AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
All comments regarding the Draft Plans must be submitted using this form. General Comments may be submitted at the bottom of
the form. Comments which include cut-and paste text (or redlined or re-worded sections) of the proposed Plans will be rejected.
Please provide full explanatory and careful comments regarding your proposed changes, keeping in mind that your proposed
changes might have an unintended consequence for a different project or location in the state. All forms should be submitted to
ahfa.mf.qap@ahfa.com as an attachment to the email. Other documentation, e.g., product information or photos, may also be
submittedt6. Upon close of the commenting period, all comments will be posted at www.ahfa.com for review.
11/6/2015
Name: David Morrow
Plan Section
Organization: Morrow Realty
Section
Reference
Section
Page #
Housing Credit
Add A - Point
Scoring
2
Housing Credit
Add A - Point
Scoring
5
General Comment
Housing Credit
Add D Compliance
3-8
Email: davidm@morrowrealty.com
Phone: 205-759-5781
Specific Comments
A telephone availability letter should not be required to be
submitted in the application package. Most residents use cell
phones and the requirement for such a letter is outdated. This
would allow applicants to spend more time on putting
together a quality application instead of chasing down such
letters.
Delete tiebreaker No. 2 (priority will be given to the owner
who requested the least amount of Housing Credits per unit)
or move it down and make it the last tiebreaker. Including
this tiebreaker would cause applicants to seek to request
funds that are too small to make deals feasible or are
otherwise not up to the quality standards that Alabama has
enjoyed over the years. This is evidenced by other states who
have used this methodology to negative results.
The subsidy point spread is too large. Generally, private
developers can only get smaller per unit values associated
with the FHLB's AHP program. Please revise as follows:
7 points - $10,001 or more per unit
6 points - $8,001 to $10,000 per unit
5 points - $4,000 to $8,000 per unit
An owner and management company should have an
opportunity to cure prior to duduction of application
compliance points and being deemed "non-compliant". Unit
inspections for compliance by the owner or management
company more often than monthly wil interfere with the
tenant's right to quite enjoyment of their apartment.
Section II.B. Amend to provide that AHFA will not assess
penalty points based upon governmental inspection reports
until AHFA (or its designated representative) has investigated
the noncompliance alleged in such governmental inspection
reports. With the exception of state governmental entities
AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
General Comment
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which regularly audit compliance with Section 42 of the Code,
a report from an outside party many not necessarily be a
reliable indication of compliance or noncompliance.
Any and all construction or rehabilitation underwriting cost
guidelines, particularly construction costs, should be disclosed
in written form if there are any thresholds or limits that
Developers need to fall within. Currently there is a cost
reasonableness test for eligibility and/or allowable credits or
HOME funds, but no one knows what it is. Developers need to
make informed decisions with regards to spending a large
sums of predevelopment costs if they do not know they will
qualify or have sufficient resources. There should also not be a
one size fits all cost guidelines as some costs are higher if
located in certain areas of the state that have to meet more
stringent construction standards for hurricanes for instance.
Additionally, tax exempt bond rehabs may be structured
differently in financing and timing of construction costs spread
out over time so it would not be apples to apples in comparing
the construction costs up front or the scope of work done up
front to stand alone 9% rehab projects.
AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
Plan
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