NCDA Legislative Policy and Professional Development Conference Housing

NCDA Legislative, Policy, and Professional Development Conference Housing Track: Basic HOME February 15, 2017 1: 30 -5: 30 pm NCDA 2017

The Journey to Quality Housing NCDA 2017

HOME Investment Partnerships Program BASIC HOME Presented by Sheryl Kenny NCDA 2017

THIS TRAINING COVERS: History and Purpose of the HOME Program HOME Regulations Eligible HOME Activities Community Housing Development Organizations (CHDOs) • Project Examples/HOME Program Exercise • • NCDA 2017

Introductions • Future Networking Resources • Tell Us…. . – Your Name – Agency & Position – Years of Experience with HOME – HOME Allocation – HOME Info You Need ASAP NCDA 2017

1) HISTORY AND PURPOSE OF THE HOME PROGRAM NCDA 2017

HOME Investment Partnerships Program • Created by the National Affordable Housing Act of 1990 (NAHA), – The largest Federal block grant to State and local governments designed exclusively to create affordable housing. – Based on CDBG, but many compromises – competition: states; non-profits; local governments – Initially no administrative funds NCDA 2017

HOME Investment Partnerships Program • Congressional intent: – Provide decent affordable housing to lowerincome households; – Expand the capacity of nonprofit housing providers; – Strengthen the ability of state and local governments to provide housing; and – Leverage private-sector participation. NCDA 2017

HOME Investment Partnerships Program – Intended Beneficiaries, families that are: • Low-income = 80% or less of Area Median Income (AMI) • Very-low-income = 50% or less of AMI – HOME limits are determined by HUD at the 80% and 50% levels » HUD has flexibility to move above and below these levels based on high housing costs or unusually high or low incomes. » Published on HUD Website: » https: //www. hudexchange. info/programs/homeincome-limits/ NCDA 2017

Program-Wide Income Targeting - I • Background – Controversy about how deeply HOME should be targeted • Many felt 80% AMI insufficient, especially for rental • Compromise – 80% AMI for Homebuyer & Owner Rehab. – 90% of families in rental units must have incomes of 60% AMI or less – for units completed in a program year NCDA 2017

Program-Wide Income Targeting - II • Income Targeting - Rental – Program-wide income targeting of PJ’s rental projects and TBRA • Some flexibility within individual projects • Deeper targeting of rental projects program-wide – Rental Units and Tenant-based Rental Assistance (TBRA) Units • 90% of families in rental units must have incomes of 60% AMI or less (completed in program year) NCDA 2017

INCOME LIMIT EXAMPLE U. S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) STATE: New Mexico –Albuquerque, NM MSA PROGR 1 2 AM PERSON 3 PERSON 4 PERSON 5 PERSON 6 PERSON 7 PERSON 8 PERSON 30% LIMITS 12950 14800 16650 18500 20000 21500 22950 24450 VERY LOW INCOME (50%) 21600 24650 27750 30800 33300 35750 38200 40700 29580 33300 36960 39960 42900 45840 48840 39450 44400 49300 53250 57200 61150 65100 60% 25920 LIMITS LOW INCOME 34550 (80%) NCDA 2017

HOME Investment Partnerships Program • FY 2012 & 2013 HUD Appropriations Law – Imposed new statutory requirements on FY 2012 and 2013 funded HOME projects • ‘Operating Guidance for Implementing FY 2012 HOME Appropriation Requirements’ (CPD Notice 12 -007) • 2013 HOME Rule made major changes • https: //www. hudexchange. info/programs/h ome/home-final-rule/highlights-of-thechanges-in-the-home-final-rule/ NCDA 2017

Why Changes to HOME Regs? • Accelerate timely production/occupancy of assisted housing, • Strengthen performance of PJs and their partners in producing/preserving affordable housing units, • Provide PJs with greater flexibility in the design and implementation of their programs, and • Increase administrative transparency and accountability. NCDA 2017

HOME OVERVIEW • Allocates Funds to Participating Jurisdictions (PJs) – (PJs – State/local governments – including consortia – that receive HOME funding) – 40% to States; 60% to Local Governments • Minimum Thresholds: – States: $3 million – Local Governments: $500 K (or $335 k when appropriation < $1. 5 B) NCDA 2017

HOME OVERVIEW • Formula based on six factors: – Vacancy-adjusted rental units (household head < poverty level) – Substandard occupied units – Age of units occupied by poor h/holds – Cost of producing rental units in area – Number of families below the poverty rate – Population NCDA 2017

HOME OVERVIEW • Consortium – Special PJ: Group of local governments that: – Are contiguous units of local government – Notify HUD by March 1 – year prior – Get Certification from State – Have legally binding 3 year agreement among members • Each locality must make a 3 year commitment • May be automatically renewed for new 3 years • One locality acts as lead member NCDA 2017

Program Partners • Typical HOME Program Partners: – States – Subrecipients – Developers, Owners & Sponsors – CHDOs – Contractors – Faith-based Organizations NCDA 2017

GLOSSARY • Glossary of HUD Terms • • ADDI Affordability Period CAPER CDBG CHDO Commitment FONSI PJ NCDA 2017

PJ Responsibilities • Allocation of Funds by PJs: – Commit within 2 years – Expend within 5 years – (New - Grant Based Accounting) • Project Completion – Must be completed within 4 years of date written agreement is executed • Planning and Administrative Costs – Maximum - 10% of Grant plus Program Income (PI) • At least 15% for CHDOs • At least 25% Match from non-federal sources • Monitor, keep records, and report NCDA 2017

HOME Appropriations HOME Investment Partnerships FY 2015 FY 2016 Increase % Increase Local Governments 538, 920, 000 568, 860, 000 29, 940, 000 6% States 359, 280, 000 379, 240, 000 19, 960, 000 6% 1, 800, 000 1, 900, 000 100, 000 6% 900, 000 950, 000, 000 6% Insular Areas Total HOME NCDA 2017

Impact of Decreasing HOME Funds HOME Five-Year Accomplishments Rental Units Homebuyer Units Homeowner rehab Units Total units Completed TBRA Households Assisted FY 2011 39, 162 21, 593 9, 137 69, 892 15, 683 FY 2012 28, 779 20, 129 9, 017 57, 925 15, 929 NCDA 2017 FY 2013 20, 929 15, 350 10, 547 46, 826 12, 363 FY 2014 20, 540 12, 854 6, 431 39, 825 11, 744 FY 2015 14, 779 10, 481 5, 458 30, 718 11, 935

Impact of Decreasing HOME Funds 80 000 70 000 60 000 50 000 Rental Units Homebuyer Units 40 000 Homeowner rehab Units Total units Completed 30 000 TBRA Households Assisted 20 000 10 000 0 FY 2011 FY 2012 FY 2013 FY 2014 NCDA 2017 FY 2015

2) HOME REGULATIONS NCDA 2017

UNDERSTANDING THE RULES • Begins With Law – Title II of National Affordable Housing Act of 1990, as amended • Agency Responsible Writes Regs – Published In Federal Register – HUD’S Regs begin with “Title 24” – HOME Regs are in Part 92 NCDA 2017

HOW TO READ A REGULATION • Proposed Rules – defined period for public input, not in effect until final rule – Interim Rules – Immediate, in effect until final rule • • Final Rules Established Format Use e-CFR (Code of Federal Regulations) http: //www. ecfr. gov/cgi-bin/textidx? tpl=/ecfrbrowse/Title 24/24 cfr 92_main_0 2. tpl NCDA 2017

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HOME Regulation Example Citation - § 92. 205(a)(1) • • • Title 24: Housing and Urban Development PART 92—HOME INVESTMENT PARTNERSHIPS PROGRAM Subpart E—Program Requirements § 92. 205 Eligible activities: General. (a) Eligible activities. (1) HOME funds may be used by a participating jurisdiction to provide incentives to develop and support affordable rental housing and homeownership affordability through the acquisition (including assistance to homebuyers), new construction, reconstruction, or rehabilitation of nonluxury housing with suitable amenities, including real property acquisition, site improvements, conversion, demolition, and other expenses, including financing costs, relocation expenses of any displaced persons, families, businesses, or organizations; to provide tenant-based rental assistance, including security deposits; to provide payment of reasonable administrative and planning costs; and to provide for the payment of operating expenses of community housing development organizations. The housing must be permanent or transitional housing. The specific eligible costs for these activities are set forth in §§ 92. 206 through 92. 209. The activities and costs are eligible only if the housing meets the property standards in § 92. 251 upon project completion. (2) Acquisition of vacant land or demolition must be undertaken only with respect to a particular housing project intended to provide affordable housing within the time frames established in paragraph (2) of the definition of “commitment” in § 92. 2. (3) Conversion of an existing structure to affordable housing is rehabilitation, unless the conversion entails adding one or more units beyond the existing walls, in which case, the project is new construction for purposes of this part. NCDA 2017

Exercise 1 READING THE REGULATIONS • Using the HOME Final Rule (Regulations) on your smart phone or device: – First, find and briefly describe the following Citations: 1. 2. 3. 4. 5. § 92. 220(a) § 92. 214(a)(8) § 92. 207 § 92. 352(b) § 92. 356(c) – Second, answer the questions on the following slide • Work in groups • Report out NCDA 2017

Questions about the Regs 1. How many categories of eligible match are listed at 92. 220? Name some of them. 2. Can HOME match be from another federal source? 3. List the individuals that must adhere to conflict of interest provisions of this section. 4. Can funds be committed to a HOME project before completion of the environmental review? 5. What is the cap on administration and what are some eligible administrative and planning costs? NCDA 2017

OTHER RESOURCES • Web Addresses: – HOME Program Website https: //www. hudexchange. info/programs/home/ – HOME Training – HUD Exchange • https: //www. hudexchange. info/training-events/ – National Community Development Association’s (NCDA) home page: www. ncdaonline. org NCDA 2017

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3) ELIGIBLE HOME ACTIVITIES NCDA 2017

ELIGIBLE ACTIVITIES - I • Within the Major Programs, the following are eligible activities: – Acquisition (including assistance to homebuyers) – New construction, reconstruction, or rehabilitation of non-luxury housing with suitable amenities, including: • • Real property acquisition; Site improvements; Conversion; and Demolition. – Tenant-based rental assistance, including security deposits NCDA 2017

ELIGIBLE ACTIVITIES - II – Administrative and planning costs – CHDO operating expenses – Other costs that support the development of affordable housing, including: • Financing costs; • Relocation expenses of any displaced persons, families, businesses, or organizations; and • Refinancing of existing indebtedness (only for rehab. ) NCDA 2017

Other General Eligibility Requirements -I • HOME-assisted housing must be permanent or transitional housing (i. e. , not short-term shelters). • Acquisition of vacant land or demolition are eligible: – Only if HOME-eligible housing is to be constructed at the site within 12 months after the acquisition. • Conversion of an existing structure to affordable housing is rehabilitation, – Adding one or more units beyond the existing walls, is considered to be new construction. NCDA 2017

HOME Assistance is Per Unit • Specific units are targeted as HOME units – HOME Units have minimum ($1, 000) and maximum HOME per unit subsidy limits – Only actual HOME-eligible costs may be charged to that unit: • Comparable units: costs may be pro-rated • Non-comparable units: costs determined by cost allocation (more in Chapter 6) – HOME eligibility and affordability requirements are applied only to HOME Units – HOME is different from CDBG • 51% of CDBG units must be income-eligible – Can pay up to full project cost (but can’t do new construction w/ CDBG) NCDA 2017

HOME Funds and Public Housing • Be careful when using HOME Funds with Federally assisted Public Housing: – HOME Funds can’t be used for housing units funded under section 9 of 1937 Housing Act – HAUs can’t receive Operating Fund or Capital Fund assistance under section 9 of 1937 Housing Act • Assisting non-federal public housing is generally OK NCDA 2017

Prohibited Activities • Project reserve accounts or operating subsidies – However, HOME funds may be used to provide initial operating deficit reserve per § 92. 206(d)(5) • Tenant-based rental assistance for the special purposes of the existing section 8 program • Non-federal matching contributions required under any other Federal program • Assistance authorized under section 9 of the 1937 Act (Public Housing Capital and Operating Funds) NCDA 2017

Prohibited Activities • Assistance to project previously assisted with HOME funds during affordability period – Except: • HOME Funds may be committed to a project up to one year after project completion, but – The total amount of HOME funds in the project may not exceed the maximum per-unit subsidy amount. • Tenant-based rental assistance; • Assistance to a homebuyer to acquire housing previously assisted with HOME funds; or • Assistance to Troubled HA Rental Project (up to max. per unit subsidy) NCDA 2017

Prohibited Activities • Acquisition of property owned by the participating jurisdiction – Except: • property acquired by the participating jurisdiction with HOME funds, or • property acquired in anticipation of carrying out a HOME project. NCDA 2017

Prohibited Activities • Delinquent taxes, fees or charges on properties to be assisted with HOME funds • Any cost that is not eligible under §§ 92. 206 through 92. 209 • PJs may not charge servicing and origination fees in HOME-assisted projects (can be admin. ) • However, PJs may charge nominal application fees (although these fees are not an eligible HOME cost) to project owners to discourage frivolous applications. • New – can charge monitoring fees to rental projects during affordability period NCDA 2017

Terminated Projects & Projects not meeting Affordability Requirements • Termination for failure to meet afford-ability requirements – All HOME Funds must be repaid • Except: – Special CHDO project-specific loans – CHDO operating funds – Administration costs NCDA 2017

Eligible Costs • Eligible HOME Costs: – Eligible Project Costs – CHDO Costs – Administrative and Planning Costs – Tenant-based Rental Assistance Costs – Pre-Award Costs • Timing issue – Project Closeout in IDIS must be done 120 days after final draw - § 92. 502(d)(1) NCDA 2017

Eligible Project Costs - I • Development Hard Costs – New Construction • Must meet: – New construction standards (usually building code) – Model Energy Code – Rehabilitation • Must meet property standards – Demolition – Utility Connections – Site Improvements NCDA 2017

Eligible Project Costs - IV • Acquisition – Improved or unimproved property – Homebuyer assistance – HOME project construction must begin within 1 year (no land banking) – Upon completion, HOME units must meet affordability, occupancy & property standard requirements – Closeout timing issue NCDA 2017

Eligible Project Costs - V • Project Related Soft Costs – – Architectural, engineering or related professional services Financing costs Project audit Information Services, including: • Affirmative Marketing • Fair Housing Information – – – Initial operating deficit reserve PJ staff and overhead costs Impact fees Environmental review and release of funds Closeout timing issue NCDA 2017

CHDO COSTS • CHDO Set Aside (or CHDO Reserve) • CHDO Capacity Building • Project-specific CHDO loans: – Technical assistance and site control loans, and – Seed money loans. • CHDO Operating Costs NCDA 2017

Tenant-Based Rental Assistance (TBRA) • TBRA consists of : – Rental Assistance • Subsidy that a PJ may pay to or on behalf of an eligible family. – Security Deposits • Loans or grants to eligible families for security deposits for rental units – Utility Deposits (but only with above) (Discussed more fully in Chapter Six) NCDA 2017

The Major Programs • Administration and Planning • Homebuyer Activities – Direct Assistance to homebuyers – Project Development • • Rental Housing Activities Owner-occupied Housing Rehabilitation Tenant-Based Rental Assistance (TBRA) CHDO Costs and Activities NCDA 2017

Administrative & Planning Costs • Limitation of 10% of annual grant plus program income – By PJ and/or subrecipient NCDA 2017

Administrative & Planning Costs • Typical program administration costs cover: – Staff and overhead costs to administer the HOME program; – Staff and overhead activity related costs: • That the PJ has chosen not to include in that activity’s costs, or • That must be excluded from project costs because the project has not been completed in accordance with HOME requirements. – Providing information to officials and the public – Budget and scheduling preparation – Development of written agreements with others to carry out activities – Monitoring program progress and compliance (continued) NCDA 2017

Administrative & Planning Costs • Typical program administration costs cover: – Developing agreements and monitoring housing not assisted with HOME funds that the PJ uses as Match – Report preparation – Office expenses – Official travel – Legal, audit, and accounting services – Fair Housing activities – Costs of complying with other Federal Requirements NCDA 2017

Administrative & Planning Costs • Typical activities covered as planning costs include: – Development of the Consolidated Plan – Individual project plans • Excluding delivery costs such as engineering and architectural fees – Development of Assessment of Fair Housing NCDA 2017

Admin. vs. Project Costs Administration costs: Project costs: Count against 10% administrative cap Do not count against 10% administrative cap -But only if the project goes to completion. Do not count towards maximum per-unit subsidy Count towards maximum per-unit subsidy Do not increase match liability. Increase match liability. Do not have to be repaid if the project does not meet HOME requirements Must be charged to HOME administration when project does not go to completion and meet HOME requirements. NCDA 2017 This would require a PJ, which has already charged these costs to a project, to back them out and charge them to administration. This could be a problem if the PJ is close to the 10% cap.

Homebuyer Activities NCDA 2017

Homeownership Housing New Construction – Ownership Housing Birmingham, AL – “Blitzbuilds” happen in first week of June each year (Homeownership Month) during which Habitat, a group of licensed homebuilders and City cooperate to build-out a small (10 -11 lot) subdivision over a one-week timeframe. City HOME dollars back-stop any shortfalls on materials. NCDA 2017

1 st Time Homebuyer Class Quincy, MA NCDA 2017

Homeownership Project Requirements • Overview – HOME funds may go to: • Homebuyers to purchase and rehab. housing; • Developers or owners (including CHDOs) to develop affordable homeownership housing NCDA 2017

Homeownership Project Requirements – Forms of Assistance - I • Direct assistance to homebuyers – Downpayment, closing cost assistance, or loan-cost-buy down – Rehabilitation costs for purchased property – Provided as loans, grants or loan guarantees » Most use loans NCDA 2017

Homeownership Project Requirements – Forms of Assistance – II • Assistance to developers (Development Subsidy) for: – Acquisition, – Construction, – Reconstruction, – Rehabilitation, – Conversion of non-housing, – Demolition of existing buildings, and – Site improvements. NCDA 2017

Homeownership Project Requirements • Affordability Period – From 5 -15 years. During this period: • Resale or recapture provisions imposed; and • HA Units must meet property standards. – Affordability period does not apply to rehabilitation of owner-occupied housing (not acquired with HA) NCDA 2017

Homeownership Project Requirements Homeownership Affordability Periods Homeownership Assistance per Unit Minimum period of affordability in years Under $15, 000 5 $15, 000 to $40, 000 10 Over $40, 000 15 NCDA 2017

Homeownership Project Requirements • Income Eligibility – Low Income (=<80% AMI) • Homebuyer – by the time of purchase agreement • New construction or rehab. units – at time of agreement to purchase or lease-purchase • Income-eligibility requirement only at purchase, – Can remain in property regardless of later income so long as principal residence NCDA 2017

Homeownership Project Requirements • Principal Residence – Buyers must use property as their principal residence during affordability period NCDA 2017

Homeownership Project Requirements • New - Homebuyer Program Design – All HOME-assisted homebuyers must receive housing counseling. See final rule for Housing Counseling Certification, published Dec. 14, 2016 – Counseling should be comprehensive, including post-purchase counseling, if feasible • Homebuyers may be charged a reasonable fee for counseling • HOME funds can’t be used, – Except that counseling costs for a HA homebuyer (through d/p assistance or who purchases a HAU), can be eligible project soft costs (included in max. per unit subsidy) or as admin cost (10% cap). – If homebuyer not ultimately assisted with HOME funds, counseling must be admin. cost. NCDA 2017

Homeownership Project Requirements • Maximum Property Value – Property must “be modest” – HOME purchase price or after purchase & rehab. Limit: • 95% of median purchase price for area. Either: 1. Single family mortgage limits at » https: //www. hudexchange. info/resource/2312/homemaximum-purchase-price-after-rehab-value/ 2. PJ may determine using procedures in § 92. 254(a)(2)(iii) NCDA 2017

Homeownership Project Requirements • Exception to restriction on Subsequent HOME Funding – Normally, no additional HOME Funds after one year from project completion. – A PJ may use additional HOME funds after one year: – Beforeclosure or at foreclosure sale: » To acquire housing through a purchase option, right of first refusal, or other preemptive right; – To provide assistance to another HOME eligible homebuyer. • Total of original and additional HOME assistance may not exceed maximum per-unit subsidy. NCDA 2017

Homeownership Project Requirements • New - Homebuyer Unit Transfer Deadline [§ 92. 254(a)(3)] – Units acquired, rehabilitated or newly constructed with HOME funds for homeownership purposes must be sold to an eligible buyer within 9 months of construction completion. (2012 & 2013: 6 months, completion means Cert. of Occupancy issued or owner rehab: PJ & owner’s signoff) – If transfer has not occurred, the unit must be converted to a HOME rental unit and operated in compliance with § 92. 252 for the affordability period applicable to rental projects. (2012 & 2013: same, transfer defined as ratified sales contract between buyer and developer; if not converted must repay HOME funds; HUD has no exception authority) • 20 years for new construction NCDA 2017

Homeownership Project Requirements • Resale vs. Recapture – PJ must impose either resale or recapture requirements on HA homeowner units – (except owner-occupied rehab, not acquired w/HOME) • Must include requirements in Consolidated Plan or AAP and (new) HUD must approve in writing • Cannot be hybrid – But can use in separate programs w/in PJ NCDA 2017

Homeownership Project Requirements • Resale - I – During affordability period, on initial and subsequent sales of HAU: • PJ-imposed deed restriction or covenant running with land, with following conditions: – Must be sold to an income-eligible family – Must be principal residence of owner – Must be affordable to a reasonable range of low-income homebuyers (usually 70 -80% AMI); and – Must provide seller with a fair return on their investment » including homeowner’s investment (downpayment and principal payments) and any capital improvement. » Fair return defined by PJ (for example: resale price based on changes in Housing Price Index [HPI]) • Must address how it can be made affordable if return on investment is too high; NCDA 2017

Homeownership Project Requirements • Resale - II – During affordability period, on initial and subsequent sales: • Must also have agreement (mortgage, note) w/entity (buyer, developer) initially receiving funds – Recommend mortgage assumable by subsequent buyers » Gives more protection – Funds repaid under mortgage are not Recaptured Funds but are PI (and will reduce amount needed by PJ to repay) NCDA 2017

Homeownership Project Requirements • Resale - III – Advantage • Provides long-term affordability. – Useful in areas of rapidly rising housing prices and in high-housing-cost areas – Disadvantages • Mortgage financing may be difficult to obtain • If property is sold in foreclosure or if buyer defaults on HOME terms, proceeds might not cover required repayment of HOME assistance – Amount repayable is total of HOME assistance to the unit: both development and buyer – PJ is on the hook for full amount of HOME assistance • Buyers may not understand/accept deed restriction • Administration is somewhat more complicated NCDA 2017

Homeownership Project Requirements • Resale – IV – Deed restrictions may terminate in event of foreclosure • HOME investment must be repaid if unit no longer meets affordability requirements • Restrictions revived if owner of foreclosed property regains ownership during affordability period • To forestall foreclosure, add purchase options or rights of first refusal to deed restriction – See exception to restrictions on subsequent HOME funding (earlier slide) NCDA 2017

Homeownership Project Requirements • Recapture - I – Can only be used when providing direct subsidy to homebuyer – During affordability period, when HA property sold, PJ collects some or all of HOME assistance from net sale proceeds: • Must be sold to – Any willing buyer – At any price – At any time • PJ decides proportion of net proceeds to seller and to PJ (Recapture) • Property no longer subject to HOME Rules after Recapture NCDA 2017

Homeownership Project Requirements • Recapture - IA – New - Assumption of Recapture Obligations by Subsequent Homebuyer [§ 92. 254(a)(5)(ii)] • Subsequent low-income purchaser of a HA homeownership unit may assume the existing HOME loan and recapture obligation when no additional HOME assistance is provided • Where additional HOME assistance needed, the original HOME assistance must be recaptured. – A separate HOME subsidy must be provided to the new homebuyer, and a new affordability period must be established based on that assistance to the buyer. NCDA 2017

Homeownership Project Requirements • Recapture - II – Advantages • • Easier to administer Easier for buyers and banks to understand May provide additional funding for HOME activities If no net proceeds neither seller nor PJ on hook for HOME Assistance – Disadvantage • Property may no longer be affordable NCDA 2017

Homeownership Project Requirements • Recapture - III – HOME Amount Subject to Recapture • Amount of HOME assistance that enabled homebuyer to buy dwelling unit – Includes HOME assistance that reduced purchase price from fair market value to an affordable price – Excludes amount between cost of producing unit and market value of property (i. e. , development subsidy) » If HOME assistance only used for development subsidy, resale option must be used NCDA 2017

Homeownership Project Requirements • Recapture - IV – HOME Amount Subject to Recapture Market value of home (If HA development) - Sales Price of home = Discount benefiting homebuyer + HOME Funds directly to homebuyer (e. g. , DPA) = Amount subject to recapture – Does not include HOME $ used for cost of producing unit (development subsidy) NCDA 2017

Homeownership Project Requirements • Recapture - V – Limited to amount of Net Proceeds of sale • Net Proceeds are sales price minus superior loan repayment (other than HOME funds) and any closing costs NCDA 2017

Homeownership Project Requirements • Recapture - VI – Recapture Options • • Owner Investment Returned First PJ Recaptures Entire Amount Reduction During Affordability Period Shared Net Proceeds • See 92. 254(a)(5) for more detail NCDA 2017

Rental Housing Activities NCDA 2017

Rental Projects Burlington, VT – Rental Housing (40 Units – 28 HOME) Waterfront Housing is a mixed-income, LEED-certified rental project developed through a partnership between Housing Vermont, a non-profit syndication and development company that creates permanently affordable housing for Vermonters, and the Burlington Community Land Trust. Built on a former scrap yard (w/ EPA Grant for cleanup). NCDA 2017

New Construction & Rehabilitation – Rental Housing Weymouth, MA - 12 units of affordable housing for homeless families and individuals including six rehabilitated housing units and six new modular units. NCDA 2017

Rental Project Requirements • Overview – HOME funds may go to developers or owners (including CHDOs) for affordable rental housing: • • Acquisition, Construction, Reconstruction, Rehabilitation, Conversion of non-housing to housing, Demolition of existing buildings, and Site improvements. NCDA 2017

Rental Project Requirements • Affordability Period – From 5 -20 years. During this period for HA units: • • Only income-eligible tenants; Rent limitations imposed; Must meet property standards; and Specific tenant protections must be provided. – Must be imposed by deed restrictions or other covenants running with the land, except: • May terminate upon foreclosure (but HOME funds must be repaid) NCDA 2017

Rental Project Requirements Rental Affordability Periods (§ 92. 252(e)) Rental Housing Activity Minimum period of affordability in years Rehabilitation or acquisition of existing housing per unit amount of HOME funds: Under $15, 000 5 $15, 000 to $40, 000 10 Over $40, 000 or any rehabilitation involving refinancing 15 New Construction or acquisition of newly constructed housing 20 NCDA 2017

Rental Project Requirements • Income Targeting – Several different requirements affect rental income targeting • Project Requirements: All HOME-assisted Rental or TBRA units must be 80% of AMI or less – Minimum of 20% of HA Units in multi-unit (5 or more HOME Assisted Units) projects must be =< 50% • Program Wide: 90% of a PJ’s HOME-assisted Rental Units and TBRA units must be =<60% AMI NCDA 2017

Rental Project Requirements INCOME TARGETING Maximum Income Limit for Unit Any HOME-assisted Rental or TBRA unit 80% of AMI Program Wide: 90% of a PJ’s HOME-assisted Rental Units or TBRA units 60% of AMI Minimum of 20% of Units in multi-unit projects 80% of 60% of 50% of AMI HOME-assisted Rental & TBRA Units Affected Any unit not affected by the following two Any unit not affected by the AMIrestrictions following two restrictions Applies to All Units Developed during Applies to All Units the PJ’s Program Developed during the PJ’s AMI Year Projects with 5 or Program Year more HOMEassisted rental units Projects with 5 or more 50% of AMI NCDA 2017 HOME-assisted rental units

Rental Project Requirements Middletown PJ Distribution of Income Targeting of 100 Rental and TBRA Units for Program Year 2015 Project # VLI Units (50% AMI) 60% AMI Units LI Units (80% AMI) 1 2 0 8 TBRA Program 0 8 2 2 2 8 0 3 2 8 0 4 2 8 0 5 2 8 0 6 2 8 0 7 2 8 0 8 2 8 0 9 2 8 0 Total Rental & TBRA Units Total Combined TBRA & Rental Units Percent of Combined TBRA & Rental Units and LI Units 18 72 10 90% 10% NCDA 2017

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Question • Would the project still meet HOME rental requirements if the PJ had one more household above 60% AMI? • 21 Households at 60% or below and 3 households above 60%? NCDA 2017

Rental Project Requirements • Rental Unit Designation – Fixed vs. Floating • Defines how vacancies and HA units w/ over-income tenants treated • Designated at commitment (must include in agreement) – Fixed Units • When units are not comparable (size, b/r, & amenities) • Designated HA units remain the same throughout the affordability period – All HOME requirements apply to these units throughout AP • Upon vacancy or over-income tenants, they must be filled with HOME-eligible tenants. NCDA 2017

Rental Project Requirements • Rental Unit Designation – Fixed vs. Floating – Floating Units • All Units must be comparable • Upon vacancy or over-income tenants, next available comparable unit must be filled with HOME-eligible tenants and is designated the HA unit. – All HOME requirements apply to these units during designation NCDA 2017

Rental Project Requirements • Over Income Tenants – Over income tenants may stay in unit and unit counts as HA, if: • Required # of HA units maintained – I. e. , next available floating unit filled with HOME-eligible • Ratio of High HOME and Low HOME units maintained • Over income tenant pays rent, the lesser of: – State or local rent level; or – 30% of family’s adjusted income – Except: » LIHTC tenant » Floating unit tenant not required to exceed market rent NCDA 2017

Rental Project Requirements • Rent Limitations - I – HA unit rents cannot exceed “High HOME Rent” or “Low HOME Rent” • HUD publishes annually for each MSA • Listed for efficiency to six bedroom units • For information, includes FMR, 65% and 50% rent levels for Area NCDA 2017

Rental Project Requirements • Rent Limitations – II – High HOME Rent (Most HOME tenants) • Lower of FMR or 30% of adj. income of 65% AMI family – Low HOME Rent • New - PJ may designate any number of Low HOME Rent units in a project • Required – At least 20% of units are required to be set aside for 50% AMI tenants, in projects of 5+ HA units: – Rents may not exceed 30 percent of the annual income of a 50 percent AMI family » Exception: If project-based subsidy, then that rent may be used • So long as the tenant pays no more than 30% of their adjusted income towards rent. NCDA 2017

U. S. DEPARTMENT OF HUD STATE: New Mexico– 04/2016 Albuquerque, NM MSA U. S. DEPARTMENT OF HUD 06/28/2011 PROGRAM 1 BR 2 BR 3 BR 4 BR 5 BR STATE: TEXAS EFFICIENCY 6 BR LOW HOME RENT LIMIT 551 590 708 818 912 1006 1100 HIGH HOME RENT LIMIT 591 767 941 1091 1198 1302 1408 Austin-Round Rock-San Marcos, TX MSA For Information Only: FAIR MARKET RENT 591 767 941 1352 1643 1889 2136 50% RENT LIMIT 551 590 708 818 912 1006 1100 65% RENT LIMIT 738 791 952 1091 1198 1302 1408 NCDA 2017

Rental Project Requirements • Rent Limitations – III – Initial Rent Schedule • PJ must review and approve project rents • Rent limits include both the rent and utilities (or utility allowance) – Utility Allowances • PJ must establish max. monthly allowances for utilities, when utilities are not included in rent. See: – HOMEfires, V. 13, No. 2, May 2016 and – HUD Utility Schedule Model Webcast • HOME rents can’t exceed max. HOME rent minus utility allowance – Unless utilities included in rent, then HOME rent NCDA 2017

Rental Project Requirements • Site and Neighborhood Standards – For new rental housing: • PJ must make written determination that the site meets requirements: – Meets physical requirements and provides adequate infrastructure; – Will affirmatively further Fair Housing and other civil rights; – Is not located in an area of minority or low-income concentration, unless certain criteria are met; and – Provides a greater choice of housing opportunities and accessibility to transportation, public and government services. NCDA 2017

Rental Example 60 Units: 10 HOME-Assisted (1 bedroom), 50 Market Rate (2 bedroom) 1 2 3 4 5 6 7 8 9 10 NCDA 2017

Rental Example Questions • Are these fixed or floating units and why? • How many of the 10 HOME-assisted units must be filled by households making less than 50% AMI? • What is the maximum number of units that can be charged high HOME rent amounts? • If this was the only rental project the PJ completed during the program year, how many households over 60% AMI could rent the units? NCDA 2017

General Project Requirements • Two tests to determine HOME assistance amount and Number of HOME Assisted Units: 1. Maximum per Unit (MPU) Subsidy 2. Fund Apportionment • HOME funds to Total Development Cost: HOME Assisted Units to Total Units • Both must be used to determine: – Allowable # of HOME Assisted units – Maximum amount of HOME Funds invested NCDA 2017

General Project Requirements • Minimum Per-Unit Subsidy is $1, 000 • Maximum Per-Unit Subsidy - I – MPU Subsidy Limits set by (Interim Policy – CPD Notice -15 -003 – Section 234 basic mortgage limits) • Also see HOMEfires – V. 12 No 1, May, 2015 • Contact HUD Rep for your MPU Subsidy Limits – Creates a cap on the HOME assistance for a specific number of HOME units – Creates a floor on the number of HOME units for a specific amount of HOME assistance NCDA 2017

General Project Requirements • Maximum Per-Unit Subsidy (Cap on Assistance) – Developer wants 10 HA units and $2 M in HOME assistance • MPU Subsidy =$150, 000 – How much HOME $ could you give her for 10 HA units? Example 1 – 60 -Unit Project – Cap on Assistance Requested # of Units 10 Maximum per Unit Subsidy $150, 000 Maximum HOME Assistance to Project $1, 500, 000 NCDA 2017

General Project Requirements • Maximum Per-Unit Subsidy (Floor on # of units) – What’s the minimum number of units if the developer sticks with her $2 million request? Example 1 – 60 Unit Project – Floor on Units Requested HOME Assistance $2, 000 Maximum per Unit Subsidy $150, 000 Minimum # of HOME Units 14 NCDA 2017

General Project Requirements • Apportioning HOME funds to a Multi-Unit Project - I – HOME Costs to total development costs (TDC) can’t exceed proportion of HA units to total units – Apportioning funds also creates a cap on HOME funds or a floor for # of HA units – Establishing HOME costs for apportioning depends on whether units are • Comparable; or • Not comparable NCDA 2017

General Project Requirements • Apportioning HOME funds to a Multi-Unit Project – II – Comparable Units • If Similar in size, features and number of bedrooms, then • HOME cost per unit may be pro-rated based on the ratio of HOME units to total units. • (“Floating” rental units must always be comparable) NCDA 2017

General Project Requirements HOME Apportionment Example – Comparable Units 60 -Unit Project Total Development Cost $6, 000 Proposed HOME Assistance $2, 000 Percent HOME Funds 34% Total # of Units Minimum # of HOME Units 60 60 x 34% = 20. 4 rounded up to 21 Proposed # of HA Units 10 60 -Unit Project Does Not Pass HOME Apportionment Test Note: HOME unit determinations are always rounded up. NCDA 2017

General Project Requirements • Apportioning HOME funds to a Multi-Unit Project – III – Non-Comparable Units • HOME costs allocated on a unit by unit basis: – Identify HOME units – Develop a pro-forma to determine cost per HA unit – Track costs for each unit including % of common costs » HOME Amt. of common costs = sq. ft. of HA units/total sq. ft. x common costs – (HA non-comp. rental units must always be “fixed”) NCDA 2017

General Project Requirements HOME Apportionment Example – Non-Comparable Units 60 -Unit Project Total Development Cost $6, 000 Total # of Units 60 TDC/unit $100, 000 Cost per HOME unit per proforma $80, 000 Cost per HOME unit of the Common Areas $15, 000 Total Max. Apportioned cost/HA unit $95, 000 Proposed # of HA Units 10 Max. HOME Assist. /Apportioned Costs NCDA 2017 10 x $95, 000 = $950, 000

General Project Requirements • Balancing Apportioned Costs with the Maximum Per-Unit Subsidy – Both the Apportion Funds Test and the Maximum Per-Unit Subsidy set • Caps on the amount of HOME Funds; or • Floors on the number of HA units. – Most cases: • Subsidy limit sets cap • Apportion Test sets floor NCDA 2017

General Project Requirements Balancing Apportioned Cost and Maximum Per Unit Subsidy Example – 60 -Unit Project Non–Comparable Units Proposed # of HA Units 10 Maximum HOME Assistance – Apportioned Costs 10 x $95, 000 = $950, 000 Maximum HOME Assistance – Per Unit Subsidy Limit 10 x $150, 000 = $1, 500, 000 CAP: Developer’s HOME Subsidy limited to $950, 000 If developer had asked for full $1, 500, 000, would have to increase # of units to 15 (25% of total units) NCDA 2017

Rehabilitation of Owner. Occupied Project Requirements NCDA 2017

Rehabilitation – Before and After Des Moines, IA - HOME, Inc. (CHDO) NCDA 2017

Rehabilitation of Owner-Occupied Housing Homeowner Housing Rehabilitation Quincy, MA NCDA 2017

Rehabilitation of Owner-Occupied Housing Project Requirements • Overview – HOME rehab. funds may go to: • Ensure that the home meets required property and rehabilitation standards • To make essential improvements, including – Energy-related repairs or improvements, – Improvements necessary to permit use by persons with disabilities, and – Abatement of lead-based paint hazards • To refinancing existing debt (see 92. 206(b)) NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Income Eligibility – At the time of HOME commitment – Low Income (80% AMI or less) • Affordability Period – No Affordability Period (income eligibility at commitment) – No HOME repayment requirement NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Principal Residence – At the time of HOME commitment • Forms of Assistance – Grants – Loans (direct or deferred-payment) – Loan Guarantees NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Maximum Property Value - I – May not exceed either: • 95 percent of the median purchase price of the area as determined by HUD (203(b) limits); or • 95 percent of the median area purchase price for single family housing in the jurisdiction, established by the PJ. – Must use HUD-approved method • See HUD website at: https: //www. hudexchange. info/resource/2312/homemaximum-purchase-price-after-rehab-value/ NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Maximum Property Value – II – Determination of value must be done before committing HOME funds to project – Must use one of three methods: • Estimate of Value • Appraisals • Tax Assessments NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Property Standards – Must meet all applicable local codes, rehabilitation standards, ordinances, and zoning ordinances at the time of project completion. • HOME funds may not be used for emergency or small home repairs. NCDA 2017

Owner-Occupied Housing Rehab. Project Requirements • Rehabilitation Standards – PJ must establish written rehabilitation standards that: • Brings substandard housing up to code; • Prescribes methods and materials; and • New - Meets requirements for: – – Health and safety Major systems for rental & ownership housing Disaster mitigation standards Capital needs assessment for multifamily (26+) rental housing NCDA 2017

Tenant-Based Rental Assistance Requirements NCDA 2017

Tenant-Based Rental Assistance Requirements • Overview – HOME TBRA funds may go to: • To rental tenants for short-term support, including: – Rent subsidies – Security deposits – New – Utility deposits but only with one of above • Project-based subsidies not allowed NCDA 2017

Tenant-Based Rental Assistance Requirements • TBRA must be in Consolidated Plan: – As a strategy; and – Must specify local market conditions that lead to choice of this option. NCDA 2017

Tenant-Based Rental Assistance Requirements • New - Self-Sufficiency Programs in TBRA – May use TBRA to administer a self-sufficiency program in which family is required to participate as a condition of selection for tenant-based rental assistance. • Can’t terminate assistance because of family’s failure to continue participation in the self-sufficiency program – But renewal of the assistance can be conditioned on participation in the program. • PJs may not require persons with disabilities to participate in medical or disability-related services as a part of a selfsufficiency program. NCDA 2017

Tenant-Based Rental Assistance Requirements • Income Targeting – Several different requirements affect TBRA income targeting • All HOME-assisted Rental or TBRA units must be 80% of AMI or less • Program Wide: 90% of a PJ’s HOME-assisted Rental Units and TBRA units must be =<60% AMI – Family must meet income requirements: • Initially; and • Annually during assistance period. NCDA 2017

Tenant-Based Rental Assistance Requirements • Tenant Selection - I – PJ must develop written tenant selection policies and criteria, and select families in accordance with these policies: • Tenants must meet income requirements • May establish a preference for individuals with special needs • May also provide a preference for a specific category of individuals with disabilities NCDA 2017

Tenant-Based Rental Assistance Requirements • Tenant Selection – II – Policies may not be administered in a discriminatory fashion or have a discriminatory effect. – May select low-income families currently residing in HA rehabilitation or acquisition units. • May use tenant-based assistance in rehabilitated or acquired housing unit or in other qualified housing. NCDA 2017

Tenant-Based Rental Assistance Requirements • Portability of Assistance – PJ may allow TBRA outside of boundaries • Term of Rental Contract – Max. 24 months – Contract Term must • Start with 1 st day of lease • Coincide with lease (if contract with owner) • Need not terminate with lease (if contract w/ family), but – No Payments until new lease NCDA 2017

Tenant-Based Rental Assistance Requirements • Rent Reasonableness – PJ must disapprove lease if rent not reasonable (based on comparable units) NCDA 2017

Tenant-Based Rental Assistance Requirements • Tenant Protections – Leases must be for at least one year (unless tenant agrees) and cannot contain any of following agreements: To be sued, to admit guilt, to a judgment in favor of owner; To allow owner to take hold or sell personal property; To excuse owner from responsibility; To allow owner to sue without notice; To allow owner to evict without following civil court procedures; • To waive a jury trial; • To waive right to appeal a court’s decision; and • To pay owner cost of legal actions no matter what outcome. • • • NCDA 2017

Tenant-Based Rental Assistance Requirements • Housing Quality – TBRA Units – Must meet Section 8 HQS – Must be inspected initially and annually NCDA 2017

Tenant-Based Rental Assistance Requirements • Security Deposits - I – May be given in addition to TBRA rent subsidy – State or local definition of security deposit applies – Maximum = two months rent – Only Tenant can apply – All TBRA requirements apply, except • Term of assistance • Maximum subsidy NCDA 2017

Tenant-Based Rental Assistance Requirements • Security Deposits – II – Lease minimum 1 year • Can’t contain prohibited provisions – Payment to tenant or landlord – PJ may provide as loan or grant • If grant, family may keep funds when leaving unit • If loan: – PJ must arrange for return of funds from owner or tenant – If owner subtracts for damages, PJ may: » Accept balance; or » Require full repayment – Terms must be in written agreement with tenant NCDA 2017

Community Housing Development Organizations (CHDOs) NCDA 2017

CHDO Project - New Construction – 1 ST Time Homebuyers Salinas, CA – Partnership between the City, Hartnell College (provided student labor), and CHISPA (a CHDO) – Community Housing Improvement Systems and Planning Association – Project Manager NCDA 2017

Ashley (top left) Erika Jesse Audrey And their new home CHDO New Construction – 1 st Time Homebuyers Mc. Allen, TX – First of 154 homes – All HOME-assisted – All Green and Energy Star Certified – 1 st so designated in Rio Grande Valley NCDA 2017

CHDOs • Community Housing Development Organizations (CHDOs): – Background – What is a CHDO? – The CHDO Set-aside – Special CHDO Costs – Other Special CHDO Requirements NCDA 2017

Background: The CHDO Set Aside • During legislative process – States vs. localities vs. non-profits – Compromise • CDBG model (CBDO), but • At least 15% of state/local funds set aside for special non-profits: CHDOs – To count, CHDO must be have substantial role: » Owner, developer or sponsor NCDA 2017

What is a CHDO? - I § 92. 2 -Definitions • Where in Regs? • Non-profit that is tax exempt – IRS § 501(c)(3) or (4) – May be sponsored or created by for-profit, but the for-profit: • May not appoint more than 1/3 rd of board • May not be developer or manager of housing • Cannot control CHDO’s procurement NCDA 2017

What is a CHDO? - II • Purpose (in charter or by-laws) – provision of decent affordable housing • History of serving the community – (If not) Parent has a least 1 year of experience • Board of directors: – Not more than 1/3 rd appointed by PJ or PJ public officials (can’t be CHDO officers or employees) • Remaining 2/3 rds can’t be appointed by these – Not more than 1/3 rd appointed by for-profit sponsor or sponsor officers or employees (can’t be CHDO officers or employees) – At least 1/3 rd low-income residents or elected representatives of low-income n/hood orgs. NCDA 2017

What is a CHDO? - III • Must provide a formal process for lowincome program beneficiaries to advise CHDO • Demonstrated capacity for HOME activities – New - Must have paid staff with development and/or management experience • No person to benefit from net earnings NCDA 2017

What is a CHDO? - IV • Must be certified by PJ as CHDO – Initially; and – New - Before committing CHDO set-aside funds for each project • New - PJ must document that the CHDO has the capacity to own, develop or sponsor housing each time it commits funds for a specific project. NCDA 2017

The CHDO Set-Aside • Reserving CHDO Set-Aside Funds – Two years to reserve at least 15% of annual grant • New -“Reserved” means written agreement with certified CHDO for a specific project – 2015 and later: 15% is no longer cumulative over life of program: • IDIS automatically sets aside 15% each year • CHDOs have a separate 5 -year deadline for expending Set-aside funds. NCDA 2017

Set-Aside for Community Housing Development Organizations (CHDOs) [§ 92. 300] • To qualify for CHDO Set-aside funds – Must have “effective project control” – Must be owner, developer or sponsor NCDA 2017

Set-Aside for Community Housing Development Organizations (CHDOs) [§ 92. 300] • When a CHDO is not a CHDO: – For a HOME activity that it is using other than HOME Set-Aside funds for – When acting as a HOME subrecipient, e. g. , when administering: • TBRA Program • Homeowner rehab. Program • Direct homebuyer assistance, except – In connection with a CHDO set-aside project See Table Next Slide NCDA 2017

Eligible CHDO Subrecipient Activities Eligible CHDO Set-Aside Activities Eligible Activity CHDO Developer CHDO Sponsor CHDO Owner CHDO Subrecipient Acquisition/rehabilitation of rental housing X X New construction of rental housing X X Acquisition/rehabilitation of homebuyer properties X X X New construction of homebuyer properties X X X Direct financial assistance (i. e. downpayment and closing costs) to purchasers of HOMEassisted homebuyer housing owned, sponsored, or developed by a CHDO with HOME funds X X X Tenant-based rental assistance (TBRA) X Homeowner rehabilitation X Provision of downpayment or closing cost assistance X Brokering or other real estate transactions when CHDO acts as a conduit for HOME funds X NCDA 2017

Community Housing Development Organizations • CHDOs vs. CBDOs – Community Based Development Organizations • Used in CDBG Programs – Can do some things CDBG grantees cannot » New Housing Construction • Similar but do not automatically qualify as CHDOs – May have to change board and by-laws • For-profits may be CBDOs but not CHDOs NCDA 2017

Special CHDO Costs - I • There are 3 kinds: – CHDO Capacity Building – Project-specific CHDO loans: • Technical assistance and site control loans, and • Seed money loans. – CHDO Operating Costs NCDA 2017

Special CHDO Costs - II • CHDO Capacity Building – PJ may provide capacity building funds: • Only during PJ’s 1 st two years, • If no capable organizations, • Lesser of: – 20% of CHDO Set aside; or – $150, 000 NCDA 2017

Special CHDO Costs - III • Project-specific CHDO loans: – Up to 10% of CHDO Set aside: • Technical assistance and site control loans – Costs necessary to determine project feasibility • Seed money loans – Preconstruction costs – CHDO must have site control, preliminary financing commitment and capable development team • Must repay from construction loan proceeds or other project income, however: – PJ may waive repayment, if it determines impediments beyond CHDO’s control. NCDA 2017

Special CHDO Costs - IV • CHDO Operating Costs – Costs include salaries, wages, benefits, training & travel, rent, utilities, etc. – Up to 5% of PJ’s HOME Allocation (not just CHDO Set aside) • Up to the greater of: – 50% of CHDO’s total operating expenses, or – $50, 000 – CHDO must have: • Current CHDO Set aside project, or • Written agreement w/ PJ to have one within 2 years • Can’t be acting only as subrecipient – Doesn’t count: • Toward required 15% CHDO Set-aside • Against 10% HOME administrative Cap • Doesn’t require HOME Match NCDA 2017

Other Special CHDO Requirements - I • Tenant Participation Plan – CHDO must adopt and follow: • Fair lease and grievance procedure (approved by PJ) • Plan for tenant participation in management decisions NCDA 2017

Other Special CHDO Requirements - II • CHDO Proceeds - I – Proceeds resulting from investment of CHDO Setaside funds, for example: • • Permanent financing used to pay off construction loan Sale of rental housing to second non-profit Sale of ownership housing Loan payments from homebuyer – But not rental income (also not HOME PI) – Also, not proceeds from CHDO as subrecipient activities (but is HOME PI) NCDA 2017

Other Special CHDO Requirements - III • CHDO Proceeds – II – PJ may allow CHDO to keep proceeds or require return to PJ • Written agreement must specify: – – Proceeds retained or returned Requirements for use Reports Documents – Proceeds returned to PJ are HOME PI – Proceeds retained are not HOME PI • Not subject to HOME rules • Must be used for HOME-eligible housing • Provide CHDO with equity NCDA 2017

HOME CHDO Questions • Springtown receives $1 M in HOME funds in PY 16, and they have one CHDO that requests $140, 000. They decide to give them the full amount. Have they met the CHDO set-aside requirement? • What would be their next steps? NCDA 2017

HOME Program Examples • Complete the HOME Budget Worksheet for your PJ • Record the number of Households assisted for each HOME-funded activity • Compare your HOME program budget and outcome data with your others in your group • What ideas can you share about the differences/similarities? NCDA 2017

DISCUSSION/QUESTIONS THANK YOU!! NCDA 2017