NCSHA_HOME_Breaking_News_HUD

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HOME Program
Breaking News
NCSHA HFA Institute
January 12, 2015
FY 2015 HOME Budget Picture
• HOME FY 2015 Appropriation: $900 Million
• 47% Decrease since FY 2010
• Administration budget proposed eliminating
continuous grandfathering/reduce # of local PJs
• Local PJs receiving less than $500K in 3 years of 5-year
Con Plan cycle would lose PJ status
• If appropriation increased, PJs receiving allocations
>$500K would re-enter program
2
HOME Rulemaking
• HOME Rule published July 24, 2013
– Most provisions apply prospectively to projects
committed after 8/23/13
– Provisions w/delayed effective dates now effective
• Separate CHDO expenditure deadline
• Property Standards, Inspections, Utility Allowances –
were to go into effect 1/24/15 – stay tuned for
additional information
– Technical Corrections due to be published late this
month
3
Upcoming HOME Guidance
• New/Revised CPD Notices
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–
–
–
–
–
–
CHDO Qualifications and Roles
Project Underwriting and Subsidy Layering
Homebuyer Policies and Underwriting
Match – updated for new rule
Cost Allocation
Deadline Compliance – updated for new rule
Requirements for Committing Funds
• Applicability Charts
Slide 4
FIFO Change
• First-In-First-Out Disbursements
– For FY15 & subsequent grants, IDIS will no longer
function FIFO.
• FY 14 and prior grants will continue FIFO
– PJ will commit HOME funds from a specific year’s
grant to a project. When the PJ draws funds for
that project, the funds specifically committed to
those projects will be disbursed through IDIS.
– Guidance on new IDIS functionality coming soon.
5
HOME Commitment Change
• GAO issued opinion that HUD’s current
“cumulative method” violates Sec 218(g) of
NAHA, which establishes 24-month
commitment requirement.
– HUD is required to implement commitment and
CHDO reservation requirements on a grantspecific basis
• HUD drafting proposed rule to implement
grant-specific method
6
HOME Commitments
• GAO Decision: HUD must change method of
determining compliance with commitment deadlines
from “cumulative method” to “grant-specific method”
– PJs required to commit funds from each specific grant
within 24 months
– 15% of each grant must be used for CHDO set-aside
project (no more cumulative average)
• HOME funds that become uncommitted after 24
month deadline cannot be recommitted
– Cancelled projects
– Projects completed below budget
• Change to treatment of program income required
7
HOME Commitments
• HUD anticipates significant increase in deobligations for:
– Failure to commit timely
– Funds becoming uncommitted after deadline
• HUD is seeking a legislative fix that would establish
cumulative method/CHDO cumulative average in statute
– New methodology may apply as early as FY 15 grants
with deadlines occurring in 2017
• Proposed and final rulemaking required
8
Additional HOME Rulemaking
• Conforming changes to HOME rule will be made
through upcoming regulations issued for:
– New Violence Against Women Act (VAWA) provisions
– 2 CFR Part 200 Changes
• HUD expects to draft another proposed rule for
HOME to include:
– HERA exception to HOME rents for units occupied by
HCV holders
– Alternative to 221(d)(3) limits
– Tweaks to July 2013 rule provisions
9
HOME TA & Training
• CHDO Workshops (for CHDOs and PJs)
– 25 Workshops Spring 2014 – Fall 2014
– HUD provided travel scholarships to more than 200 CHDOs
• Updated Building HOME deliveries have begun
– 25 Workshops Fall 2014 – Spring 2015
– Building HOME is going online
• HOME Regulations Cert and Admin Cert courses: 2015
• Project Underwriting & Subsidy Layering: 2015
• Underwriting Homebuyers: Winter 2015
Slide 10
Where to Find It
• For information on HOME training, policy
guidance, TA products, visit
www.hudexchange.info
• Sign up for HOME listserv
https://www.hudexchange.info/mailinglist/
Slide 11
FINANCIAL & INFORMATION
SERVICES DIVISION
UPDATE
HOME Accomplishments
• Over history of the HOME program (through
December 1, 2014):
– 1,189,846 HOME units completed
• 465,077 rental units (39.1%)
• 493,842 homebuyer units (41.5%)
• 230,927 homeowner rehab units (19.4%)
– 296,084 households received TBRA
– Historical average HOME cost/unit = $23,470
– Historical average TBRA/household = $3,185
– Historical leveraging 4.17 : 1
13
FY 2014 HOME PJs / Funding
• 640 Participating Jurisdictions
– 52 states (including DC and Puerto Rico)
– 584 local PJs (including 142 consortia)
– 4 Insular Areas
• FY 2014 Funding level $1 billion
– Added $12.7 million in prior year recaptured
funds
14
HOME FY 2014 Accomplishments
• 39,825 HOME units completed
• 20,540 rental units (51.6%)
• 12,854 homebuyer units (32.3%)
• 6,431 homeowner rehab units (16.1%)
• 11,744 households assisted with TBRA
15
Cumulative / FY 2014 Tenure Type
16
HOME Four-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
FY 2013
20,929
15,350
10,547
46,826
12,363
FY 2014
20,540
12,854
6,431
39,825
11,744
17
FY 2007 - 2014 Accomplishments
18
FY 2007 - 2015 Appropriations
19
Changes for FY 2015
• FIFO (first-in, first-out) accounting
– Commits and disburses oldest available
funds first by fund type and recipient
– For 1992 - 2014 HOME grants
• Grant-based accounting
– Commits funds from a specific grant and
disburses the same funds
– For 2015+ grants
20
Report Changes
• Deadline Compliance Status Report
– 2015 deadlines:
• Commitment requirement for grants through 2013
– Includes new CHDO commitment requirement
• Disbursement requirement for grants through 2010
– Includes new CHDO disbursement requirement
– Cumulative requirements
– CHDO reservation requirement removed
– New CPD Notice issued shortly
21
Report Changes
• IDIS PR27 Report
– Change in commitment and CHDO commitment
requirement
– Additional fund types not yet available to PJs
• IDIS PR49 Report
– Changed for 2015 deadlines:
• Includes new CHDO commitment requirement
• Includes new CHDO disbursement requirement
• CHDO reservation requirement removed
– Cumulative requirements
22
TCAP Accomplishments
•
•
•
•
•
$2.25 billion+ expended
62,305 TCAP units reported completed
60,494 units reported occupied
1,811 units reported vacant
9 activities remain open in IDIS
– ARKANSAS DEVELOPMENT FINANCE AUTHORITY (1)
– DISTRICT OF COLUMBIA DEPARTMENT OF
HOUSING AND COMMUNITY DEVELOPMENT (3)
– LOUISIANA HOUSING FINANCE AGENCY (1)
– MINNESOTA HOUSING FINANCE AGENCY (4)
23
TCAP Closeout
• All Financial Closeouts completed
• Grant Closeout Procedures forthcoming
• All TCAP activities must be marked
completed in IDIS
• All TCAP units must be marked occupied
in IDIS with applicable beneficiary
characteristics entered in the system
24
25
Housing Trust Fund
• The HTF was established in the Housing and Economic
Recovery Act (HERA) on July 30, 2008
• Goals of the HTF: to increase and preserve the supply of
decent, safe, and affordable housing for extremely low-income
(ELI) and very low-income (VLI) households, with primary
attention to rental housing
• Per HERA, GSEs (Fannie Mae and Freddie Mac) are to deposit
4.2 basis points of each dollar of unpaid principal balance of its
total new business purchases during each fiscal year into the
HTF.
26
Housing Trust Fund
• Since 2009, FHFA had suspended these deposits due
to financial viability of Fannie Mae and Freddie Mac
but in December 2014, FHFA terminated suspension
of deposits by GSEs into HTF.
• GSEs are to begin deposits starting with FY 2016
(January 1, 2016)
• Estimates of the expected amounts of these
deposits, and therefore the amount available for
allocation to States, vary widely
27
HTF Overview
HTF Beneficiaries are ELI ( below 30% of area
median income) or VLI (below 50% of area median
income)
•
• At least 80% of each annual formula allocation
must be spent on rental housing
• Up to 10% of each annual formula allocation may
be spent on homeownership
• Up to 10% of each annual formula allocation may
be spent on administrative costs
28
HTF Rulemaking
• Proposed HTF formula rule published on
December 4, 2009
• Proposed program rule published on
October 29, 2010
• Combined regulations to be published
shortly
HTF Formula
Per proposed HTF formula rule published
on December 4, 2009
Formula allocations will be made to states and insular
areas based on statutorily required need based factors
and the relative cost of construction in each state:
1) Shortage of standard rental units affordable and
available to extremely low-income renter households
in the state
2) Shortage of standard rental units affordable and
available to very low-income renter households in the
state
30
HTF Formula
3) The proportion of extremely low-income renter
households in the state living with either incomplete
kitchen or plumbing facilities, more than one person
per room, or paying more than 50% of income for
housing costs
4) The number of very low-income renter households in
the state paying more than 50% of income on rent
5) The relative cost of construction in the state is also
used as a factor that will adjust the amounts in each
state’s formula allocation
31
HTF Participation Requirements
•
HTF funds will be allocated by formula to States
•
To administer HTF allocation, States may designate a:
 State housing finance agency, a housing and
community development entity;
 a tribally designated housing entity (as such term is
defined in section 4 of the Native American Housing
Assistance and Self-Determination Act of 1997 (25
U.S.C. 4103));
 or any other qualified instrumentality of the State to
receive such grant amounts.
32
HTF Participation Requirements
• All States must submit an “HTF Allocation Plan”, which describes
how HTF funds will be distributed, as part of their Consolidated
Plans
• Public participation and input on the HTF Allocation Plan is
required by law
• HTF Allocation Plan must be based on priority housing needs
identified in the Plan
• HTF funds will likely be combined at local level with LIHTC;
HOME; and other Federal, state, and local programs to create
mixed-income communities
33
HTF Implementation
• HTF Regulations published very soon
• States will designate HTF agency AFTER
regulations published
• Formula Allocations will likely be made in
Spring 2016, based on GSE deposits to HTF
made in early 2016.
• States will begin implementation with 2016
Consolidated Plan Program Year
• HTF Allocation Plans due to HUD with 2016
Consolidated Action Plans
34
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