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THOUGHTS on POSITIVE CHANGES THAT COULD BE MADE TO THE MFH PROGRAM:

This article discusses the current state of the RD MFH program and proposes ideas for positive changes that can be made to address issues such as shrinking program, mortgage maturity crisis, and unfunded energy efficiency opportunities.

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THOUGHTS on POSITIVE CHANGES THAT COULD BE MADE TO THE MFH PROGRAM:

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  1. THOUGHTS on POSITIVE CHANGES THAT COULD BE MADE TO THE MFH PROGRAM: Larry Anderson VP RHPA & CEO Get RD Done Right! 571-296-4746 landerson@rhpallc.com 4-7-2017

  2. Current State of the RD MFH Program • Shrinking Program – RA units peaked 2013, RA outlays peaked 2014 • Massive deferred rehabilitation needs – $2.6 B in 2004 New CPA says $5.6 Billion “reserve deficit from inflation and passage of time” • Pending Mortgage Maturity crisis – Lose 75% over the next 20 years • Massive unfunded energy efficiency opportunities and handicapped accessibility needs – who knows the actual amount? • Years of starving program operations and preservation to “save RA.” • Short sighted regulatory interpretations – no mgt fee increases, cut NP asset mgt fee, no PPI wait list, no split rents – regardless of the reg. • Verbal guidance – no rent increases, limit SWP’s to get the “bad” projects out, using 515, are we out of RA or voucher funds, etc…? • Shrinking staff – loss of experience, expertise, and accountability • Limited release of program data – how many prepaid, how many preserved, how many MPR’s closed, RA use, success of new RA tool • GOOD NEWS: Surplus RA -- $200 M in FY16, maybe $350 M in FY17? • GOOD NEWS: Great RD staff still hanging in there - new PAT and HQ underwriting team – experienced and committed owners/operators – irreplaceable program that works – people that need our help!

  3. Latest on the RD MFH Mortgage Maturity (MM) crisis • New RD data - MM still bad, but the worst is 10 years later. • Key RD process questions: • Why the big difference with the new data? Is this version right? • What happens with 30 yr. term, 50 yr. am loans (after 95)? • What if “damage settlement” loan matures before RUC’s expire? • Will MM projects receive priority for funding - MPR, RA, 515 or 538? • Can prepayment prevention tools be used & prioritized to avert MM? • Key owner/operator/purchaser questions: • What and where are my restrictions (project based or property based) • Where are my projects with MM? (multiple, single loans or cost items) • When to talk to RD about options? (portfolio solutions or one off) • Preservation strategies • Exit strategies • Capital needs and resource availability

  4. Key RD MFH Mortgage Maturity (MM) crisis policy changes to increase preservation activity • RD needs new ideas to attract resources to preserve projects • Use all available RA – the FY13 RA sequester funding crisis is over • Encourage two step transfers – acquire, then rehab • Allow operating budget support for GP purchase • Eliminate artificial caps on rent increases – CRCU and percentages • Better appraisal guidance - RUCS limit by tenant incomes not rents • Partner with State HFA’s, regional or local housing stakeholders • Better written guidance on NP sale rules and funding • Duty to Serve – work with Fannie and Freddie for new options • Encourage more mission based NP participation, beyond UNL: • End the artificial suppression of asset management fees – regulations over handbooks • Publish “Sale to NP and PB” funding availability and guidance • Encourage the use of prepayment prevention incentives with simpler guidance and national funding • Allow MPR RTO incentive to be used by NP’s

  5. Significantly, USDA occupancy reports show RA units peaked in FY13 – the portfolio is now losing roughly 1,290 RA units a year

  6. GAP between RA Outlays and Obligations (millions)

  7. More common sense policy ideas to prevent MM • Use the RA windfall GAP – the RA funding crisis is over • Provide guidance and TA to encourage mission based ownership • Provide direction in writing - change your regulations – not interpretations – provide a coherent preservation program • Make it easier to get ownership change and rehab accomplished • Use existing prepay incentives: $1 M in RA = 10 projects saved • Use available funding to encourage portfolio transactions • Publish funding rules – use 515 money more openly and effectively • Bring in the full RD Team under MFH HQ – include CNA reviewers, appraisers, architects, and closing attorneys to speed up processing • Eliminate incentives to convert to market – huge reserves, no cost tenant protections, refusing common sense SWPs, allow for re-ams, clarify what happens after 30 year term, use 1% SWP deferrals • Steady the RA Boat – transfer all unused RA and stop RA retirement • Publish your accomplishments and program status • Fight for resources - work with Federal, State and Local funders.

  8. Even more common sense policy ideas to prevent MM • Work with developers “upfront” to help manage expectations • Sit down, review potential deals, discuss options and make a plan • Find better ways to work with properties that don’t fit a market based solutions, but still meet a significant need in the community • Use dormant tools – such as consolidations, waivers, deferral, write offs, protective advances or unused RA • Make a quick decision on underwriting • Use a sales price option that covers “exit taxes” • No requirement that sales price equals equity • Clarify how “other” components and RUPS fit into a sales price • Don’t turn down free money • No requirement that all funds are “fungible” • Encourage GP buyouts by strong NPs or good mission based entities • Two step process – helps facilitate portfolio transactions • Develop a new protocol to “pool” reserve funding and reduce project costs - trade easy access to funding for reduced rents • Allow for portfolio level management

  9. WA mortgage maturity loss data – New data pushes the cliff back ten years

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