Affordable Housing

COVID-19 CDBG Eviction Moratorium Q&A Released

~ Chris Campbell ~ Leave a comment

Earlier today, HUD released a Q&A to address questions concerning the eviction moratorium established by the CARES Act. Section 4024 of the Act imposes a 120-day moratorium on evictions, ending July 24, 2020. The moratorium extends to units in projects receiving funding from Community Development Block Grants (CDBG), Neighborhood Stabilization Programs (NSP) or Disaster Recovery.  

The Q&A clarifies which units are covered by the eviction moratorium, and which fees landlords may charge tenants for accrued costs after the moratorium ends. The full Q&A can be found here. For additional guidance, please visit the CDBG COVID-19 Resources page.  

NAHRO provides additional COVID-19 resources at www.NAHRO.org/coronavirus.

RAD COVID-19 FAQ Updated

~ Tushar Gurjal ~ Leave a comment

In a RADBlast! email earlier today, HUD noted that they have updated one of their COVID-19 FAQs with additional information on RAD conversions during the COVID-19 event. According to the email, this update includes “further guidance on completing environmental reports when professionals may not be able to access the interior or exterior of the site . . . [and] provides an option that would give PHAs more time to execute new Section 8 leases at the point of conversion.”

The updated FAQ may be found here.

[5/21/2020 – edited for clarity.]

Two Additional HCV Guidebook Chapters Published

~ Tushar Gurjal ~ Leave a comment

The Housing Choice Voucher (HCV) guidebook continues to be updated by HUD. Most recently, chapters on Utility Allowances and Special Housing Types have been added. Currently available chapters include the following:

The National Association of Housing and Redevelopment Officials is excited that HUD is continuing to update its HCV guidebook. We enthusiastically await future chapters and the regular and timely updating of the guidebook.

The full guidebook may be accessed here.

Managing During COVID-19: Homelessness Resources Webinar – Wed, May 27 at 2pm ET

~ Georgi Banna ~ Leave a comment

On Wednesday, May 27. 2020, NAHRO is hosting a complimentary webinar – Managing During COVID-19: Homelessness Resources.

Join Nan Roman, President and CEO of the National Alliance to End Homelessness, and leaders from NAHRO member agencies for a discussion of available homelessness resources and best practices for their use. Bring your questions and comments and join your fellow PHAs for this interactive webinar!

Register for NAHRO’s Managing During COVID-19: Homelessness Resources Webinar here!

Final CRA Rule Released by OCC

~ Eric Oberdorfer ~ Leave a comment

Earlier today, the Office of the Comptroller of the Currency (OCC) finalized their overhaul of the Community Reinvestment Act (CRA) regulations. Although the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (FDIC) released a proposed CRA rule together, the FDIC noted that they are not prepared to finalize a CRA proposal at this time, meaning the FDIC’s final rule may differ from the OCC’s. Moreover, the Federal Reserve, also responsible for governing the CRA, was not involved in the proposed rule.

The CRA is a critical tool that encourages banking and lending institutions to lend necessary funding to affordable housing and community development projects by receiving favorable CRA consideration for community development activities. These activities include investment in Low-Income Housing Tax Credit (LIHTC) projects, New Market Tax Credit (NMTC) projects, and historic rehabilitation tax credit projects. Virtually no affordable rental housing development would occur without LIHTC, and the CRA is critical to ensuring banks remain motivated to invest in LIHTC.

Continue reading →

Repositioning Webinar Series

~ Tushar Gurjal ~ Leave a comment

HUD’s Office of Public and Indian Housing (PIH) is holding a series of webinars to help PHAs understand the repositioning process and identify strategies and resources to complete the repositioning process. All webinars will be held between 1 pm and 3 pm ET. Topics may be found below.

Webinar TopicsDatesRegistration
Developing a Repositioning StrategyMay 13, 2020
Options for Scattered-Site UnitsJune 3, 2020Register Now
Options for 50-and-Under PHAsJune 24, 2020Register Now
RAD and Section 18 BlendsJuly 22, 2020Register Now
Resident ConsiderationsAugust 12, 2020Register Now
Streamlined Voluntary ConversionSeptember 2, 2020Register Now
Options for Obsolete UnitsSeptember 30, 2020Register Now
Common PHA Board QuestionsOctober 28, 2020Register Now
PHA CloseoutNovember 18, 2020Register Now

Additional information may be found here.

Postponed – NAHRO Presents Webinar on CARES Act Funding and Waivers

~ Georgi Banna ~ Leave a comment

UPDATE – The Managing During COVID-19” series: “PHA to PHA Best Practices webinar scheduled for Wednesday, May 20 from 2-3 pm eastern time has been postponed. We apologize for any inconvenience this postponement has caused. Best practices on CARES Act funding and waivers will be discussed in future webinars. Information on future webinars will be posted at www.nahroblog.org. Thanks again.

Tune in this coming Wednesday, May 20, from 2-3 p.m. eastern time for the latest installment of our complimentary Managing During COVID-19” series: “PHA to PHA Best Practices! Your fellow NAHRO members will discuss which waivers they’re using and what they’re spending their funding on. Learn from your peers, ask questions, and share your own ideas!

Click Here to Register for the complimentary webinar Managing During COVID-19: Sharing Best Practices: Waivers and Funding!

Admin Fee Set-aside Application Deadline Extended

~ Tushar Gurjal ~ Leave a comment

Yesterday, HUD sent an email extending the deadline for certain requests related to the administrative fee for the Housing Choice Voucher (HCV) program. The Department will not accept regular mail or faxes for these applications. so PHAs must submit their applications electronically. The extended deadline of 5 pm ET on Wed., July 15, 2020 applies to the following administrative fee requests:

  • Blended administrative fee rate requests (questions may be sent to PIHFinancialManagementDivision@hud.gov);
  • Higher administrative fee rate requests (questions may be sent to FinancialManagementCenter@hud.gov);
  • Special fees (questions may be sent to 2020SpecialFees@hud.gov), including:
    • Category 1: HUD-VASH special fees;
    • Category 2: Family Unification Program special fees;
    • Category 3: Disaster Related Special Fees; and
    • Category 4: Application for other Special Fees under the Secretary’s Discretion.

PIH Notice 2020-04 (a notice implementing the HCV program in calendar year 2020) provides additional details on the eligibility and documentation requirements.

CARES Act Supplemental Operating Fund Draw Downs For Immediate Needs Only

~ Eric Oberdorfer ~ Leave a comment

Today, HUD’s Financial Management Division (FMD), sent out an email to PHAs regarding the draw down of CARES Act Supplemental Operating Funds. PHAs should only draw down CARES Act Supplemental Operating Funds as needed to fund eligible, immediate needs to prepare for, prevent, and respond to coronavirus. Unlike regular Operating Funds, which can be drawn down all at once, CARES Act Supplemental Operating Funds can only be drawn down to pay for immediate needs and cannot be held as reserves. These funds are available to PHAs via a single obligation to a unique grant number, ending with the letter “C.” Any funds that have been drawn down other than to pay for immediate needs must be returned to HUD. Returned funds will be reapplied to the funds available under the Award Number/Project Number and will remain available through December 31, 2020 or at a later date if HUD deems an extension necessary. PHAs that have drawn down funds in excess of their immediate needs should contact their Field Office.

HUD PIH Clarifies CARES Act Funding Timeframe Eligibility and Reporting Requirements

~ Tushar Gurjal ~ Leave a comment

Earlier today, HUD PIH sent an email to PHA Executive Directors clarifying the timeframe around the use of Coronavirus Aid, Relief, and Economic Security Act (CARES Act) funding and clarifying CARES Act reporting requirements. Additional questions regarding the CARES Act may be sent to PIH-COVID@hud.gov.

The text below is taken directly from the email sent by HUD.

Q: What is the start date for use of new public housing funds under the CARES Act? Is it the date of the implementation notice (April 28, 2020), the date they were awarded (May 1, 2020), or the date the CARES Act was passed (March 27, 2020)?

A: 2020 Public housing funds were disbursed for public housing starting May 1, 2020. These funds can cover expenses, including expanded COVID-19 related expenses included in Notice PIH 2020-07, that were incurred starting March 27, 2020. CARES Act obligations should not relate back to a period any earlier than March 27, 2020. 

Q: What is the start date for the use of new HCV Program Administrative Fees awarded under the CARES Act?

A: 2020 HCV Program Administrative Fee funds were disbursed starting May 7, 2020. HCV Administrative Fees can cover expenses, including expanded COVID-19 related expenses included in Notice PIH 2020-08, that were incurred starting March 27, 2020. CARES Act obligations should not relate back to a period any earlier than March 27, 2020. 

Q: My PHA incurred a number of expenses related to COVID-19 prior to the arrival of the CARES Act funds, as our local outbreak started in February. Can these funds cover those expenses? What if we used other funds to cover these expenses– can those accounts be reimbursed?

A: For the public housing program, expenses incurred beginning on March 27, 2020 can be paid for with CARES Act supplemental operating funds, public housing operating funds or public housing capital funds. For the housing choice voucher program, expenses incurred beginning on March 27, 2020 can be paid for with CARES Act funding or FY 2020 administrative fees. If the PHA used other accounts to pay expenses incurred on March 27th or later, they can be reimbursed by the CARES Act funding.

Q: Can you clarify the CARES Act reporting requirements?

A: As described in PIH Notice 2020-07 and PIH Notice 2020-08, the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit certain information regarding the use of CARES Act funds.

This reporting is required for “covered recipients,” defined as any entity that receives covered funds that amount to more than $150,000.  PHAs that receive CARES Act funds that amount to more than $150,000 will be subject to this additional reporting requirement based on the total amounts awarded, not each individual grant award. As outlined in the Office of Management and Budget (OMB) memorandum, M-20-21, existing reporting requirements are anticipated to meet the requirements of Section 15011, but the content and format for this reporting is still under development and will need to be reviewed against current program practices.  The Department will work in coordination with OMB to ensure that this requirement can be fulfilled by recipients of CARES Act funding in a manner that utilizes to the greatest extent possible existing reporting streams, providing the necessary transparency and accountability with minimal additional burden.  If additional reporting is necessary, further guidance will be released by the Department in the near future.