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Facts: On March 12, 2013, a site owner entered into a contract to purchase a 10-unit residential apartment building. Since 2008, the previous owner had received subsidy payments from HUD to assist low-income families living in the apartments. These payments were pursuant to a Housing Assistance Payment (HAP) contract. The new owner claimed that it relied on the existence of the HAP contract in deciding to purchase the site, and anticipated that the HAP contract would be assigned from the prior owner to him.
