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2011 Qualified Allocation Plan Forum September 16, 2010. 2011 Qualified Allocation Plan Forum WELCOME & INTRODUCTIONS. 2011 Qualified Allocation Plan Forum Agenda 2011 QAP Changes: 9:00 – 10:30am Networking Break: 10:30 – 10:45am
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2011 Qualified Allocation Plan Forum September 16, 2010
2011 Qualified Allocation Plan Forum WELCOME & INTRODUCTIONS
2011 Qualified Allocation Plan Forum • Agenda • 2011 QAP Changes: 9:00 – 10:30am • Networking Break: 10:30 – 10:45am • Intergenerational Communities: Seniors and Downtown Living • Lunch: 11:45 – 1pm • Debt Financing For Housing Credit Developments: 1 – 2pm • Networking Break: 2 – 2:15pm • Dialogue With Indiana Housing Credit Experts: 2:15 – 4pm
2011 QAP Changes • Housing Priorities • Set Aside Categories • Threshold Requirements • Evaluation Factors • Miscellaneous
2011 QAP Housing Priorities • Comprehensive Community Development • Partnerships • Adopted plans • Aging In Place • Accessible Units ratio points • Universal Design feature levels • Ending Homelessness • Tailored Services • Permanent Supportive Housing open round • High Performance Housing • LEED certification requirement • Energy efficient construction
2011 QAP Set Aside Categories • CHANGES: • Community Impact 10% Set-Aside created • Housing First Set-Aside increased to 10% • USDA 515 Set-Aside removed • Rural Set-Aside increased to 10% • “Rural” re-defined • Special Needs Set-Aside removed and • made a Threshold requirement
2011 QAP Set Aside Categories • CHANGES: • Community Impact Set-Aside • Site Visit Documentation • Narrative • One page, demonstrating how development meets set-aside requirements • Directions to site • 2 – 3 photos of site, with labels of direction in which they were taken
2011 QAP Threshold • CHANGES: • Page 10 – Submitting Satisfactory Evidence of • Site Control • Page 11 – Development Site Information • Page 11 – Only the lender letter of interest will • still be required for Threshold. The equity letter will be required with the150 day documents.
2011 QAP Threshold • CHANGES: • Page 13 – Tab J Development Team Member • Affidavits: not really a change but a notable issue during Threshold reviews. • Page 14 – Rehab (hard costs) per unit - $20,000. If competing in Preservation set-aside $30,000 per unit. • Page 15 – Displacement/Relocation Plan – MORE DETAILED.
2011 QAP Threshold • CHANGES: • Underwriting Guidelines • Page 15 – Replacement Reserves • Added: Single Family units & Historic Rehab units • Page 16 – Stabilized Debt Coverage Ratio • Broken down by Large/Small City & Rural • Also, small change if deal has NO HARD • DEBT.
2011 QAP Threshold • CHANGES: • Developer Fee Limitations: (page 17 – 18) • On a per unit basis for New Construction & Rehab. • Consultant fees are considered part of the developer fee.
2011 QAP Threshold • CHANGES: • Page 18 - Contractor Fee Limitations: NO INCREASE permitted higher than the stated percentage limitations in the fee chart. • Page 19 – Architect Fee Limitations: If proposing more that 3%, guidelines must be followed in Schedule H. • Page 19 – Consultant Fee Limitations
2011 QAP Threshold • CHANGES: • Page 19 – Reasonableness of Project Costs: IHCDA may require additional info or documentation to substantiate the reasonableness of costs. • Page 19 - MINIMUM DEVELOPMENT STANDARDS: • All new construction developments must have energy efficiency certification
2011 QAP Threshold • CHANGES: • Page 20 – Minimum amenities for Elderly • developments: • % of ADA adaptable & accessible for both new construction and rehabilitation. • Page 20 – Special Housing Needs: • Now THRESHOLD requirement
2011 QAP Threshold • CHANGES: • Page 21 – Returned Credits = Scoring Deduction
2011 QAP Threshold • Threshold Pitfalls to Avoid • Development Team • All team members are not identified – now required • Affidavits are not signed, notarized, or QAP language missing • Consultant fee isn’t backed out when determining Developer Fee • Relocation Plan is deemed “N/A” for a property with tenants • Documents are more than 12 months old • CDBG-D &/or 1602 sources identified on application
2011 QAP Evaluation Factors • Rents Charged 28 Points • Development Characteristics 91 Points • High Performance Housing 21 Points • Financing & Market 32 Points • Other 28 Points • Total 200 Points
2011 QAP Evaluation Factors • Changes: • Total possible points increased from 150 points to 200 points. • Minimum score to pass threshold increased from 60 points to 100 points (90 points for 4% credit Applications) • Removed “Constituency Served”
2011 QAP Evaluation Factors • Changes (cont.): • Added points for ADA Type A Accessible Units • For percentage greater than the minimum threshold requirements.
2011 QAP Evaluation Factors • Changes (Cont.): • Universal Design Features • Now Using a “Ribbon Color” system • Applicant to select ribbon color based on amenities as set forth in development schematics • Grey Ribbon – applicant will meet all minimum IHCDA threshold requirements only. No additional design features from Column A, Column B, or Column C. 0 points • Green Ribbon – in addition to meeting all minimum IHCDA threshold requirements, applicant commits to adopt a minimum of one (1) universal design feature from each Universal Design Column. 1 point
2011 QAP Evaluation Factors • Changes (Cont.): • Universal Design Features (cont.) • Yellow Ribbon – in addition to meeting all minimum IHCDA threshold requirements, applicant commits to adopt a minimum of two (2) universal design feature from each Universal Design Column. 2 points • Red Ribbon – in addition to meeting all minimum IHCDA threshold requirements, applicant commits to adopt a minimum of three (3) universal design feature from each Universal Design Column. 3 points • Blue Ribbon – in addition to meeting all minimum IHCDA threshold requirements, applicant commits to adopt a minimum of four (4) universal design feature from each Universal Design Column. 4 points
2011 QAP Evaluation Factors • Changes (cont.): • Vacant Structure • Added commercial as an eligible use. • Decreased number of points: • 50% of Total Development 1 point • 75% of Total Development 2 points • 100% of Total Development 3 points • Eligible structures must contain a rental housing tax credit unit in a qualified rental housing tax credit building.
2011 QAP Evaluation Factors • Changes: • Infill Housing (7 points) • Must be surrounded on at least 2 sides with adjacent development • Must maximize use of existing utilities and infrastructure; • One side of the development must be adjacent to occupied residential development, operating commercial development, active public space or another active community amenity. • Agricultural Land does not qualify as Infill • Housing for this scoring category.
2011 QAP Evaluation Factors • Changes: • Adaptive Reuse (5 Points) • Proposed development is an adaptive reuse of an entire existing building and constitutes a significant part of the development as a whole. • Change in use of a major building (not already part of an existing multifamily development) for residential use or as a community building. • Possible 3 points for a adaptive reuse of part of a building.
2011 QAP Evaluation Factors • Changes: • Brownfield (4 points) • Site where EPA, IDEM, or other environmental regulatory agency has defined the site as a Brownfield site and has determined the applicable guidelines for the cleanup required for residential use.
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) • Recognized by the local government as assisting in the stabilization of a neighborhood by demolishing or redeveloping property that has been: • Foreclosed Upon • Mortgage or tax foreclosure must be complete • Title of the property must be transferred from the former homeowner in some form of foreclosure proceeding or “in lieu of foreclosure.”
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) (cont.) • Abandoned • Mortgage or tax foreclosure proceedings have been initiated on the property; • No mortgage or tax payments have been made by the property owner for at least 90 days; and • Property has been vacant for at least 90 days.
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) (cont.) • Blighted • Considered “blighted” if 2 or more of the following are meet: • Uninhabitable, unsafe, or abandoned; • Inadequate provisions for ventilation, light, air, or sanitation; • An imminent harm to life or other property caused by a natural catastrophe in which the Governor has declared a state of emergency or has certified need for disaster assistance; provided that the owner has failed to take reasonable measures to remedy the harm.
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) (cont.) • Blighted (cont.) • Site identified by FEMA as a Superfund site, or environmental contamination to an extent that requires remedial investigation or a feasibility study; • Repeated illegal activity on the individual property of which the property owner knew or should have known; • Property maintenance is below state, county, or municipal codes for at least one year after notice of code violation
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) (cont.) • Blighted (cont.) • Site is partially built with no work on the property for a period of at least six months; and/or full debt service payments have not been made for a period of at least 90 days; and the lender and/or local government provides a letter outlining the effect the property has on the surrounding community; • Property that was acquired for redevelopment by a government entity or community organization that were foreclosed, abandoned, or blighted when acquired.
2011 QAP Evaluation Factors • Changes: • Promotes Neighborhood Stabilization (10 points) (cont.) • Greyfield Redevelopment • Previously developed retail or other commercial (non-residential) center; • Suffers from a lack of reinvestment due to abandonment of tenants; and • Has underlying utilities and paved infrastructure; • Must be: • Vacant, abandoned, or 90% of total sq. ft. is unused; and • With 25% of site comprised of associated parking areas.
2011 QAP Evaluation Factors • Changes: • Local Redevelopment Plan (11 - 14 points) • Adopted redevelopment or community revitalization plan that clearly targets specific neighborhood in which the project is located. • Must include: • Clearly delineated target area that includes the proposed project site; • Detailed policy goals, which include rehabilitation or production of affordable rental housing; • Implementation measures with specific, current, and ongoing time frames; • The proposed development must support at least one of the goals of the redevelopment or revitalization plan; and • An assessment of the existing physical structures and infrastructure of the community.
2011 QAP Evaluation Factors • Changes: • Local Redevelopment Plan (11 - 14 points) • The following are not eligible: • Short-term work plans; • Consolidated plans, municipal plans, or land use plans; or • Plans that do not reflect the current neighborhood conditions. • If the plan has been adopted by a local unit of government, and • meets all the previous requirements an additional 3 points will be • awarded for a total of 14 points.
2011 QAP Evaluation Factors • Changes: • Federally Assisted Revitalization Award (5 points) • Proposed Project is a phase or component of a : • PHA sponsored HOPE VI or Choice Neighborhoods revitalization effort; or • Revitalization initiative, in which a PHA is a central sponsor and funder, but does not included HOPE VI or Choice Neighborhoods funding; or • HUD funded Promise Neighborhoods or Sustainable Communities initiative; or • New Market Tax Credit Development • Must Have: • Affordable Units for an extended period of 30+ years; • Part of a mixed income phased community with a • significant market component;
2011 QAP Evaluation Factors • Changes: • Federally Assisted Revitalization Award (Cont’d.) • Must Have: • Facilitate the de-concentration of poverty; and • Provide for community improvements or amenities, • which may include: • - New or improved infrastructure; • - Green-space; • - Improved transportation, • - Quality of life enhancements; or • - Other improvements benefiting the community.
2011 QAP Evaluation Factors • Changes: • Off Site Improvement, Amenity, and Facility Investment (10 points) • Third party investment of resources is provided that will result in off-site improvements adjacent to the project site, and/or the development of parks, green space and shared amenities, recreational facilities and improvements adjacent to the proposed project site that will serve the tenant base for the subject property. • Must be: • Committed prior to the proposed placed in service date; • Costs and sources for improvements, amenities and/or facilities must be excluded from the cost and sources of funding for the proposed development; and • Be at least $100,000 and paid in full by third party.
2011 QAP Evaluation Factors • Changes: • Phased Developments (3 points) • Project is part of a larger, multi-phased development project, where: • At least one or more phases must have received an allocation of RHTCs and at least one phase has already began construction; • Part of a community revitalization effort; and • Originally designed to be one total development with multi-phased developments.
2011 QAP Evaluation Factors • Changes: • Removed points for: • High Performance Housing Characteristics: • Energy Star Certified Building Envelopes; • Energy Star Rated refrigerators in every unit • Sustainable Development Characteristics: • - Removed points for • - Re-Cycled Content • - Low Volatile Organic Compounds • - Low Impact Construction Practices • - Low Impact Procurement Practices • - Owner Paid Utilities
2011 QAP Evaluation Factors • Changes: • Building Certification (6 points max.) • All buildings must receive at least one (1) energy efficiency certification • Buildings can receive more than 1 certification to maximize points. • LEED • Green Building Standard • Energy Star HERS Rating
2011 QAP Evaluation Factors • Changes: • Desirable Sites • Removed points for desirable sites that are located ½ - 1 mile from the development • NOTE: To receive points, applicant must place a map in Tab Q containing: • Location of site including an indication of major access roads; • * Indication of distances with a ¼ mile radius indicated on the map; • Areas of residential development adjacent to or near the site; • Indication of any significant industrial or commercial development; and • All desirable facilities or activities.
2011 QAP Evaluation Factors • Changes: • Financing & Market • Revised wording to “Public Funds” with a firm commitment that does not require any further approval • Must enhance and/or create significant cost savings for the development • Increased percentage of public funds to total development costs required to receive points
2011 QAP Evaluation Factors • Changes: • Credit Reduction (Max 5 Points) • 1 point for each percent that a project reduces the amount of RHTCs requested versus the maximum allowable credit amount. • Committed funds must be part of the permanent sources for the development and remain in place for a min. of 10 years. • Example: • Total Development Costs: $10,000,000 $787,700 • Eligible Basis: $9,000,000 • Applicable Fraction: 100% $810,000 • Applicable Percentage: 9% • Max. Allowable Credit: $810,000 97% * • Credits Requested: $787,700 • *Constitutes a 3% reduction in the • amount of RHTCs requested for • 3 points.
2011 QAP Evaluation Factors • Changes: • Subsidized Housing Waiting List • Must now complete and execute Form L to receive points • Community Revitalization Preservation • Must be located within the corporate limits of a City or Town; and • Must not have been used as agricultural land within the past five years.
2011 QAP Evaluation Factors • Changes: • Tenant Investment Plan (Max. 8 Points) • Level 1: Programs/Classes • Requires ongoing tenant participation and/or program management • i.e. discounts, referrals, educational resources • Range from 1 – 3 points • Level 2: Behavioral/Health Services • Targets services for specific tenants • i.e. treatment, prevention, or assistance based on specific special need • Range from 1 – 4 points
2011 QAP Evaluation Factors • Changes: • Tenant Investment Plan (Max. 8 Points) (cont.) • Level 3: Community Enhancement to encourage Aging in Place • Requires both extensive tenant participation, as well as management maintenance. • i.e. case manager, resident liaison, monthly activities programs • Range from 1 – 6 points • Level 4: Permanent Supportive Housing • Reserved for applicants building Permanent Supportive Housing developments • Services must be in line with or match the philosophy of the Housing First description • Range from 1 – 8 points
2011 QAP Evaluation Factors • Changes: • Tenant Investment Plan (Max. 8 Points) (cont.) • Must Submit a Tenant Investment Summary which includes: • Tenant Investment Plan checklist; • Brief TIP narrative identifying an annual budget, the role of the TIP Coordinator, and how the services will meet the needs of the tenants; • Form M must be filled out for each Service Provider/Agent/Organization and signed by all parties in agreement; • A TIP Exhibit A must be attached to each agreement; and • Exhibit B listing any “Other” services being offered that may not be listed.
2011 QAP Threshold • Scoring Pitfalls to Avoid • Lack of required documentation/required language. • Desirable sites: ¼ mile radius on map. • RHTCs as part of the overall financial structure • = 10 year credit amount ÷ Total Development • Unit Size: Must include a floor plan with exact total net square footage printed clearly for each for each unit type/size. • Unique Features: Use a bullet point list with a description of each unique feature.
Application Best Practices • Submit a copy of all documents on CD-R • Organize in application order • PDF, legible format • Self-score sheets • Show your work for calculations • Include notes if score sheet suggests (desirable site) • One file per application • Label all documents with development name
2011 QAP Miscellaneous • Housing First Open Round • New Fees • Each additional threshold requirement • Extension request for any deadline • Conditional Commitment Equity Letter • Carryover Allocation Date – On or before July 5th , 2011