HOME Program Breaking News

NCSHA HFA InstituteJanuary 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

• New/Revised CPD Notices– 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

Upcoming HOME Guidance

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 grant-specific 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

• 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

HOME TA & Training

Slide 10

• For information on HOME training, policy guidance, TA products, visit www.hudexchange.info

• Sign up for HOME listserv https://www.hudexchange.info/mailinglist/

Where to Find It

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

15

• 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

Cumulative / FY 2014 Tenure Type

16

HOME Four-Year Accomplishments

17

FY 2011 FY 2012 FY 2013 FY 2014Rental Units 39,162 28,779 20,929 20,540Homebuyer Units 21,593 20,129 15,350 12,854Homeowner rehab Units 9,137 9,017 10,547 6,431Total units Completed 69,892 57,925 46,826 39,825TBRA Households Assisted 15,683 15,929 12,363 11,744

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 FormulaPer 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 Formula3) 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