RAD Roundup – RAD Supplemental Guidance

There has been a lot of activity around the new RAD guidance documents over the past few days. This post is meant to compile a lot of that information in one place.

New RAD Guidance Documents:

Additional HUD Documentation of new RAD Guidance Documents:

Additional non-HUD Posts:

 

HUD Publishes Notice on Voluntary Transfer and Consolidation of HCV Programs

HUD has published PIH 2018-12 titled “Process for Public Housing Agency Volunteer Transfers and Consolidations of Housing Choice Vouchers and Project-Based Vouchers.” The notice describes the process by which a PHA may request a voluntary transfer or a consolidation of the agency’s Housing Choice Voucher (HCV) program. In a voluntary transfer, one PHA’s identifying number and Consolidated Annual Contributions Contract (CACC) remains intact, while in a consolidation, both or all of the PHA’s names, CACCs, and identifying numbers are terminated and replaced. The notice applies to PHAs that administer the HCV program, including project-based vouchers (PBVs), but excludes the Public Housing Low-Rent program and the Section 8 Moderate Rehabilitation program.

Click below for additional information.

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HUD Publishes New RAD Guidance

Tomorrow, HUD will publish new Rental Assistance Demonstration (RAD) guidance in the form of two new Federal Register notices. The Department has also published a new RAD Public and Indian Housing (PIH) Notice. The three new guidance documents are the following:

  1. Rental Assistance Demonstration: Implementation of Certain Fiscal Year (FY) 2018 Appropriations Act Provisions (link is to a pre-publication copy);
    1. [7/3/18 Edit – The final, published document can be found here];
  2. Rental Assistance Demonstration: Supplemental Guidance on Final Notice (link is to a pre-publication copy);
    1. [7/3/18 Edit – The final, published document can be found here]; and
  3. PIH-2018-11Rental Assistance Demonstration (RAD) – Supplemental Guidance.

[7/2/18 11:55 am edit – At the same time this post was published, HUD sent a RADBlast! email with additional information.

  • Modified FY 16 RAD Rents can be found here.
  • HUD will host a webinar on July 9, 2018 at 2 pm ET. Registration can be found here.
  • Finally, a version of the RAD notice revised version 3 as amended with the Supplemental Notice can be found here.]

The first notice announces several things:

  1. HUD will use rent levels based on the FY 18 RAD rent base year for Commitments to enter into a HAP contract (CHAPs), portfolio awards, and multi-phase awards issued on or after January 1, 2019. Those rent levels will be published once the final public housing operating subsidy obligation is made for FY 18.
  2. For awards before Jan. 1, 2019, HUD will modify the FY 16 RAD rent base year by replacing the PHA’s FY 16 Capital Fund Formula Grant  with the PHA’s FY 18 Capital Fund Formula Grant (i.e., in calculating RAD rents before Jan. 1, 2019, HUD will use FY 18 Capital Grant allocations, but FY 16 Operating Fund allocations and tenant rents);
  3. The Department can award RAD authority to certain projects where PHAs have submitted Letters of Interest (LOIs) to reserve their position on the RAD waiting list if they submit a complete RAD application within 60 days of publication of the notice;
  4. For all multi-phase awards issued after March 22, 2018, PHAs will have until September 30, 2024 to submit an application for the final phase of the project covered by the multi-phase award; and
  5. HUD may approve a replacement CHAP without new application materials, when a PHA voluntarily withdraws a project and requests new RAD authority for the same project within one month thereafter.

The second notice summarizes certain aspects of the PIH notice. It expands Rent Bundling such that PHAs may bundle between RAD project-based vouchers and non-RAD project-based vouchers. It allows PHAs to establish a project-specific utility allowances for Covered Projects. It provides alternative developer fee limits when a PHA adopts a waiting list preference for households exiting homelessness. It establishes that HUD will disapprove a proposed conversion where a PHA is disposing units at a proposed project and HUD determines that the use of disposition and RAD undermines the unit replacement requirements of RAD. It creates a streamlined conversion option for PHAs that have a very small public housing portfolio of 50 units or less that will not involve any rehabilitation, new construction, or relocation.

NAHRO members will receive additional coverage on these notices and the RAD program.

HUD Releases CoC Program Competition NOFA

On June 20, HUD issued the Notice of Funding Availability (NOFA) for the FY 18 Continuum of Care (CoC) Program Competition. The FY 18 omnibus provided $2.513 billion to fund the Homeless Assistance Grants account, $130 million above FY 2017 enacted, including at least $2.106 billion for the Continuum of Care (CoC) and Rural Housing Stability Assistance programs. Approximately $2.1 billion is available in this FY 2018 CoC Program Competition NOFA, including up to $50 million available for Domestic Violence Bonus projects. Interested parties can apply as either collaborative applicants or  project applicants.

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HUD Posts Lead-Base Paint Hazard Reduction Grant NOFA

On June 19, HUD posted a Notice of Funding Availability (NOFA) for federally recognized Native American tribal governments, city or county townships, county governments, state governments, and special district governments for its Lead-Based Paint Hazard Reduction program. The purpose of the grant is to help eligible entities undertake “comprehensive programs to identify and control lead-based paint hazards in eligible privately-owned rental or owner-occupied housing populations.” Continue reading

HUD Seeks Comments on Disparate Impact

On Wednesday, June 20, HUD will formally publish their Advanced Notice of Proposed Rulemaking  (ANPR) titled, “Reconsideration of HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard.” HUD is seeking comment on whether they should reopen the rule based on the Supreme Court’s ruling in the 2015 Texas Department of Housing and Community Affairs versus the Inclusive Communities Project, Inc (Inclusive Communities) and public feedback relating to HUD’s regulatory reform efforts. Comments are due 60 days after the ANPR is published on June 20th. HUD announced their plan to reexamine the Disparate Impact Final Rule in a press release on May 10th.

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HUD Voucher NOFAs extended

NAHRO members recently emailed me to let me know that HUD has extended two of their voucher NOFA deadlines. According to information posted on HUD’s Public and Indian Housing website the following voucher Notice of Funding Availability (NOFAs) have extended deadlines:

  • New 2017 Mainstream Voucher Program Deadline – June 20, 2018; and
  • New Family Unification Program NOFA for Fiscal Years 2017 and 2018 Deadline – July 26, 2018.

Additionally, the new deadline for joining ConnectHomeUSA is June 29th, 2018.

Final Round of Opportunity Zones Approved

On April 14, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) announced the final round of designated Opportunity Zones in 4 additional states. Established by the Tax Cuts and Jobs Act of 2017, Congress created the new community development program that encourages long-term investments in low-income urban and rural communities. The Opportunity Zone Program provides tax incentives for investors to re-invest unrealized capital gains into Opportunity Funds. Opportunity Funds are private sector investment vehicles that invest at least 90 percent of their capital in Opportunity Zones. This new program has the potential to be an important, viable program for housing and community development agencies.

According to the Department of the Treasury, nearly 35 million Americans live in the communities designated as Opportunity Zones, and designated census tracts  had an average poverty rate of over 32 percent.

The final round of submissions were approved for: Florida; Nevada; Pennsylvania; and Utah.