Operator(Tenant) = 223
• Agreement Between Supplier and Management Company = 223
• Checklist for Provisions of Management Agreement Between Management Company and Individual Member Store Operator = 223
• SHOPPING CENTERS
• Checklist of Factors in Developing a Shopping Center = 224
• PLAN FOR EMPLOYEE PARTICIPATION IN OWNERSHIP OF A LARGE CORPORATION
• Model Plan for Employee Benefit Program = 227
• FOUNDATIONS AS A SOURCE OF LOANS AND EQUITY CAPITAL
• Sample Social Investment Requirement = 227
• Sample Preliminary Letter Agreement = 228
• Sample Restrictions = 228
• Forms of Investment = 229
• Sample Administrative Agreement = 229
• CHURCH GROUPS AS A SOURCE OF FUNDS
• Guide Sheet for Loan Application from MELIC = 229
• Names and Addresses of Religious Organizations That Provide Funds for Investment = 230
• STATE AND LOCAL GOVERNMENTAL SOURCES OF FINANCING
• List of State Business Development Corporations = 231
• STOCK ISSUES AS A SOURCE OF FUNDS
• Information To Be Included in Regulation A Offering Circular = 232
• Outline of a Prospectus(or Offering Circular) for an Intrastate Offering = 235
• INSTITUTIONAL SOURCES OF LONG-TERM LOANS
• Long-Term Debt Financing = 236
• A Form of Note = 245
• COMMERCIAL BANKS AS A SOURCE OF SHORT-TERM AND MEDIUM-TERM LOANS
• Letter Agreement Blanket Loan Guaranty = 245
• Guaranty(Between Member of Credit Pool, Commercial Bank, and 501(c)(3) Organizations) = 246
• Limited Power of Attorney = 246
• Blanket Loan Guaranty Agreement Between〔LEDC〕and Lender = 247
• Application for Loan Under Blanket Guaranty = 249
• Authorization of Loan Guaranty = 249
• USE OF LEASE GUARANTEES
• Application for Lease Guarantee(Lessee Requirements) = 250
• Application for Lease Guarantee(Lessor's Requirements) = 254