Rural Development RRHA of Illinois “Happy 5-15 Day” Hot Topics in 2013 Barry Ramsey Housing Program Director Rural Development • • • • Sequestration and 2013 Budget Impacts RD Portfolio Overview (Then & Now) Collaboration with Treasury & HUD IRS Reporting on Predetermined Amortization Schedule System (PASS) Loans • 2014 Outlook – • “The future ain’t what it used to be.” - Yogi Berra Sequestration…and the 2013 Budget • Sequestration triggered a 5% cut of all domestic discretionary funding (RD loans, grants & RA) • The 2013 budget reduced RA by an additional 2.77% • Renewal shortfalls are anticipated for 25-30 properties in IL this year • April memo from Dallas Tonsager sent to MFH Property Owners $1,300 $1,250 $1,200 $1,150 $1,100 $1,050 $1,000 $950 $900 $850 Renewals ($m) 2013 Budget ($837m) 2014 Proposed ($1,015m) $800 2013 2014 2015 2016 2017 2018 2019 2020 Rental Assistance USDA has developed some actions for reducing RA costs – The renewal cost of RA in 2013 is expected to be $933 million; plans to offset that figure with about $31 million in savings from initiatives are underway: Use of Overage (overage collected will be converted to RA renewal dollars); No incentive offers have been made to prepaying projects since August 2012. A notice will soon be published outlining plans to make offers which can be funded. Additional RA won’t be part of the offer if it is not available; No RA is anticipated for MPR rehabs or new construction projects; RA funds from prepaid and foreclosed properties is being converted into RA renewals; RA not used for 6 consecutive months will no longer be transferred to other properties by State Directors, but will be converted to RA renewals; Increased enforcement of occupancy standards targeting “over-housed” RA units like 1 person in a 2 bedroom unit when a 1 bedroom unit is available; Continued emphasis through nationwide audits of tenant certification renewals with RA for correct income and asset documentation including death records maintained by the Social Security Administration. Savings efforts may still result in a shortfall for some properties. MFH Budget Summary MFH Programs ($m) #MFH Loans for REO Sales *Guaranteed 538 Direct 515 RRH Loans Rental Assistance MPR Rehab Demo (Outlay) MFH Vouchers Housing Preservation Grants Farm Labor Housing Loans Farm Labor Housing Grants FY 2010 Enacted FY 2011 Enacted FY 2012 Enacted FY 2013 Enacted FY 2014 Proposed 130 70 980 26 16 11 26 9 31 69 954 13 16 10 19 9 130 64 904 2 11 3 21 7 150 29 837 16 9 3 21 8 150 28 1,015 20 13 24 8 #No funds are designated for Agency financing on REO properties (other than the $29m in 515 loan funds for general use) *Guaranteed loans are paid from Lender fees – no cost to the Government RD PORTFOLIO (THEN & NOW) CASELOAD 1995 2013 Change RRH Properties (IL) 785 567 -27.8% RRH Total Units (IL) 11,808 10,456 -11.4% Rental Assistance Units 6,576 7,370 +12.1% % Units with RA 55.7% 70.4% +14.7% Project Size (IL) 15.0 units 18.4 units +22.7% 11.4% of units have prepaid or been foreclosed, 16.4% of units have been consolidated into another project, 12.1% in additional RA has been provided (794 more units) from new projects or incentive offers to prevent prepayments, Today, over 70% of units in Illinois include RA funded by USDA. RD PORTFOLIO (THEN & NOW) 56 ILLINOIS 57 Category 1 Category 2 581 properties (8/2011) Category 3 567 properties (5/2013) 468 40 53 Category 1 Category 2 Category 3 474 Category 1 = needed, but able to prepay; Category 2 = needed, core properties to preserve; Category 3 = not needed, not viable to preserve Collaboration with Treasury & HUD Financial Reporting – consistency for annual audits and AUP requirements Physical Inspections – acceptance of another Agency’s reports Subsidy Layering – common underwriting for RD/HUD acquisition/rehab tax credit deals Income Reporting / Definitions – common recertification form for all Capital Needs Assessments – HUD template Fair Housing Compliance Enforcement – coop agreements between USDA & HUD IRS Reporting & PASS IRS reporting is based on an IRS News Release, IR-85-55, dated 6/3/85 and states “If loan is governed by PASS, the borrower may deduct interest computed at the full note rate of interest, but must include in income the loan credit provided by the FmHA”. IRS form 1098 reports as an expense: Interest paid by the borrower cash, RA, overage collected & PASS Subsidy IRS form 1099-MISC reports as income: Rental Assistance Payments, and PASS Interest Credit Subsidy Payments Example $1,000,000 PASS loan closed in 1986 for 50 years at 10.625% note rate and plan II interest credit at 1% 10.625% = $8,899.07 note payment 1.0% = $2,118.59 reduced payment Difference = $6,780.48 monthly subsidy With no extra payments, interest due at installment 438 equals the subsidy amount and the approx. loan balance = $764,000 (in year 37); With a $10,000 extra payment, interest due at installment 314 equals the subsidy amount and the approx. loan balance = $764,000 (in year 27) Example At the point when the subsidy equals the monthly interest, part of the subsidy also pays monthly principal In our $1,000,000 loan example, this occurs in 2022. For the next 13.5 years: Subsidy = $1,105,218 which is taxable income Interest = $684,405 which is an expense Difference= $420,813 which is “phantom income” With a $10,000 extra payment, this event occurs in 2012 (10 years sooner). For the next 13.5 years, it’s the same story: subsidy exceeds interest by $420,813 The loan pays off in 2025, almost 11 years early! What Can I Do Says the Borrower? Do Nothing…pay taxes on $420,813 and pay in full just over 10 years early Reamortize / same rate and term (spread the $10,000 payment over the original loan term cutting the phantom income by 55%) Reamortize / new rate and term (smaller payment & subsidy drops phantom income 90% in 30 years) $1,200,000 $1,000,000 $800,000 $600,000 $400,000 $200,000 Subsidy Interest Phantom Income $0 A 30 year new rate/term amortization postpones phantom income from subsidy for another 20 years; A 50 year new rate/term amortization has no phantom income from subsidy during the entire 30 year loan term. Questions? Rural Development is an Equal Opportunity Lender, Provider, and Employer. Complaints of discrimination should be sent to USDA, Director, Office of Civil Rights, Washington, D. C. 20250-9410.