2015 QAP/Application Questions
Points/Scoring
1. Question
I was looking for verification with regards to the point that can be achieved for a family deal
with 15% or greater 3 bedroom units. The question relates to a mixed income deal. In order to
get the points on a mixed income project where only a % of the units are set aside as LIHTC
units, can you qualify for the point for having 15% or greater of the LIHTC units as 3 bedroom?
AHFA Response
Based on the language in the scoring addendum, the 15% or greater 3 bedroom units would
apply to the low-income portion of the project.
2. Question
Addendum F, Part II. Penalty Scoring, Fees for Non-Compliance and Suspension Criteria when
referring to the “owner” in this section are the point deductions allocated only to the
underlying General Partner entity or are they applied down to the individual person with
ownership in the project?
Or
Is the term “owner”, for purposes of Addendum F, defined as the General Partner Entity or the
individual person?
AHFA Response
Ownership includes all individuals, shareholders, members, organizations, general and special
limited partners.
3. Question
Concerning points for Federal Historic Tax Credit and Alabama Historic Rehabilitation Tax
Credit, AHFA responded that a Part II as approved by the National Park Service is required.
Why is AHFA requiring a Part II be completed at application time?
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AHFA Response
Should you wish the requirements to be changed, please submit comments during the
commenting period.
4. Question
If the Covered Picnic Pavilion is included in a project for 4 points, can the Picnic Area with Grills
also be included for 2 points? If both can be included in a project for points, must they be at
different locations on the project site? Can they be adjacent to each other as long as all
requirements are met for both amenities?
AHFA Response
Yes, the Covered Picnic Pavilion and Picnic Area with Grills may be combined for one project.
The project architect should be key in assisting with the placement and design for the site.
5. Question
I received a call earlier today from an out-of-state developer asking if the 8609s referred to in
Addendum A Section A.2.(iv) (as seen below) had to be for deals in Alabama. I believe the
intent is that they should be but it does read as though the 8609s do not have to be from a
particular state. Can you please clarify whether or not the 8609 must be for a Project in
Alabama to gain the points as outlined in Addendum A Section A.2(iv)?
AHFA Response
These points are specifically for projects that (a) received 8609’s issued by AHFA or (b) closed
an AHFA HOME loan after 2004.
6. Question
New revised QAP you drafted last week under Project Characteristics (vi) (a). This means HOME
deals that mature the end of 20 years before 2014 or 2015, correct? This year QAP being 2015
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means December 31, 2016 could be within one year. So would 2016 maturing projects also
meet this criteria?
AHFA Response
The final 2015 Housing Credit Qualified Allocation Plan awards points for projects that mature
“prior to or within the year covered by the applicable QAP”. Therefore, only HOME loans that
matured prior to the year of 2015 or will mature during the year 2015 are eligible.
Application Forms
7. Question
If a third-party is planning to complete the online application on behalf of multiple entities,
does it need to submit multiple third party authorization forms?
AHFA Response
Yes, a Third-Party Authorization Form will be required for each ownership entity and included in
the applicable Initial Application Submission.
8. Question
If an entity/member of the ownership structure is completing the application, will a third party
authorization form be required?
AHFA Response
Yes, a Third-Party Authorization Form will be required even if an entity/member of the
ownership structure is completing the application.
9. Question
In point scoring section (iii.) Rent Affordability, the QAP states, “A maximum of 7 points will be
given to projects, which have a commitment for additional subsidies from the … Federal
Historic Tax Credit, Alabama Historic Rehabilitation Tax Credit. The commitment must be a fully
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executed firm commitment from the applicable entity that will be granting the funds to
project.”
In the case of Historic Tax Credits, does “a firm commitment” entail a complete approval of Part
II by the National Park Service, or something short of that?
AHFA Response
Yes. Part II as approved by the National Park Service is required.
10. Question
AHFA DMS Authority Online 3rd Party Authorization Form – What do you want for the owner
entity name? Should this be your LTD or the individual owner? If it for the LTD, we do not have
an owner DMS organization code that is requested? It says all members of the ownership
structure must sign; can just the managing member sign or does every member need to sign
the form?
AHFA Response
To properly complete the AHFA DMS Authorization Form, you must provide the owner entity
name and not the name of an individual.
A DMS organization code will be provided after you provide the completed authorization form
to AHFA.
AHFA requires that every member sign the authorization form.
Application
11. Question
With the application deadline announced to be March 19, can you please confirm that the
deadline to submit the Phase I and market study will be February 17, which is 30 days prior to
the app deadline?
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AHFA Response
Yes, February 17 is the last day for submitting all of the pre-submission application items to
AHFA. This due date is listed in the Application Instructions.
12. Question
How does AHFA intend to handle receipt of the pre-apps due by February 17 since the
workshop is also on that date? Will you have someone set up to take the apps at the workshop
or will we have to deliver them to the AHFA office after the workshop?
AHFA Response
No. Required initial application items will not be accepted at the workshop. Someone will be
at AHFA to receive the initial application items during regular business hours prior to and
ending February 17th at 5:00 p.m. CST.
13. Question
Do you have a date in which, if the cost cert is submitted, it will make the “cutoff” to receive
8609’s in time to be counted toward an “AL Point” for the 2015 application cycle?
AHFA Response
A complete and accurate cost certification must be received by AHFA by 5:00 p.m. (CST) on
February 17, 2015. The 8609s must be issued by AHFA by Monday, March 16, 2015, in order for
them to be considered for any point categories during the 2015 application cycle.
14. Question
On 1a Profile and Initial Application Checklist under #2, for individuals should the a. column be
left blank?
AHFA Response
Yes, column a should be left blank for individual.
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15. Question
Does the legal documents for the ownership entity need to be provided with the initial
application under “Other Supporting Documentation”?
AHFA Response
These documents will be submitted with the final application submission.
16. Question
In regards to the different layers of the ownership entity and credit authorization forms, when
an address is requested should the physical address or the mailing address be listed? Our
mailing addresses are P.O. Boxes, and we have a physical address for courier delivery. Should I
list both physical and mailing addresses?
AHFA Response
For purposes of Credit Authorization Form, provide the physical address.
17. Question
I have a question for the Preliminary Application due 2/17 are we expected to have EIN
numbers for proposed Ownership?
AHFA Response
Tax ID numbers are not required at time of application for newly formed entities.
18. Question
Guidance in regard to zoning; for purposes of a tax credit application will a letter from the
County indicating that the property is “Unzoned” be sufficient to meet threshold for proper
zoning?
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AHFA Response
Yes. Please provide all supporting documentation to verify to AHFA that you have followed the
applicable zoning regulations and rules of the specific County in which your proposed
development will be located.
19. Question
Per the 2015 QAP, if I submit an application requesting HOME funds from AHFA the total
number of units in the development cannot exceed 56.
If I receive HOME funds from a local participating jurisdiction and only request Housing Credits
from AHFA in my application does the 56 unit limit apply?
AHFA Response
AHFA does not dictate local PJ’s requirements. AHFA’s 56 unit requirement is applicable to
AHFA HOME Program funds only.
20. Question
I am aware that with AHFA Home funds we are not allowed to use Section 8 utility allowance.
Does this apply to County or City Home funds also?
AHFA Response
The prohibition against the use of Section 8 utility allowances with HOME Funds is specified in
section 92.252(d) of the HOME Final Rule.
Environmental
21. Question
a. Are Phase I and II’s required for existing properties for rehab?
b. We were just curious as to how an environmental is done on an existing property? You
obviously can’t do soil testing, etc. and the site has been disturbed because buildings
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are already in existence. We have had several environmental agencies ask the same
question even though we have sent them the documents on your web site. We were
just curious and thought you might have a little more information as it pertains to
existing sites.
AHFA Response
a. Per Addendum B of the Plans,
“Alabama Housing Finance Authority (AHFA) requires that a project-specific
Environmental Site Assessment (“ESA”) Phase I Report be submitted for each application
by a third party Environmental Professional (“EP”)…
…For all Applications made to AHFA:
If a Phase I ESA for a project either (a) identifies a Recognized Environmental Condition
(which includes, but is not limited to, controlled recognized environmental conditions,
historical recognized environmental conditions, etc., hereinafter collectively referred to
as (“RECs”)) and or (b) recommends additional testing, investigation or a Phase II Report
be conducted, any and all Phase II Reports and Addendums that are prepared to address
the RECs identified or additional testing recommendations must be included at the time
of report submission.”
b. You may consult with an Environmental Specialist who has done an EPA previously with
AHFA and review Addendum B.
22. Question
Should the Environmentalist doing our ESA do the Environmental Regulatory Checklist if we are
Tax Credit only?
AHFA Response
Addendum B to the allocation plans with all the attachments is required on all applications.
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23. Question
Can you confirm that we can use the asbestos survey from last year on the re-submittal of a tax
credit site with an updated Phase I ESA?
AHFA Response
Yes, a prior year survey is acceptable.
24. Question
I was looking through the package for this year and just wanted to determine if we need to
submit the Exhibit B 1 and 2, and noise study, with tax credit only sites?
AHFA Response
Exhibit B1 and 2, and noise study are required for both HOME & Tax Credit projects this year.
25. Question
The third slide in the PowerPoint Presentations says, “any and/or all environmental concerns
raised will be fully vetted prior to the submission of the environmental report(s). Does this
mean that a Phase I ESA that recommends Phase II should not be submitted until the Phase II is
performed and all environmental issues settled?
AHFA Response
Yes, all environmental concerns should be fully vetted.
Yes.
26. Question
When there is an application for HOME funds what additional environmental investigations,
submittals or certifications are required in addition to what is required for every other AHFA
application?
AHFA Response
All requirements are the same for all applications submitted.
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27. Question
When it is said that the Phase I must be in the format shown in section X4 of the ASTM
standards does that mean that the format of the report must follow that same numbered order
and headings or that all those items be included in eth report?
AHFA Response
Yes, please provide the report in the format specified in Addendum B
28. Question
Regarding asbestos, lead-based paint, mold, radon and PCBs, are the potential presence of any
of these an REC for AHFA purposes and thus cause for additional testing and verification or is it
sufficient to note their potential presence? Under what circumstance does AHFA want to see
testing for each of those items? Regarding lead-based paint, would AHFA like to see chip
samples or XRF?
AHFA Response
Regarding lead based paint testing, If the proposed project involves rehabilitation, removal, or
demolition of a building built prior to 1978, the applicant must provide a LBP report at the time
of the complete application submission and at applicant’s expense. AHFA requires all LBP to be
completely abated (eliminated). A list of licensed LBP contractors can be obtained from the
Alabama Department of Public Health at www.adph.org.
An asbestos testing report will be required on every project that includes demolition or
rehabilitation of any structure. All friable and non-friable ACM in deteriorated condition must
be completely abated. An asbestos contractor’s listing may be obtained from Alabama
Department of Environmental Management (ADEM) (334) 271-7700 or at
www.adem.state.al.us. Non-friable ACMs may be managed in place if in an intact condition. A
site-specific Operations & Maintenance Plan for asbestos must be implemented if ACMs are to
be left in place.
If your phase I report recommends any additional testing other than the above lead based paint
and asbestos testing reports, all testing must be completed and cleared prior to initial
application submission.
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29. Question
There is no specific mention of vapor intrusion. While an opinion regarding vapor intrusion
would normally be discussed in a Phase I ESA as part of the potential effects of on-site and offsite RECs or assessed as part of a Phase II, if indicated, AHFA has indicated in the past that a
specific ASTM E2600 Vapor Encroachment Screening was required. Is an E2600 VES required?
AHFA Response
No, the E2600 Vapor Encroachment Screening is not required, unless the RECs indicate findings.
30. Question
Addendum B2, Manmade Hazards, asks about aboveground storage tanks (ASTs) of 100 gallons
or more within 1 mile of the subject site. While this is beyond the ASTM E1527 search distance
for registered storage tanks we can ask for an expanded search. However, AST registration is
optional and not required in Alabama so an expanded radius search would not necessarily
reveal the information requested. Can you tell us how others have been addressing this
question?
AHFA Response
AHFA requires the expanded search in addition to the ASTM E1527 search.
31. Question
Client is looking at renovating an abandoned apartment building, and making an application to
AHFA. Would you require the lead base paint survey to include a sampling (say 3) units of this
1948 building, or do you require the LBP survey be in accordance with HUD requirements
(which would mean 38 units). There are no HOME funds being requested.
AHFA Response
Instructions on lead base paint and asbestos will be released with the final application
documents.
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32. Question
We are working on an acquisition rehab of an old USDA RD 515/LIHTC deal. The site itself is in
the floodplain, it has a blue line stream on the edge as well as a small amount of possible
wetlands around the stream.
If we get flood insurance and don’t disturb the stream or the possible wetland (they are both
undeveloped and on the edge of the site) with it work? Do we have to cut off the
stream/possible wetlands on the survey or can they be part of the site?
AHFA Response
Our requirements for flood plain/wetlands are located in the 2015 Housing Credit Allocation
Plan section II.C.#11.
33. Question
I have reviewed AHFA guidelines in depth but typically, Elderly facilities are exempt from LBP
testing, and there is no classification on Multifamily vs Elderly regarding LBP in AHFA’s
guidelines. The draft 2015 Addendum B-1 #3 states, “The Phase I ESA Report must address and
discuss, at a minimum the following issues in connection with the proposed site: asbestos, lead
based paint, mold, radon, wetlands, and PCBs.” Please advise if AHFA will accept a discussion in
our report similar to the following:
“The facility was originally constructed in 1927, prior to the 1978 ban on lead-based
paint (LBP). Therefore, lead-based paint may be present. Lead-based paint is presumed
to have been used on interior and exterior surfaces of the facility. No peeling or flaking
paint was observed at the subject property at the time of the subject property
inspection. Applicable protocols do not typically regulate facilities that are occupied by
senior citizens and/or disabled individuals.”
OR, will AHFA require testing? If AHFA will require testing on this elderly facility, please advise
as to scope you will need LBP Testing to be in accordance with (i.e. HUD Table 7.3 and the HUD
Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Chapter 7
Lead-Based Paint Inspection, 2012 Revision, etc..)
AHFA Response
Testing is required on any building built prior to 1978. AHFA does not have separate testing
requirements for elderly or family developments. We also do not specify standards for testing
as AHFA requires that all LBP & ACM related hazards be completely abated (eliminated).
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34. Question
In regards to the flood certification (#11 Threshold) would you please clarify the sentence
stating that "No portion of the site may contain wetlands, including any portion not considered
part of the site but necessary for ingress and egress to the site" If a site has to cross a wetland
area, by access if a bridge of culvert, is this considered ingress or egress, or does the wetland
area have to be adjacent to site?
AHFA Response
Yes. If the wetland area is adjacent or suspected to be adjacent to the site, you must provide a
U.S. Army Corps of Engineers delineation for the proposed site and adjacent area(s). A bridge
or culvert necessary for ingress or egress is not allowed
Schedule of Real Estate Owned
35. Question
Concerning the Schedule of Real Estate Owned, if the ownership entity is newly formed, and
the individual members involved in the ownership entity have been involved in more than three
placed in service projects with AHFA is Part 1 required? If the newly formed ownership entity
and the individual members involved don’t have any approved projects or any currently under
construction is Part 2 required? If Part 1 and Part 2 are not required, how should the Index
page for 5a Schedule of Real Estate Owned be marked since there is not a box for Not
Applicable?
AHFA Response
The Schedule of Real Estate Owned form (Initial Application Submission) for owners with less
than three (3) placed in service projects with Housing Credits and/or HOME funds awarded by
AHFA should not be submitted for newly formed entities. Parts I & 2 of the Schedule of Real
Estate Owned form should be submitted. Indicate N/A on Part 2 of the form if the owner does
not have any projects approved or currently under construction.
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36. Question
If AHFA only wants the Schedule of Real Estate if the owner has less than 3 placed in service
projects thru AHFA, how will you arrive at the maximum points for ownership and management
if we use any of our deals in other states?
AHFA Response
The Schedule of Real Estate Owned form for owners with less than three (3) AHFA placed in
service projects is an “Initial Application” requirement. For scoring purposes, additional
Schedule of Real Estate Owned forms should be completed by the applicant and submitted with
the “Final Application”.
37. Question
In terms of No. 5a of the Initial Application, an applicant must submit the form if they have less
than 3 projects "placed in service." If an applicant has two projects where AHFA has issued
8609’s and one project where COs have been issued for all units (and the property is leased)
but no 8609s have been issued, does the applicant have to submit the form?
AHFA Response
Yes. List all projects that have been placed in service
38. Question
If the ownership in an application collectively has at least three AHFA deals where 8609s were awarded,
but one of the individuals in the ownership does not, is the form still required?
AHFA Response
Yes, the form is still required on the individual or entity which does not meet the minimum
standard.
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39. Question
I need clarification with regards to the Schedule of Real Estate Owned (Part 1).
It states that any project listed that has not received Tax Credits or HOME Funds from AHFA, to attach a
certification from the financing entity verifying your ownership and number of units.
Is the financing entity the mortgage holder or the State Housing Finance Agency that allocated the Tax
Credits and/or HOME Funds?
AHFA Response
The certification from the financing entity verifying ownership and the number of units listed on the
Schedule of Real Estate Owned (Part I), can be provided by the mortgage holder or the Housing Finance
Agency.
40. Question
REO Forms – does this form need to be submitted for all owners with less than 3 deals such as a
newly formed LTD or LLC that does not own anything?
AHFA Response
No. The REO Form or the applicable fee is not required for newly formed entities.
Market Study
41. Question
When will the List of Market Analysts that have participated in an AHFA cycle be available?
AHFA Response
The List of Market Analysts that have participated in an AHFA cycle has been updated and
added to ahfa.com.
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42. Question
In changes to Market Study, Expanded Item D. Market Analysis, would you please verify that
the appropriate inclusion for calculating Average Rents is as follows?
a.
HC - Stand Alone Tax Credit Projects and Rural Development projects with Tax
Credits.
b. HOME - All project’s with State HOME Funds. What about project’s with just City or
County HOME Funds?
c.
RD – Rural Development Projects without tax credits. What about RD Projects
with Tax Credits? Are these to be included in HC.
AHFA Response
a. HC (Housing Credit) – will include Stand Alone Tax Credit Projects & Rural Development
Projects with Tax Credits
b. HOME – will include projects with HOME Funds (State/City/County)
c. Rural Development – will include Rural Development Projects without Tax Credits only
43. Question
Do you want MI/MR projects excluded from the market study?
AHFA Response
If projects are not Conventional, Rural Development, HC, or HOME (as described above) then
they should be excluded in the Average Rents section.
44. Question
Do you want all HUD projects excluded from the market study?
AHFA Response
If projects are not Conventional, Rural Development, HC, or HOME (as described above) then
they should be excluded in the Average Rents section.
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45. Question
Where is the 2015 Market Study Certification Form located?
AHFA Response
1)
2)
3)
4)
Go to AHFA website – www.ahfa.com
Under Multifamily, select “Allocation & Application Info”
On the left of the page, Select “Apply for Funding”
Under “2015 Initial Application Forms & Instructions”, Select “2015 Initial Application
Form Package with Index Pages”
5) All forms required for a 2015 Application are available within this excel workbook,
including the Market Study Certification Form (Labeled Certification)
46. Question
Historically we have always entered forecasted demand in Item “D” in the Certification
Question “Demand from New Renter Households” which included both existing demand and
new demand. This is the analysis compiling demand from turnover of existing units and new
households entering the market (negative if they are existing and the market is shrinking). For
example turnover creates demand for 188 units with 5 additional units added to demand for
next year calculating total demand of 193.
In the certification question “Demand from New Renter Households” are you asking for the 193
in the example or the 5 in the example?
AHFA Response
In order to answer the Demand Analysis section of the Market Certification regarding your
example, the question “Demand from New Renter Households” should be answered with “5
additional Units.” Also, the demand from turnover of existing units will be combined with the
“Demand for the New Renter Households” to answer “Total Demand for the proposed project”.
Underwriting
47. Question
It was mentioned during ALCARH that potentially 50% of the HOME funds could be used during
construction. Will this be the case for 2015 HOME Projects?
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AHFA Response
No. AHFA does not allocate HOME funds during the construction period.
48. Question
With the addition of a penalty to the extension requests, will extension fees now be allowable
Development Cost for the Cost Certification?
AHFA Response
No, they will not be allowable.
49. Question
Are any of the Average Rents calculated with duplicates so as to have one project included in
more than one classification?
AHFA Response
No, projects should not be included in more than one classification.
50. Question
a. On the checklist under Supply Analysis (page 3) you ask for # of ALL EXISTING RENTAL
UNITS, which I interpret to be all units including both conventional projects and all
subsidized units of every type?
b. The request for # of all AHFA and/or Subsidized Units I interpret to be those same units
in the prior calculation but excluding conventional projects?
c. The occupancy rate you request, do you want it modified to exclude those complexes
that would not provide occupancy information?
AHFA Response
a. All Existing Rental Units – Yes, it includes both conventional and all subsidized units
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b. # of all AHFA and/or Subsidized Units – Yes, the same units in prior calculation
(excluding conventional projects)
c. Occupancy Rate – Yes, exclude complexes that do not provide occupancy information
51. Question
Regarding Underwriting- Is the 5% vacancy allowed for projects with RA or HAP contracts?
AHFA Response
7 % will be used as the vacancy rate for all projects.
52. Question
Will LIHTC only properties be underwritten for 20 years to maintain the required DSCR or will it
be 15 years?
AHFA Response
LIHTC properties – (without HOME funds) underwritten for 15 years
53. Question
Will the replacement reserves also be trended at 3%?
AHFA Response
No. Replacement reserves are not trended at 3%.
54. Question
How does AHFA calculate capture rate?
AHFA Response
AHFA calculates the capture rate via the following formula.
Capture Rate = the total # of units/ the # of eligible households
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55. Question
Will LIHTC properties be underwritten for 20 years to maintain the required DSCR or will they
be underwritten for 15 years?
AHFA Response
LIHTC properties – (without HOME funds) underwritten for 15 years
56. Question
Is the 5% vacancy still applicable for those Projects with RA or HAP Contract? Do we need to
use 7 for units at 60% rent not covered by RA or HAP?
AHFA Response
Vacancy Rate – 7%
57. Question
Some people underwrite management fees as an operating expense that increases at 3% while
others utilize the management fee % which will make it trend at 2% or in line with revenue.
Which way will AHFA be underwriting?
AHFA Response
Refer to the Alabama Housing Finance Authority’s 2015 Underwriting Standards for Multifamily
Housing Overview located at ahfa.com.
58. Question
Would replacement reserves be considered fully funded if the balance is equal to the number
of units x ($250 or $300 as applicable) x 15 years for LIHTC-only Projects?
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AHFA Response
No, the replacement reserves would be considered fully funded if the balance is equal to the
number of units x ($250 or $300 as applicable) x 30 years for LIHTC-only projects. Please refer
to Section II. E. 1. iii. of the 2015 Housing Credit Qualified Allocation Plan.
59. Question
Would replacement reserves be considered fully funded if the balance is equal to the number
of units x ($250 or $300 as applicable) x 20 years for HOME Projects?
AHFA Response
No, the replacement reserves would be considered fully funded if the balance is equal to the
number of units x ($250 or $300 as applicable) x 30 years for LIHTC-only projects. Please refer
to Section IV. E. 1. iii. of the 2015 HOME Action Plan.
60. Question
If the replacement reserves are fully funded, will the AHFA 2015 underwriting standard of
Operating Expenses ($4,375 per unit) be reduced by the applicable replacement reserve
required deposits for AHFA underwriting purposes?
AHFA Response
Yes, the standard of operating expenses ($4,375 per unit) will be reduced by the applicable
replacement reserve required deposits for AHFA underwriting purposes.
61. Question
Will AHFA allow for a lower operating expense per unit for underwriting if there are similar
properties that have historically operated at a lower operating expense per unit? For example,
we have provided letters summarizing the historical operating expenses of similar properties
for previous applications.
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AHFA Response
Yes. Provide supporting documentation.
62. Question
AHFA’s standard for first mortgage interest rate is 7%. We have a quote from our bank at
6.5%. Can we use the lower quoted rate?
AHFA Response
Yes. Provide supporting documentation.
63. Question
AHFA’s standard for housing credit price is $0.90. We have a quote from our syndicator for
$0.92. Can we use the higher quoted price?
AHFA Response
Yes. Provide supporting documentation.
64. Question
AHFA’s standard for operating expenses per unit is $4,375. Can we use a lower amount per unit
based off of our management company’s past experience?
AHFA Response
Yes. Provide supporting documentation.
65. Question
If a project has LIHTC and City or County HOME Funds but no State Home Funds; would the
appropriate Income/Rent Limits be the LIHTC or HOME Income/Rent Limits?
AHFA Response
If a project has LIHTC and City or County HOME Funds but no State Home Funds, then the
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appropriate Income/Rent Limits would be the HOME Income/Rent Limits.
66. Question
In reference to my prior question concerning Income/Rent Limits, let me extend that question a
little. The developer’s pro-forma I am looking at has mixed and matched from both the HOME
and the LIHTC Income/Rent Limit. I would have thought it would be one or the other for all
tenants and rents and in this case with city or county HOME funds, it would have been the
HOME Income and Rent Limits.
AHFA Response
The HOME Income/Rent Limits should be used for the appropriate amount of units with HOME
funds. If this does not include the entire project, then the remaining units will have to follow
the LIHTC Income/Rent Limits.
67. Question
I have a question/clarification with regards to page 9 of the draft 2015 Housing Credit QAP.
Page 9 regarding the market study criteria, Subsection (ii); it reads:
Active AHFA projects in the defined market area must have an overall average stabilized
vacancy rate of fifteen percent (15%) or above. Active is defined as any AHFA project that is
still in its applicable compliance period and extended-use period.
Can you clarify this particular section for me? I am having difficulty understanding the exact
meaning.
AHFA Response
If the results of the market study show that active AHFA projects within the market area where
the proposed project will be located have occupancy rates of 85% or lower, then the
application will be terminated due to an insufficient need for more housing. (85% or lower
occupancy rate is another way to look at 15% or higher vacancy rate).
(A complete cost certification is defined as there are no additional items required or requested
by AHFA, all permanent sources of financing have been closed and all items in the cost
certification are correct.)
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68. Question
Do the 2015 underwriting standards listed on the website below apply to 4% deals also?
If we have documented letters of intent for higher credit prices and lower permanent debt will
AHFA accept these instead of the underwriting standards or will the deal need to be
underwritten with the posted guidelines?
AHFA Response
Please provide supporting documentation for our review so that we can consider reducing the
first mortgage interest rate for underwriting purposes. Regarding your question concerning the
4% Housing Credit Rate, AHFA will use a 3-month average of the credit rate when underwriting.
Fees
69. Question
Under 5b, if an applicant has zero projects (AHFA or otherwise), does the applicant need to
submit the $2,000.00 fee?
AHFA Response
No. The applicable fee is not required for newly formed entities.
70. Question
Under 5b, if two members of the applicant have less than 3 AHFA deals, is one $2000 fee
required or does each submit a separate fee ($4000 total). If a third member of the same
applicant has ten deals with three under the AHFA, is the $2,000 required for the overall
applicant?
AHFA Response
The fee is per application.
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71. Question
Section I. D. 3. Project Inspection Fee (pages 9 & 10)
This section requires a $2,000 deposit and a Schedule of Real Estate Owned for projects with
an owner or owners that have ownership in less three (3) placed in service projects funded with
Housing Credits or HOME funds awarded by AHFA.
“I am an owner in 4 Alabama projects that have received certificates of occupancy and are
placed in service. However, two (2) of the projects have not received forms 8609 yet. Is receipt
of the Certificates of Occupancy sufficient to meet the standard of placed in service as outlined
in the QAP? “
AHFA Response
Yes, the Certificate of Occupancy is sufficient to meet the standard for determining the Placed
in Service Date.
Neighborhood Services
72. Question
We have a site within 2 miles of a Target Grocery Store. This store does not have a meat or
produce department. Does this grocery store still count for 2 points?
AHFA Response
No. As defined, “Grocery Store: A store that retails food including but not limited to fresh
meats (prepackaged sandwich meats are not eligible), fresh fruits, and vegetables. (I.E. Winn
Dixie, Piggly Wiggly, Publix, Walmart Supercenter) Sam’s Club and Costco will not count as a
grocery store due to membership fees. “
73. Question
Concerning points for proximity to a Dr. Office / Hospital, would the county health department
meet the requirements for points?
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They provide the following services:
Clinical Services






Plan First Provider - Contact Janice Wittscheck at (256) 765-7554
Family Planning - Counseling and Birth Control
Nurse Practitioner Available
Women’s Health - Pap Smear, and Breast and Cervical Program
Sexually Transmitted Disease (STD) - Testing, Treatment, and Counseling
Women, Infants, and Children (WIC) - Application, Voucher Issuance, and Nutrition
Counseling
 Medicaid Enrollment
 Vaccinations - Infants and Children, Influenza and Pneumococcal
 Tuberculosis Testing and Treatment
 Clinical Laboratory Testing
Income-Based Fees
AHFA Response
It is the applicant’s responsibility to provide documentation regarding the extent of verifiable
primary care medical service available and the specific provider/individual.
The information provided in the list of clinical services provided above is not sufficient to meet
AHFA requirements.
Design Quality Standards
74. Question
The DQS for Rehab states:
9. All parking must be asphalt or concrete. An asphalt or concrete paving recommendation letter must
be provided with the application by a geotechnical engineer.
There is no Tab in the index. No form letter provided. It appears AHFA was not going to require this
letter any more but it was left in the MDS.
Please clarify if we need this at the time of application.
AHFA Response
The paving recommendation letter from the geotechnical engineer will be required on all
approved projects within 135 days of the date of reservation.
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75. Question
If using leveraging funds not on current AHFA list; when, how, and what do I submit the
request for approval of such funds?
AHFA Response
Requests to include additional funding sources as leveraging for points should be presented
to AHFA for consideration during the official commenting period for the HOME and Housing
Credit Plans.
76. Question
For any “Deviation” we failed to note with the 2/17 pre-application package, do we simply
submit with the 3/17 application package and pay the fee?
AHFA Response
Deviation requests should be submitted to AHFA as soon as the applicant becomes aware a
deviation is necessary. According to item 6, on page 10 of the QAP, the deviation request
fees are assessed for any deviations requested after the reservation for funding.
77. Question
Where in the application should the “asphalt or paving recommendation letter” be placed?
AHFA Response
According to item 3(vi.) on page 24 of the QAP, the paving recommendation letter from a
geotechnical engineer is due within 135 days of the date of the reservation letter.
78. Question
Any chance we can end the QAP requirement of getting landline phone availability letter?
AHFA Response
This comment should be submitted for AHFA’s consideration during the official
commenting period for the HOME and Housing Credit Plans. Phone letters will be required
for the 2015 application cycle.
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79. Question
If something is missing in the initial pre-application, how does AHFA handle that missing
document?
AHFA Response
According to item D.2., on page 9 of the QAP, the applicant will have five business days
from notification by AHFA to provide the required items. A $1,500 fee will charged for
each missing and/or incomplete application document.
80. Question
Please confirm that negative compliance points are charged against BOTH owner and
management company. If so, will they “double count”? i.e.…. If an owner has a negative
point and is using the management company that got the negative point, will that be two
negative points or just one?
AHFA Response
Penalty points will be assessed to both the owner and the management company of record
for each audited property from May 1 through December 31, 2014. The cumulative points
for all properties owned by each owner and not the management company will be used in
determining the points deducted for any given 2015 application.
Cumulative penalty points for each owner or each management company meeting or
exceeding 20 total points for all properties audited will preclude either the owner or
management company from participating in the 2015 application cycle.
81. Question
Management Penalty- How will a management company point penalty be
administered?
 Against any application on which they are named as Management Company?
 Against only their deal they have ownership in & management?
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AHFA Response
Management company points will only be used to determine if the management company
meets or exceeds 20 cumulative points for all audited properties from May 1 through
December 31, 2014. If the management company exceeds this limit they will be precluded
from participating on any applications in the 2015 application cycle. The management
company points will not be used as a direct deduction to the application.
82. Question
On the self-score sheet under points lost, what do you want for occurrence?
AHFA Response
Under the Compliance Section of the Self-Score Sheet, the spaces under “Occurrence”
should be filled with the total number of non-compliance issues identified for each item.
Applicants should refer to the 2015 Housing Credit Qualified Allocation Plan, HOME Action
Plan, and Application Forms/Documents and Instructions for complete information
regarding each item.
83. Question
I have the following questions concerning 23b Credit Authorization Form.
•
The form has a check box for Developer and General Contractor. However, the
instructions at the top of the form say it must be completed for all owners, members and
general partners. Credit authorizations for the owners, members and general partners
were submitted with the initial application on Form 2b. Must we re-submit credit
authorizations again for the owners, members and general partners?
•
If we must re-submit Credit Authorizations for the owners, members and general
partner, which box should we check on Form 23b?
AHFA Response
The credit authorization forms for the ownership entities were submitted with the initial
application, those specific credit authorization forms do not need to be resubmitted with
the complete application submittal.
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Last Revised March 6, 2015