Extreme home Makeover

1. Extreme home Makeover Presented by: Stacy Day, HCCp Ambling Management Company

3. Hud Regulation updates • Published july 13, 2013 for commitments after 8/23/14 • Commitment date • Delayed changes • Retroactive changes • Hud to publish applicability chart (date unknown)

4. Participating jurisdiction • Pj will have much more active role….in some cases this will require figuring out who the PJ contact is!! (smaller pjs) • Need to determine if home units are fixed or floating to determine applicability of home rules

6. Student rules • Tax credit: Comprised entirely of full time students. exceptions: • Married and entitled to file a joint tax return (same sex couples married in any state that recognizes same sex marriages meet exception in all states) • All adult members are single parents with minor children and the children are only claimed by a parent • The household includes a member who receives title iv of the social security act (TANF/welfare) • The household includes a member who formerly received foster care assistance • The household contains members who get assistance from the Job training partnership act or Similar program

7. Student rules • HOMe has adopted the section 8 student rules for all adult students (FT AND PT students). Exceptions: • a dependent of the household living with parent • Over age 23 • A veteran • Married • A parent with dependent child (ren) • A disabled individual who was receiving assistance prior to nov 30, 2005 • 1. be independent from parents OR 2. have parents who are income eligible

9. Student rules • Is this retroactive? Currently up for debate! • DCA – currently only applicable to commitments after 8/23/14 • Need to create and implement home student certification • How will this be administered if household was qualified at MI and later needs to meet a home student exception? • No assistance to remove • Suggested it will be treated like the nau rule as “temporary” non compliance

10. Utility allowances • Tax credit • Rural development (RD) • HUD rent schedule • Conventional lihtc • Local pha • Estimate from utility co • Hfa estimate • Hud’s utility schedule model • Energy consumption model • Home • No longer recognizes pha • Pjprovides ua to owner that is property specific before lease up and annually going forward • Delayed for commitments made after January 24, 2015 • Hudutility schedule model • By otherwise determining the allowance based on the specific utilities at the project

11. Income calculations • Tax Credit • 4530.3 - Uses highest amount if a range is provided when calculating income (standard in the industry) • Home • Tax return • Section 8 method (most common) – uses average if range is given • Rent calculation • Nau rule

12. Gross rent test • Tax Credit • Resident rent + ua + non optional charges* *exception – if a resident receives $1 in subsidy, resident rent can exceed gross • Home • Tenant rent + subsidy + ua + non optional charges (must be below “low” or “high” rent)* *exception: project based subsidy is not included in rents for very low income (50%) households (must watch when households become market renter – may require a rent reduction)!

13. Program discrepancies • Due to the differences in: • Student rules • income calculations • UA methods • Gross rent test Should program specific tics be used?

14. Audit cycle • Tax Credit • 20% of each project every 3 years (can conduct more frequently) • Home • Previous: annually • Current: every 3 years • If findings, re-inspect in 12 months DCA note: will notify owners of schedule for 2015. If existing issues, annually. If no issues, every 3 years

15. Lease terms • Tax Credit • Move in: minimum of 6 (full) months • Recertification: no requirement • Home • Move in and renewal: 12 full months unless other terms agreed upon by resident and management

16. Lease up deadlines • Tax Credit • All buildings must be placed in service no later than two years after the end of the year in which credits are allocated • Home • Project completion – completed within 4 years of commitment of home funds or funds will need to be repaid • Lease up • Within 6 mo of completion: if units remain unoccupied, pj must provide hud marketing efforts • Within 18 mo of completion: hud will require repayment of home funds for all unoccupied units

17. Requesting rent increases (DCA) • Per the updated regulations, the pj is required to approve all rent increases prior to implementation • In order to simplify the rent increase approval process and to assist in calculating the allowable rents, dca has created the dca home rent request(official instructions and the final form will be provided by DCA before the end of October, 2014)

18. Requesting rent increases (DCA) • the request form will be completed any time the owner/management agent would like to increase rents above the current approved rents. examples: • UA change (PHA and actual estimates) • Income limits published (mtsp) • Rent limits published (home) • Ability to increase rents when not currently at max • Note: a separate increase will be required for each ua type

19. Requesting rent increases (DCA) • The form will be submitted electronically using the following format: • Copy that has been printed and signed by owner/mgmt agent • Excel copy with file format to include: • Project # • Project name • HOME rent request • Date (no dashes) • Ua Type (pha/actual) • Example: GA-99-001 ABC apartments HOME rent request 092514 phaua

20. Requesting rent increases (DCA) • Submitted to: compliance@dca.ga.gov • The text of the email should include why you are submitting the request (phaua update, actual ua update, change in methodology) • Note: when changing ua methodology, there is a separate approval required for the ua change in addition to the rent increase request • Subject line will mirror the file name • DCA approval will be 30 days or less