As part of this transaction, New Directions, with the legal guidance of Stites & Harbison, engaged in a HUD Mark-to-Market ("M2M") process which was initiated through the Office of Multifamily Housing Assistance Restructuring ("OHMAR") pursuant to the Multifamily Assisted Housing Reform and Affordability Act of 1997. The M2M process restructured the rents and first mortgage amounts relating to the projects while providing a stabilizing reserve for replacement that will ensure the future financial stability of the projects. The existing mortgages were also paid off and restructured through new HUD-insured mortgages provided by Red Mortgage Capital, Inc., under the FHA Section 223(a)(7) Program.