3. Regional Loan Center Responsibilities and Procedures for Sanctions, Continued Before imposing an LDP against an interstate participant operating in areas g. Impose LDP, If beyond your RLC's jurisdiction: Appropriate, Contact all RLCs serving jurisdictions in which the participant operates to continued find out whether: They have experienced problems with the participant, and They wish to impose sanctions against the participant in their jurisdictions and to what extent. Obtain concurrence of CO on chosen course of action. Coordinate the contents of the LDP notices between all affected RLCs. An RLC may implement an LDP to a greater or lesser degree within its jurisdiction than another RLC, or choose not to take action when another RLC does. Ensure that the reasons for the difference in treatment are supported by adequate documentation of all relevant facts, including any differences in the participant's activities in each jurisdiction. h. Arrange If a participant against whom debarment, suspension, or an LDP is imposed requests a formal hearing, CO Loan Policy may first encourage the participant Formal Hearing to have an informal meeting with the RLC to resolve the issues. Make every effort toward informal resolution to avoid the time and cost of a formal hearing. If informal means of resolution become exhausted, arrange a hearing date, in consultation with CO Loan Policy. Continued on next page 3. Regional Loan Center Responsibilities and Procedures for Sanctions, Continued h. Arrange The hearing is to begin within 30-business days of receipt from the request, Formal unless postponed because: Hearing, Participant requests postponement and presents a reasonable basis, or continued VA requires additional time to conclude its investigations, or The case has been, or is being, referred by the IG to a U.S. Attorney or the Department of Justice for consideration of criminal prosecution, or criminal prosecution has been initiated, but has not been concluded.
3. Regional Loan Center Responsibilities and Procedures for Sanctions, Continued g. Impose LDP, If Appropriate, continued Before imposing an LDP against an interstate participant operating in areas beyond your RLC's jurisdiction: Contact all RLCs serving jurisdictions in which the participant operates to find out whether: They have experienced problems with the participant, and They wish to impose sanctions against the participant in their jurisdictions and to what extent. Obtain concurrence of CO on chosen course of action. Coordinate the contents of the LDP notices between all affected RLCs. An RLC may implement an LDP to a greater or lesser degree within its jurisdiction than another RLC, or choose not to take action when another RLC does. Ensure that the reasons for the difference in treatment are supported by adequate documentation of all relevant facts, including any differences in the participant's activities in each jurisdiction. h. Arrange Formal Hearing If a participant against whom debarment, suspension, or an LDP is imposed requests a formal hearing, CO Loan Policy may first encourage the participant to have an informal meeting with the RLC to resolve the issues. Make every effort toward informal resolution to avoid the time and cost of a formal hearing. If informal means of resolution become exhausted, arrange a hearing date, in consultation with CO Loan Policy. Continued on next page 3. Regional Loan Center Responsibilities and Procedures for Sanctions, Continued h. Arrange Formal Hearing, continued The hearing is to begin within 30-business days of receipt from the request, unless postponed because: Participant requests postponement and presents a reasonable basis, or VA requires additional time to conclude its investigations, or The case has been, or is being, referred by the IG to a U.S. Attorney or the Department of Justice for consideration of criminal prosecution, or criminal prosecution has been initiated, but has not been concluded.