Office of Multifamily Housing
Joe Crisafulli, Boston Hub Director
NCSHA Conference 10/20/14
1
Affordable Housing Preservation Update
• Section 8 Renewal Guide Waiver Authority Delegation
– Purpose: Encourage and streamline affordable housing preservation.
– Authority for 5 Waivers delegated to Hub Directors in field
1.
Prohibition on for-profit participants- Chapter 15
2.
Section 15-8 – Requiring lowering comparable market rent to reflect
use-restricted rent levels.
3.
Section 15-6.C.1. Post-rehab rents effective only at completion of the
rehab.
Affordable Housing Preservation Update Continued
• Section 8 Renewal Guide Waiver Authority Delegation
4.
Section 15-5.B.2- Does not allow for early termination of preMAHRA contract.
5.
Section 3-2.A.- Property score of 60 or above to be eligible for
MUTM.
6. Section 3-7.F.1.d – Allows use of a Lender ordered MAP
appraisal in lieu of a separate RCS for MUTM transaction using
FHA financing. No waiver necessary per 8/28/14 guidance.
Section 8- More Preservation Tools
Combining Section 8 HAP Contracts- Guidance issued via memo
on 9/18/2014 . Benefits: Lower administrative costs, consolidate
oversight, shared reserves, better debt and equity terms and
pricing.
Transferring Budget Authority (aka “Portage”) of PB Section 8 HAP
Contract- Section 8(b)(b)(1) of U.S. Housing Act of 1937- Notice
H14-14 was issued on 10/9/14.
Section 8 Pass Through- Used successfully in preservation
scenarios where units planned for rehab are uninhabitable.
Requires HQ approval.
CNA e Tool
• Origin- 2010 President’s Domestic Policy Council policy alignment
initiative.
• HUD, USDA-RD & Treasury (LIHTCs via HFAs) use capital needs
assessments (CNA)/physical due diligence in their programs.
• Interagency Rental Policy Working Group- incorporated feedback
from multifamily stakeholders, including HFAs, recommended
creation of a data standard and electronic template for CNAs.
CNA e Tool
• CNA e-Tool is born. It is a suite of inter-related tools:
– Aligned electronic template incorporating a data standard for assessments.
– Creates automated process for preparation, review, submission, approval and
periodic updating of CNAs
– Expected to evolve and improve to execute due diligence on asset
acquisition/loan origination, RfR administration and periodic review of capital
needs.
CNA e Tool Coming this Fall
• Initial version of CNA-e Tool is complete. HQ is working on
guidance, training and rollout of the tool. Publication of
the Notice is expected this fall.
• Will become the required standard for HUD and USDA for a
number of programs.
CNA e Tool Roll-out
• Roll-out will:
1.
Introduce the tool and its support, training and
technical assistance tools, etc.
2.
Identify programs that will be required to migrate to
CNA-e-Tool.
• Most likely:
a. All Multifamily FHA applications requiring CNAs
b. All RAD and M2M applications
c. All Asset Management-required CNAs
Rollout, Continued
3. Detail implementation schedule. Likely HUD will:
a. Begin accepting CNAs via the CNA-e-Tool and encouraging
lender’s use 30 days after Notice.
b. Require use of CNA e Tool circa 180 days later.
• Stay tuned.
Electronic template is available in 2 forms: Excel and Business to
Government (B2G) interface (allows assessor firms/lenders to map
existing templates to CNA e Tool). View these at HUD MF homepage:
http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing
/mfh
(See upper right under “What’s New”)
CNA e Tool – take aways
• Flexibility allows use in multiple programs at different
agencies
• Each agency /program will need to develop some specific
guidance conforming to their needs.
• The tool is free. Once it is rolled out it will be available on
the HUD website.
Take Aways Continued
• HUD invites and encourages HFAs to adopt and use it
as their standard CNA tool.
• We hope that CNA e Tool will become an industry
standard used by multiple partners and encourage
commercial add ons such as mobile apps.
• HUD looks forward to working with HFAs that are
interested in utilizing CNA e-Tool
• THANK YOU- Questions/comments to
CNAeTOOL@Hud.Gov
LIHTC Pilot Program Progress Check-in
“The Heavy F”
Geographic Expansion:
– Initial Selection of 4 Pilot Hubs, Expanded to 9
– Initial limit to Pilot Hub Jurisdictions, Expanded to
Include Projects from all States
12
“The Heavy F” Continued
-- Processing System for Projects not In Pilot Hubs
Industry Expansion:
Lender Selection 4th Round Increased Pilot Lender
firms from 37 to 52
13
LIHTC Program Progress Check-in
• Program Rules Refinement (FAQs, Document
Updates)
• Projects In Pipeline (As of 9/8/14)
o
o
o
o
o
14
Concept Meeting Held
Closed
Pilot Hubs with Projects
Lenders with Projects
Average Days to Close
123 Projects/13,582 Units
27 Projects
9
20 of 37
101 (Excludes Applicant Delays)
LIHTC Pilot- Future Program Development
Continued Integration of Pilot with RAD
Recent Policy Development: More flexible rules on
debt limits, IOI transfers, Completion Assurance and
other matters posted on February 28th.
Future Expansion: Program adjustments expected on
an ongoing basis, to be Included in 2014 MAP Guide
Revision
15