USDA ..t..

-s:
Un....................... of AgrIcuIt...
...... Development
State OffIce
June 15, 2007
Stephen A. LaRoque, Executive Director
Piedmont Development Company, Inc.
POBox 1034
2213 Hull Road Suite 8
Kinston, NC 28503
Re; Hilton Partnership
Dear Mr. LaRoque:
We have reviewed the 5150,000.00 loan request submitted by Mark Hilton- individual and Tony
Hilton - individual for the purpose of fmancing working capital for real estate leasing business. The
business will retain 2 and create 1 jobs residents in Catawba and surrounding counties.
Based on the infonnation provided, the total project cost is 5205,000.00. This project includes working
capital needs and unit acquisition in the amount of 5205,000.00. This represents 1000.4 ofthe project
cost.
Therefore, the Intennediary Relending Program loan in the amount of$lJv.
'
VV\.1"vv
ECDC-RLF in the amount of525,OOO.OO (12.19%) and applicant contribution
will constitute 100% ofthe project cost. This also meets the 75125 criteria U"'..;"'AA ....,.,.
4274-D section 331 (b) (2).
The project based on the infonnation submitted has been classified as a Categorical Exclusion
and all applicable certifications have been received .
.wo6 Bland Road, Suita 280 Raleigh. North Carolina 27609
Phone: (019) 8734000 Fax: (018) TDD: (818) 873-2003 Web:
Commltlild to the Mute of nal CXII'JII1unHIeL
I
'l '.,
,
Please provide our office with the applicable copies of the loan documents immediately after the loan
for Mark Hilton- individual and Tony Hilton - individual has been closed.






Sincerely,
GEORGE L. VITAL
Business Program Specialist
Attachments
PDC
Piedmont Development Company, loc. PO Bos 1034 Kinston, N.C. 18503
Phone 251-527-3399 Fax 151-517-3799
June 15, 2007
Mr. George Vital
USDA Rural Development
Suite 260
4405 Bland Road
Raleigh, NC 27609
Dear Mr. Vital:
Re: Hilton Partnership
I am submitting documentation for a $150,000.00 IRP loan request by Hilton Partnership. This
is a real estate investment partnership located at 1351 Northern Drive. Conover, Catawba
County, NC. Loan funds will be used for the purchase of 41 mobile home rental units. This
loan will accompany an additional loan from ECDC for $25,000.00. These loans will account for
85% of the total project costs. The borrower is Hilton Partnership. They have been in this
business since2002. This loan will create one new job and save two existing jobs for a total of
three jobs. .




The project is located in and will serve a rural area as defined by Rural Business Cooperative
Service. The proceeds will be used for an eligible project that complies with Rural Business
Cooperative Service statutes, and regulations. We have determined that no conflict of interest
exists between the borrower, Rural Business Cooperative Service, and East Carolina
Development Company, Inc.
The Board of Directors of Piedmont Development Development Company, Inc. has approved
this loan as submitted to
amount of $150,000
new job.
I am on this loan to the applicant in the
five years. This loan will help create 3
Sincerely,
East carolina Development Company, Inc. is an equal opportunity lender.
IRP-16
Stephen LaRoque
Executive Director
enclosures
East Carolina Development Company. Inc. is an equal opportunity lender.
IRP16
o
o
.'
FORM 1940 - 20
C. 117 (6)
REQUEST FOR ENVIRONMENTAL INFORMATION
Project Name _____ ______
Location 1351 Northern Drive, Conover, NC
Item 1a. Has a Federal, State, or Local Environmental Statement or Analysis been prepared for
this project 0 Yes No
1b. If "No", provide the information requested in instructions as EXHIBIT I.
Item 2. The State Historic Preservation Officer (SHPO) has been provided a detailed project
description and has been requested to submit comments to the appropriate FmHA Office.
Yes @ Date description submitted to SHPO
(...J
eJ
f"k'"1 ay,ittf
Item 3. Are any of the following land uses or environmental resources either to be effected by the
proposal or located within or adjacent to the project site(s)? (Check appropriate box for
every item of the checklist).
Yes No Unknown
1 Industrial
0
Iv!
0
2 Commercial
0 0 0
3 Residential [2j
0 0
4 Agricultural
0
[2J
0
5 Grazing
0
Iv!
0
6 Mining, Quarrying
0 0 0
7 Forests
0
I vi
0
8 Recreational
0
Ivl
0
9 Transportation
0 U2J 0
10 Parks
0 ua 0
11 Hospitals
0 U2J 0
12 Schools
0
Ivl
0
13 Open Spaces
0
Ivl
0
14 Aquifer Recharge Area
0
Ivl
0
15 Steep Slopes
0 U2l 0
16 Wildlife Refuge
0
Iv!
0
17 Shoreline
0 0 0
o
Yes No Unknown
18 Beaches
D 0 D
19 Dunes
D
[2J
D
20 Estuary
D G2J D
21 Wetlands
D
Ivl
D
22 Floodplain
D
Ivl
D
23 Wilderness
D ~ D
(designated or proposed under the Wilderness Act)
24 Wild or Scenic River
D ~ D
(proposed or designated under the Wild and
Scenic Rivers Act)
25 Historical, Archeological Sites
D ~ D
(Listed on the National Registry of Historic Places
or which may be eligible for listing)
26 Critical Habitats
D
[Z]
D
(endangered/threatened species)
27 Wildlife
D
[2]
D
28 Air Quality
D
Ivl
D
29 Solid Waste management
D
[ZJ
D
30 Energy Supplies
D
[0
D
31 Natural Landmark
D ~ D
(Listed on National Registry of Natural Landmarks)
32 Coastal Barrier Resources System
D 0 D
Item 4. Are any facilities under your ownership, lease, or supervision to be utilized in the
accomplishment of this project, either listed or under consideration for listing on the
Environmental Protection Agency's list of Violating Facilities?
DYes IXI No
~ ~
OS/24/07
~ M a r k Hilton (Date)
o
Position 3
USDA-FmHA
1. Description
Form FmHA 1940-22 a. Name of Project:
(Rev. 6-88)
Hilton Partnership
b. Project Number:
Piedmont Development
ENVIRONMENTAL CHECKLIST FOR RBEGIIRP
CATEGORICAL EXCLUSIONS
c. Location:
Conover, NC
2. Protected Resources
For the below listed land uses or environmental resources, the undersigned
has checked Column A to indicate those that are present within the site(s) of the
proposed action. Column B has been checked for those that are within the
action's area of environmental impact, such as the areas adjacent to the
proposed site(s). Column C has been checked for those land uses and environ
mental resources that will be affected by the proposed action, as defined in
Section 1940.317. (Check appropriate box or circle, as provided. If a check
appears in any circle in column A, B, or C, the environmental assessment for
a Class I action must be completed).
a. Wetlands .........................................................................................
b. Floodplains with existing structure( s) ............... __ .................... __ . __ .. __ ...... _
c. Floodplains without existing structure(s)
d. Wilderness (designated or proposed under the Wilderness Act) ..... ______.... __ .
e. Wild or Scenic River (proposed or designated under the Wild and .................
Scenic Rivers Act)
f. Historical, Archeological Sites (listed on the National Register
Historic Places or which may be eligible for listing)
g. Critical Habitat or Endangered/Threatened Species (listed or proposed) .. __ ..
h. Coastal Barrier included in Coastal Barrier Resources System ..................._
Natural Landmark (listed on National Registry ofNatural Landmarks) .........
j.
Important Farmlands .. __ .. _ ...... __ . __ ....___.................. _...... __ .. __ .................... _
k. Prime Forest Lands... _ ........................................ ___........ ___ ........ ____ .... __
I. Prime Rangeland ............. --..................- ......----- ...... - ................. - .....
m. Approved Coastal Zone Management Area __ ....................... __ ................ __
n. Sole Source Aquifer Recharge Area ......................................................
(designated by Environmental Protection Agency)
o. State Water Quality Standard .............................................................
.A..
Located on
Proposed
Site(s)
Yes No
0 ~
0 ~
0 ~
0
~
0
~
0
0
~
0 ~
0 ~
0 ~
0 ~
0 ~
0
~
0
~
.a .c.
Located within Affected by
Actions's Area of
Proposed
Environmental
Impact
Action
Yes No Yes No
0 ~ 0 ~
0 ~ 0
~
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0 ~
0 0
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0 ~
0 ~ 0
~
0 ~ 0 ~
0
..
Page 2
o
3. Compliance With Highly Erodible Land and Wetland Conservation Requirements
DYes No This action is subject to the highly erodible land and wetland conservation requirements contained in Exhibit
M of FmHA Instruction 1940-G.
If "yes' is checked, complete (a), (b), (c), and (d).
a. Attached as Exhibit __ is a completed Form SCS-CPA-026 which documents the following:
DYes D No Highly erodible land is present on the farm property.
DYes D No Wetland is present on the farm property.
DYes D No Converted wetland is present on the farm property.
b. DYes D No This action qualifies for the following exemption allowed under Exhibit M:
c. DYes D No The applicant must complete the following requirements prior to approval of the action in order to retain or
regain its eligibility for FmHA financial assistance:
d. 0 Yes D No Under the requirements of Exhibit M, the applicant's proposed activities are eligible for FmHA financial
assistance.
4. Finding
This proposal meets, in terms of its size and components, the criteria for a categorical exclusion as defined in Sections 1940.3 10
and 1940.317. As indicated in item 2 above, the proposal does not affect any important land uses or environmental resources
th ould subject it ion as a categorical exclusion. Finally, the proposal is neither a phase nor segment of a pro-
j ieh when vi ();:,e " mee"h"equi.emen" of a catogo.ieal oxclusion pc< Section 1940 .317 (d).

(*Signature of Preparer)
George L. Vital- Business Program
Speciali t
(Date)
Zeb Steven Byrd - Director- Business Coop. Services
(Title)
* See Section 1940.302 for listing of FmHA officials authorized to prepare this form. See Section 1940.316 for when a concurring official's signature is
required and who is authorized to sign as the concurring official. 'US.GPO 1995.655.009122512
C.114
o
NO CONFLICT OF INTEREST
BETWEEN
PIEDMONT DEVELOPMENT COMPANY, INC.
AND
HILTON PARTNERSHIP
Piedmont Development Company, Inc., and its principal officers, including immediate family holds
no legal or financial interest or influence in the ultimate recipient. Hilton Partnership
The ultimate recipient. Hilton Partnership . its principal officers. including
immediate family, hold no legal or financial interest in Piedmont Development Company. Inc.
Stephen LaRoque, Executive Director
Piedmont Development Company. Inc.
Mark Hilton
Hilton Partnership
05/24/07
(Date)
o
BANK REJECTION ANDIOR COMMITMENT LETTER
HILTON PARTNERSHIP
"The loan is not otherwise available on reasonable (Le., usual and customary) rates and terms from
private sources or other Federal, State or local program$. The intermediary and ultimate recipient
are unable to finance the proposed project from their own resources or through commercial credit
or other Federal, State, or local programs at reasonable rates and terms."
Bank Rejection Letters from:
CAPITAL BANK
BANK OF GRANITE
Mark Hilton
05/24/07
(Date)
Stephen LaRoque, Executive Director
05/24/07
(Date)
o
RIGHT TO REQUEST SPECIFIC REASONS FOR CREDIT DENIAL
May 29,2007
RE: Commercial Loan Request
Application Date: April 25, 2007
Amount: $205,000.00
Purpose: To purchase 41 mobile homes
Collateral: 41 individual mobile homes
Dear Mark Hilton:, :'.
Thank you for applying to us for the above referenced loan request. After carefully reviewing your
application, we are sorry to advise you that we cannot grant a loan to you at this time.
If you would like a statement of specific reasons why your application was denied, please contact our
compliance officer at the address listed below. We will provide you with the statement of reasons within
30 days after receiving your request.
Capital Bank
Attn: TERESA GRIGSBY
333 Fayetteville Street, Suite 400
Raleigh, NC 27601
(919) 645-6370
D We obtained information from a consumer reporting agency as part of our consideration of your
application, its name, address, and toll free number is listed below. The reporting agency played no
part in our decision and is unable to supply specific reasons why we have denied credit to you. You
have the right under the Fair Credit Reporting Act to know the information contained in your credit file
at the consumer reporting agency. You have a right to a free copy of your report from the reporting
agency, if you request it no later than 60 days after you receive this notice. In addition, if you find that
any information contained in the report you receive is inaccurate or incomplete, you have the right to
dispute the matter with the reporting agency. You can find out about the information contained in your
file by contacting:
D Equlfax Consumer Relations D Experlan D TransUnlon
P.O. Box 740241 P.O. Box 2002 P.O. Box 1000
Atlanta, GA 30374 Allen, TX 75013 Chester, PA 19022
(800) 685-1111 (888) 397-3742 (800) 888-4213
www.eguifax.com www.experian.com www.transunion.com
[K] Our credit decision was based In whole or in part on information obtained from an affiliate or from an
outside source other than a consumer reporting agency. Under the Fair Credit Reporting Act, you have
the right to make a written request, no later than sixty (60) days after you received this notice, for
disclosure of the nature of this information.
Name: M. Kent Walker Title: Commercial Relationship Mgr.
EQUAL CREDIT OPPORTUNITY ACT NOTICE
The federal Equal Credit Opportunity Act prohibits creditors from discrimination against credit applicants
on the basis of race, color, religion, national origin, sex marital status, age (provided the applicant has the
capacity to enter into a binding contract); because all or part of the applicant's income derives from any
public assistance program; or because the applicant has in good faith exercised any right under the
Consumer Credit Protection Act. The federal agency that administers compliance with this law
concerning this creditor is:
FDIC Consumer Response Center
2345 Grand Ave
Suite 100
Kansas City, MO 64108
o NOTICE OF ACTION TAKEN {}
PRINCIPAL FOR CREDIT DENIAL, TERMltIn"ION, CHANGE
OR OTHER ACTION TAKEN CONCERNING CREDIT
BANK OF GRANITE Date 5/29/07
Address
PO Box 1567
Conover NC 28613
Applicant Mark K Hilton NOTICE: The federal Equal Opportunity Act prohibits creditors from discriminating
Applicant
against credit applicants on the basis of race, color, religion, national origin, sex,
Mailing Address
City. State. Zip
1351 Northern Dr NW
Conover NC 28613
marital status, age (provided the applicant has the capacity to enter into a binding
contract); because all or part of the applicant's income derives from any public
assistance program; or because the applicant has in good faith exercised any right
under the Consumer Credit Protection Act. The federal agency that administers
compliance with this law concerning this creditor is
Federal Deposit Insurance Corporation
Consumer Response Center
2345 Grand Boulevard, Suite 100
Kansas City, Missouri 64108
Thank you for your application.
Description of Account, Transaction, or Requested Credit Loan to purchase mobile homes
Based on your application. we must inform you that
o We are unable to make a decision on your application because the following information is missing
Please provide the requested information to us by so that we may give your application further consideration.
o We are unable to offer you credit on the terms that you requested. We can, however, offer you credit on the following terms
If this offer is acceptable to you, please notify us by
[8] We regret that we are unable to approve your request for the following reason(s):
o Credit application incomplete 0 Length of employment o No credit file
o Insufficient number of credit 0 Unable to verify employment o Limited credit experience
references provided 0 Temporary or irregular employment o Poor credit performance with us
o Unacceptable type of credit 0 Unable to verify income o Delinquent past or present credit obligations
references provided 0 Income inSUfficient for amount with others
o Unable to verify credit references of credit requested o Garnishment, attachment, foreclosure, repossession,
o Length of residence 0 Excessive obligations in relation collection action or judgement
o Temporary residence to income o Bankruptcy
o Unable to verify residence 0 Sufficient unsecured credit for o Slow or past due in trade or loan payments
reported income
[8] Value or type of collateral not sufficient
o Other, specify
If you have any questions regarding this notice, you should contact Vicki A Lovett
Telephone 828-464-4539
o Our credit decision was based in whole or in part on information obtained in a report from the consumer reporting agency listed below. You have a
right under the Fair Credit Reporting Act to know the information contained in your credit file at the consumer reporting agency. The reporting agency
played no part in our deCision and is unable to supply specific reasons why we have denied credit to you. You also have a right to a free copy of your
report from the reporting agency. if you request it no later than 60 days after you receive this notice. In addition, if you find any information contained in
the report that you receive is inaccurate or incomplete, you have the right to dispute the matter with the reporting agency.
Name: EaUIFAX CREDIT INFORMATION SERVICES, INC.
Address: 1150 Lake Hearn Drive Suite 460, Atlanta, GA 30374-0241
Telephone: 1-800-685-1111
o Our credit decision was based in whole or in part on information obtained from an affiliate or from an outside source other than a consumer reporting
agency. Under the Fair Credit Reporting Act, you have the right to make a written request, no later than 60 days after you receive this notice, for
disclosure of the nature of this information.
o NOTICE OF RIGHT TO RECEIVE COPY OF APPRAISAL
You have the right to a copy of the appraisal report used in connection with your application for credit. If you wish to receive a copy, please write to us at
the mailing address we have provided. We must hear from you no later than 90 days after we notify you about the action taken on your credit
application or your withdrawal of your application. In your letter, include the following information: date of application, name(s) of loan applicant(s).
property address, and your current mailing address.
o
FORM 1940 - Q
LOBBYING FORM
BETWEEN
PIEDMONT DEVELOPMENT COMPANY, INC.
AND
HILTON PARTNERSHIP
The undersigned states that to the best of his or her knowledge and belief that if any funds have
been paid or will be paid to any person for influencing or attempting to influence an officer or
employee of any agency, a Member of Congress, or an employee of a Member of Congress in
connection with this commitment providing for the United States to insure or guarantee a loan, the
undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying,"
in accordance with its instructions.
Submission of this statement is a prerequisite for making or entering into this transaction imposed
by section 1352, title 31, US Code. Any person who fails to file the required statement shall be
subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure.
Mark Hilton
Piedmont Development Company, Inc. Hilton Partnership
~ ~ , ~
05/24/07
(Date)
C.114
o
NO CONFLICT OF INTEREST
BETWEEN
PIEDMONT DEVELOPMENT COMPANY, INC.
AND
HILTON PARTNERSHIP
Piedmont Development Company, Inc., and its principal officers, including immediate family holds
no legal or financial interest or influence in the ultimate recipient. Hilton Partnership
The ultimate recipient, Hilton Partnership , its principal officers, including
immediate family, hold no legal or financial interest in Piedmont Development Company, Inc.
~
Piedmont Development Company, Inc.
Mark Hilton
Hilton Partnership
05/24/07
(Date)
o
C,128
CERTIFICATION OF ELIGIBILITY AND COMPLIANCE
BETWEEN
EAST CAROLINA DEVELOPMENT COMPANY, INC.
AND
HILTON PARTNERSHIP
Piedmont Development Company, Inc., hereby certifies that Hilton Partnership
is an eligible recipient. the proposed loan is for eligible purposes, and the proposed loan complies
with all applicable statutes and regulations.
~
Piedmont Development Company, Inc.
Mark Hilton
Hilton Partnership
05/24/07
(Date)
o
C. 118 (A) (7) (IV)
CERTIFICATION OF FLOOD PLAIN STATUS
The undersigned hereby certifies that the property to be purchased and or collateralized by the
proposed loan is not located in a flood hazard zone as defined by the US Department of Housing
and Urban Development.
05/24/07
Mark Hilton (Date)
Hilton Partnership
o
o
RURAL CERTIFICATION
The undersigned hereby certifies that the assistance requested in the application will be used to
carry out activities or projects located in or servicing residents of a rural area. "Rural Area" shall
mean all territory of a state that is not within the outer boundary of any city having a population of
twenty-five thousand or more and its immediate adjacent urban area with a population density of
more than one hundred persons per square mile as determined by the Secretary of Agriculture
according to the latest Decennial Census.
Stephen LaRoque, Executive Director
Piedmont Development Company, Inc.
Mark Hilton
Hilton Partnership
05/24/07
(Date)
o
o
C. 117 (C)
NONDISCRIMINATION CERTIFICATION
The undersigned does hereby certify that the applicant organization does not deny services,
employment, or membership to persons based on political preference, race, religion, age, sex,
sexual preference, disability, or marital status.
05/24/07
Mark Hilton (Date)
Hilton Partnership
o
CITIZENSHIP CERTIFICATION
I hereby certify that I am a United States Citizen.
05/24/07
Mark Hilton (Date)
Hilton Partnership