1.  The OMB form noncritical repair certification form HUD-92117-ORCF (Rev. 03/13) is designed for situations where repairs are made post-closing.   In situations where repairs are made prior to closing, it is probably more appropriate to delete Section 2, 4, 6 and 7.    It would also be easier if Section 3 permitted an Exhibit A to be attached for invoices and photos in addition to the list of repairs.
 
Procedurally, should I be submitting this OMB form revision request through the 232 DocumentFAQ request or is this a Carol Jun/ HQ review request?

 

 

 

 

 

If the repairs are made prior to closing and an escrow per se is not required, this document becomes more of a certification and has very little legal concern.  Should ORCF approach field counsel for a suggested way to document completion of such repairs, your suggested revisions are one acceptable approach.  Because of the limited legal interests in this scenario, there is no need to pro-actively approach ORCF on this matter.