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Qualified Allocation Plan Update. Presenter Name in bold , position, if used, in italics Oregon Housing and Community Services or other affiliate name Date (optional) Event name or location (optional). April 5, 2019 Housing Stability Council. Presentation Agenda. Overview
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Qualified Allocation Plan Update • Presenter Name in bold, position, if used, in italics Oregon Housing and Community Services or other affiliate name Date (optional) Event name or location (optional) • April 5, 2019 • Housing Stability Council
Presentation Agenda • Overview • QAP Survey Results & Next Steps • QAP Next Steps • QAP
Qualified Allocation Plan Membership and Mission Qualified Allocation Plan (QAP) Required by IRS Section 42 to guide: • 4% LIHTC • Not Competitive; unlimited Federal Credits available however at least 51% of the project must be funded with Tax Exempt Bond funds, which are limited by state Private Activity Bond Authority. • Leverages Tax Credit Equity to cover approximately 30% of total development costs. • Currently no competitive application to prioritize policy impacts. • 9% LIHTC • Competitive; Federal Credits awarded to states annually • Leverages Tax Credit Equity to cover approximately 70% of total development costs. • Use competitive application and ranking process to implement policy priorities. • QAP
Qualified Allocation Plan Membership and Mission Goals for 2019 QAP Update: • Alignmentof the QAP to reflect priorities in Breaking New Ground: the OHCS Statewide Housing Plan, a five-year look at the agency’s priorities, goals, and strategies in ensuring a stable and affordable housing landscape and further our ability to meet key production goals. • Adoption of national best practices where possible and lessons learned over the past two years; notably to improve the timely delivery of housing to Oregonians and to ensure the appropriate and responsible subsidization of projects to be viable throughout the affordability period. • Streamlineproject selection and funding process that will take advantage of the new data system which we will be moving to by 2020. This system will both move us to a data-driven electronic application as well as the adherence to deliberate funding processes which will be accessed by both OHCS staff, as well as project sponsors. • QAP
Qualified Allocation Plan Survey Membership and Mission Membership and Mission The survey is divided into feedback on 7 Topics • Topic One: Equity and Racial Justice Priority of the Statewide Housing Plan • Topic Two: Homelessness and Permanent Supportive Housing Priorities in the Statewide Housing Plan • Topic Three: Rental Production and Rural Strategies of the Statewide Housing Plan • Topic Four: New Data System • Topic Five: Preservation Strategy • Topic Six: Tax Credit Subsidy and Cost Containment • Topic Seven: General Comments Survey Participation • 85 survey respondents total • Survey open for 2 weeks • To be used as foundation for roundtable conversations • QAP
Topic One: Equity and Racial Justice Membership and Mission Membership and Mission Current Implementation of Equity and Racial Justice QAP Incentives: • Primary focus on competitive 9% LIHTC • MWESB; scoring and reporting • Affirmative Fair Housing Marketing; scoring and requirement for all projects • Opportunity Area; scoring • Areas Vulnerable to Gentrification; scoring • Location Accessibility; transit, walkability, grocery stores, medical services, education services; scoring • Responsive Resident Services; scoring and requirement in all projects Survey Question Focus: • Comfort with current and potential expanded approaches to these efforts • Identify barriers and concerns to implementation • QAP
Topic One: Equity and Racial Justice Membership and Mission Membership and Mission • Survey Highlight: • Support greatest for current model of point based model • Modest support for expanding MWESB reporting to 4% LIHTC, but not for creating targets • Concern over supply of contractors in rural areas Minority Women and Emerging Small Business • QAP
Topic One: Equity and Racial Justice Membership and Mission Membership and Mission Minority Women and Emerging Small Business • Next Steps: • Currently working to bring on contractor and full time position within Housing Finance to focus on creating a foundation for MWESB Strategy and statewide targeting to enhance these efforts. • This work will entail outreach across the state to gain thorough understanding of challenges and opportunities; including providing guidance to those firms who would be eligible to apply for this MWESB registration • Will include MWESB in outreach conversations • Will include specific conversations with Culturally Specific organizations in public outreach • Will include Urban / Rural competition in outreach conversations • Current QAP regions based on HUD HOME Participating Jurisdictions • Current QAP Balance of State region includes a 50% set aside for rural areas to counter any urban area bias • Current QAP includes criteria scaled in response to urban vs rural areas • QAP
Topic One: Equity and Racial Justice Membership and Mission Membership and Mission Other survey highlights: • Greatest support for incentivizing Affirmative Fair Housing Marketing through points for proposals that have a sponsor partnership with culturally responsive organization that represent individuals who are least likely to access housing resources. • Majority of respondents comfortable with the Diversity Equity and Inclusion agreement; however additional work and support required to bring all participants along and to include measurements of success. *This is capacity that OHCS is intending to bring on board* • Location criteria (opportunity areas, vulnerable gentrification, and location access) are reported to have a significant impact on sponsor site selection; at the same time there is substantial concern that these criteria do not prioritize investment in rural Oregon. • There is support for giving preference or a set-aside for projects located on federally designated tribal land • QAP
Topic Two: Homelessness and Permanent Supportive Housing • Survey Highlights: • Substantial comfort in serving target population • Interest in a variety of approaches to technical assistance • Greatest comfort with prioritizing PSH in 9% LIHTC with points; secondary support for a PSH set-aside • Emphasis on the importance of rent assistance and service funding to the success of the model Permanent Supportive Housing for Chronic Homeless • QAP
Topic Two: Homelessness and Permanent Supportive Housing • Next Steps: • Launch of PSH Pilot • Focus on technical assistance and provision of rent assistance and service funding / coordinated entry • Given high level of agreement on these topics expecting a modest piece of the engagement Permanent Supportive Housing for Chronic Homeless • QAP
Topic Three: Rental Production and Rural Strategies Rental Production • Survey Highlights • Focus on fewer, more flexible, fund offerings instead of customized NOFAs with a singular goal • Give developers greater predictability regarding their ability to secure resources through a particular fund offering • Increase funding transparency; implement pre-applications to provide initial feedback on project proposals Rural Rental Production • Survey Highlights • Target development offerings to rural areas only • Target development offerings to urban/rural scattered site projects • Facilitate partnerships with developers and rural organizations • QAP
Topic Three: Rental Production and Rural Strategies Next Steps: • Include Urban / Rural assessment in outreach conversations • Ensure that QAP will continue to have set targets for serving rural areas • Pursue creation of a pre-application; discuss with developer partners what elements are most appropriate for a pre-application • Continue work to streamline application processes and funding opportunities • QAP
Topic Four: New Data System Self-Scoring and other Competitive Application Requirements • Survey Highlights • Tremendous interest in getting early sense of a project’s likelihood for funding reservation • Concern that not allowing subjective information will not consider unique project features into fund decision process • Ambivalence around the impact of such changes to the applications • QAP
Topic Four: New Data System Self-Scoring and other Competitive Application Requirements • Next Steps • Provide training opportunities for using new system • Expand dialogue with developer community on ways to give desired feedback while accomplishing an objective scoring system • QAP
Topic Five: Preservation Strategy Membership and Mission Membership and Mission • Survey Highlight: • 35% support for continuing current Preservation set-aside • Equal percentage of respondents indicated that the set-aside should be greater as did indicate the set-aside should be lower • OHCS desire to focus preservation transactions on the use of non-competitive 4% LIHTC Preservation Set-Aside: currently 35% Next Step: continue conversations regarding Preservation criteria with developer stakeholders • QAP
Topic Six: Tax Credit Subsidy and Cost Containment • Survey Highlights: • No agreement that scoring development costs is an effective way to encourage lower development costs • Fairly strong disapproval of giving projects points based on the costs of the projects in relationship to each other • Higher levels of agreement that the amount of subsidy put into a project is more important than the total cost of the project Cost Containment • QAP
Topic Seven: General Comments Pre-Application • Survey Highlights • Support for adding pre-application to the competitive application process • Next Steps • Work with developer stakeholders to identify appropriate level of detail to be shared through a pre-application • QAP
NEXT STEPS Membership and Mission Membership and Mission QAP Update Next Steps • Survey results finalized and shared to stakeholder groups, including Housing Stability Council • Stakeholder Outreach; scheduling in April & May: • Developers • Lenders / Investors • Jurisdictions / Public Funders • Culturally specific partners • May Housing Stability Council QAP update on survey elements and policy questions • QAP
QAP QUESTIONS? • QAP