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Office of Multifamily Housing. Joe Crisafulli, Boston Hub Director NCSHA Conference 10/20/14. Affordable Housing Preservation Update. Section 8 Renewal Guide Waiver Authority Delegation Purpose: Encourage and streamline affordable housing preservation. - PowerPoint PPT PresentationTRANSCRIPT
Joe Crisafulli, Boston Hub DirectorNCSHA Conference 10/20/14
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Affordable Housing Preservation Update • Section 8 Renewal Guide Waiver Authority Delegation
– Purpose: Encourage and streamline affordable housing preservation.– Authority for 5 Waivers delegated to Hub Directors in field
1. Prohibition on for-profit participants- Chapter 15
2. Section 15-8 – Requiring lowering comparable market rent to reflect use-restricted rent levels.
3. Section 15-6.C.1. Post-rehab rents effective only at completion of the rehab.
Affordable Housing Preservation Update Continued• Section 8 Renewal Guide Waiver Authority Delegation
4. Section 15-5.B.2- Does not allow for early termination of pre-MAHRA contract.
5. Section 3-2.A.- Property score of 60 or above to be eligible for MUTM.
6. Section 3-7.F.1.d – Allows use of a Lender ordered MAP appraisal in lieu of a separate RCS for MUTM transaction using FHA financing. No waiver necessary per 8/28/14 guidance.
Section 8- More Preservation Tools
Combining Section 8 HAP Contracts- Guidance issued via memo on 9/18/2014 . Benefits: Lower administrative costs, consolidate oversight, shared reserves, better debt and equity terms and pricing.
Transferring Budget Authority (aka “Portage”) of PB Section 8 HAP Contract- Section 8(b)(b)(1) of U.S. Housing Act of 1937- Notice H14-14 was issued on 10/9/14.
Section 8 Pass Through- Used successfully in preservation scenarios where units planned for rehab are uninhabitable. Requires HQ approval.
CNA e Tool• Origin- 2010 President’s Domestic Policy Council policy alignment
initiative.
• HUD, USDA-RD & Treasury (LIHTCs via HFAs) use capital needs assessments (CNA)/physical due diligence in their programs.
• Interagency Rental Policy Working Group- incorporated feedback from multifamily stakeholders, including HFAs, recommended creation of a data standard and electronic template for CNAs.
CNA e Tool• CNA e-Tool is born. It is a suite of inter-related tools:
– Aligned electronic template incorporating a data standard for assessments.
– Creates automated process for preparation, review, submission, approval and periodic updating of CNAs
– Expected to evolve and improve to execute due diligence on asset acquisition/loan origination, RfR administration and periodic review of capital needs.
CNA e Tool Coming this Fall
• Initial version of CNA-e Tool is complete. HQ is working on guidance, training and rollout of the tool. Publication of the Notice is expected this fall.
• Will become the required standard for HUD and USDA for a number of programs.
CNA e Tool Roll-out• Roll-out will:
1. Introduce the tool and its support, training and technical assistance tools, etc.
2. Identify programs that will be required to migrate to CNA-e-Tool.
• Most likely: a. All Multifamily FHA applications requiring CNAs b. All RAD and M2M applications c. All Asset Management-required CNAs
Rollout, Continued3. Detail implementation schedule. Likely HUD will:
a. Begin accepting CNAs via the CNA-e-Tool and encouraging
lender’s use 30 days after Notice. b. Require use of CNA e Tool circa 180 days later.
•Stay tuned.Electronic template is available in 2 forms: Excel and Business to Government (B2G) interface (allows assessor firms/lenders to map existing templates to CNA e Tool). View these at HUD MF homepage:http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/mfh(See upper right under “What’s New”)
CNA e Tool – take aways
• Flexibility allows use in multiple programs at different agencies
• Each agency /program will need to develop some specific guidance conforming to their needs.
• The tool is free. Once it is rolled out it will be available on the HUD website.
Take Aways Continued
• HUD invites and encourages HFAs to adopt and use it as their standard CNA tool.
• We hope that CNA e Tool will become an industry standard used by multiple partners and encourage commercial add ons such as mobile apps.
• HUD looks forward to working with HFAs that are interested in utilizing CNA e-Tool
• THANK YOU- Questions/comments to [email protected]
Geographic Expansion:
– Initial Selection of 4 Pilot Hubs, Expanded to 9
– Initial limit to Pilot Hub Jurisdictions, Expanded to Include Projects from all States
LIHTC Pilot Program Progress Check-in“The Heavy F”
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-- Processing System for Projects not In Pilot Hubs
Industry Expansion:
Lender Selection 4th Round Increased Pilot Lender firms from 37 to 52
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“The Heavy F” Continued
• Program Rules Refinement (FAQs, Document Updates)
• Projects In Pipeline (As of 9/8/14)o Concept Meeting Held 123 Projects/13,582
Unitso Closed 27 Projectso Pilot Hubs with Projects 9o Lenders with Projects 20 of 37o Average Days to Close 101 (Excludes Applicant Delays)
LIHTC Program Progress Check-in
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Continued Integration of Pilot with RAD
Recent Policy Development: More flexible rules on debt limits, IOI transfers, Completion Assurance and other matters posted on February 28th.
Future Expansion: Program adjustments expected on an ongoing basis, to be Included in 2014 MAP Guide Revision
LIHTC Pilot- Future Program Development
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