HUD Webinars for new RAD Notice (Rev. 4)

The HUD Office of Recapitalization sent a RADBlast! email reminding those on the Rental Assistance Demonstration (RAD) email list that HUD will be hosting live public webinars on sections of the new RAD notice. The webinars will be recorded and posted on the RAD Resource Desk.

The schedule can be found below:

  • Public Housing Conversions, September 19, 2019, 2 pm ET; Register here;
  • Section 202 Project Rental Assistance Contract (PRAC), September 26, 2019, 2 pm ET; Register here;
  • Moderate Rehabilitation (Mod. Rehab.), October 3, 2019, 2 pm ET; Register here;
  • Resident Rights in Public Housing Conversions, October 10, 2019, 2 pm ET; Register here;
  • Resident Rights in Section 202 PRAC and Mod. Rehab. Conversions, October 17, 2019, 2 pm ET; Register here.

The new RAD notice (Rev. 4) can be found here.

New RAD Notice, Revision 4 Released

Earlier today, HUD released the new Rental Assistance Demonstration (RAD) notice: “Rental Assistance Demonstration – Final Implementation, Revision 4” (Notice H-2019-09; PIH-2019-23 (HA)). The RAD program allows for units to be converted from certain Department of Housing and Urban Development (HUD) funding streams, such as public housing, to either a Section 8 project-based voucher (PBV) funding stream or a Section 8 project-based rental assistance (PBRA) funding stream. There are several major changes in this notice, including changes to the First Component of RAD (which allows public housing units to be converted to PBV or PBRA) and implementation of the 2018 Appropriations Act provision allowing Section 202 project rental assistance contracts (PRAC) to be converted to PBV or PBRA.

The changes to the First Component of RAD include the following:

  • A policy that RAD rents will be updated every two years (RAD awards after each update will use the updated rents);
  • A newly added “Concept Call” step to the RAD process, to allow PHAs to receive confirmation that project plans are sufficiently advanced to submit a Financing Plan;
  • More stringent notice requirements for residents in developments to be converted (the new notice details resident participation requirements at each step of the RAD process);
  • A policy that all households residing in regular PBV units will have the same resident rights extended to them as households that reside in RAD-PBVs in converted developments;
  • A mechanism for PHAs to enter into partnerships with each other to convert developments;
  • A policy allowing for rent increases in certain scenarios for PBRA conversions, such as developments located in Opportunity Zones;
  • Elimination of the requirement to submit the Capital Needs Assessment (CNA) tool in certain scenarios; and
  • Other changes (including changed requirements for portfolio awards, a change in how PHAs report debts owed, and broadening the use of “tiered environmental reviews”).

At this time, NAHRO staff are still reviewing the new notice. Additional analysis will be provided in future NAHRO publications.

The RAD Notice, Revision 4 can be found here.

[2:17 pm edit – The new notice can also be found on HUD’s RAD website here.]

HUD, FHA Issue Condominium Rule

Last week HUD released the final rule on FHA approval for single-family condominiums. HUD touts the rule as opening the FHA single-family loan products to both younger, first-time home buyers and seniors looking to age-in-place.

The rule sets the policies to update the Single Family Policy Handbook, expand single-unit approval, establish minimum owner-occupancy requirements, limit FHA insurance concentration in condominium projects, and institute commercial/nonresidential space limits.  The rule is effective October 15, 2019, and HUD estimates that 20,000 to 60,000 condominium units could be eligible for FHA-insured financing annually.

HUD’s press release on the Condominium Approval Final Rule can be viewed here.

The Condominium Approval Final Rule is available here.

Presenters Updated! Tomorrow!! Complimentary PH Unit Preservation Webinar – July 2, 1pm ET

LAST CHANCE TO REGISTER. NAHRO is hosting a complimentary Public Housing Unit Preservation Webinar tomorrow, Tuesday, July 2, at 1pm eastern time. Join Andy Rodriguez, Executive Director of the Nampa (ID) Housing Authority; Edward Mayer, Executive Director of the Housing Authority of the County of Butte (CA); and Georgi Banna, NAHRO’s Director of Policy and Program Development who will share and overview of the preservation options and will their experiences and decision making process in preserving their Public Housing units.

This session is for agencies of all sizes from the smallest to the largest and will discuss HUD’s outreach, the options and first-hand PHA experiences. Below is information on the session and the registration link.

Public Housing Preservation Options – The PHA Perspective

Has HUD reached out to your agency to discuss the future of your public housing? Join us for this complimentary session to review your options, and the NAHRO Policy team is here to provide more information and help sort through a lot of the chatter. Are you interested in joining the Rental Assistance Demonstration (RAD), using the Section 18 Demolition/Disposition program, removing your Declaration of Trust, participating in a streamlined voluntary conversion process, or continuing in public housing? We’ll provide overviews of the options available to PHAs of all sizes and discuss HUD’s plans for the future. We will also be joined by Andy Rodriguez of the Nampa (ID) Housing Authority and Edward Mayer of the Housing Authority of the County of Butte (CA), who will share their experiences and decision making process in preserving their Public Housing.

Please register for Public Housing Preservation Options – The PHA Perspective on Jul 2, 2019 1:00 PM EDT at:

https://attendee.gotowebinar.com/register/4425060811873671691?source=blog2

After registering, you will receive a confirmation email containing information about joining the webinar.

Complimentary Webinar – Public Housing Repositioning – July 2, 1pm Eastern

On Tuesday, July 2, NAHRO will be hosting a complimentary webinar on HUD’s current effort of Public Housing Repositioning. Below is information on the session and the registration link. This session is for agencies of all sizes from the smallest to the largest and will discuss HUD’s outreach, the options and first-hand PHA experiences.

Public Housing Preservation Options – The PHA Perspective

Has HUD reached out to your agency to discuss the future of your public housing? Join us for this complimentary session to review your options, and the NAHRO Policy team is here to provide more information and help sort through a lot of the chatter. Are you interested in joining the Rental Assistance Demonstration (RAD), using the Section 18 Demolition/Disposition program, removing your Declaration of Trust, participating in a streamlined voluntary conversion process, or continuing in public housing? We’ll provide overviews of the options available to PHAs of all sizes and discuss HUD’s plans for the future. We will also be joined by Andy Rodriguez of the Nampa (ID) Housing Authority, who will share Nampa’s experiences and decision making process in preserving their Public Housing.

Please register for Public Housing Preservation Options – The PHA Perspective on Jul 2, 2019 1:00 PM EDT at:

https://attendee.gotowebinar.com/register/4425060811873671691?source=blog

After registering, you will receive a confirmation email containing information about joining the webinar.

HUD Offers Technical Assistance for PHAs Considering Repositioning their Public Housing Assets

Last week, HUD’s Office of Public and Indian Housing sent an email detailing the communication and technical assistance efforts HUD was making to ensure that PHAs understood the range of options that were available to reposition their public housing assets. The following are bullet points quoted directly from the email:

  • PIH staff have been making presentations at local and national industry meetings to help PHAs become more aware of their repositioning options.
  • PHAs wanting to learn more about their repositioning may ask their local Field Office staff to walk them through the benefits of the various options—always with a focus on how best to address the local needs.
  • PIH has set up Repositioning Assistance Panels. Field office staff can reserve time with program experts identified by the Office of Recapitalization, Special Applications Center (SAC), Urban Revitalization Division, and Office of Housing Voucher Programs. These experts can discuss the various repositioning options with a PHA, enabling an informed decision about what strategy would best meet local needs. You can set up a time with a Panel through your local Field Office.
  • We have also trained Repositioning Expeditors in most Field Offices. These Expeditors are available to help PHAs with their RAD, voluntary conversion, and demo/dispo applications.
  • Understanding that these repositioning options are complex, particularly for small PHAs, the Department is working to provide the following starting late spring:
    1. Develop training materials, sample documents and other tools that help PHAs consider repositioning strategies and understand available options;
    2. Provide local training sessions to present available repositioning tools and considerations to address local affordable housing needs;
    3. Develop an online training platform and training materials to help PHAs and their boards understand repositioning options and HUD requirements; and
    4. Provide direct technical assistance to small PHAs (operating 250 or less assisted units) in how to start and sustain affordable housing strategies.

NAHRO reminds our members that repositioning is a voluntary process. The Department is providing a range of options, none of which are mandatory. Interested agencies should take actions–or not–based on the needs of their local communities and the households the agencies serve.

HUD Publishes Notice on Voluntary Conversions

In late March, HUD published a notice titled “Streamlined Voluntary Conversions of Last Remaining Projects of Small Public Housing Agencies” (PIH 2019-05 (HA)). This notice allows PHAs with 250 or fewer Public Housing units to convert them to Section 8 vouchers within the Housing Choice Voucher (HCV) program under a streamlined conversion process. This notice differs from the Rental Assistance Demonstration (RAD) program in several ways, but primarily in that instead of receiving RAD rents (i.e., a combination of public housing capital fund, operating fund, and tenant rent amounts), PHAs would receive full HCVs for their residents after conversion.

For a PHA to normally use the voluntary conversion option, it must conduct a conversion assessment and provide a timeline identifying PHA conversion actions. Under this notice, HUD is using its statutory authority to waive the conversion assessment requirement to make it easier for small PHAs to convert their portfolios. Public Housing Agencies are eligible under this notice if they meet the following requirements:

  • They have a portfolio of 250 or fewer public housing units;
  • They intend to close-out their public housing program; and
  • Conversion will result in the conversion of all public housing units.

If a converting PHA does not administer a Section 8 HCV program, then another PHA with a Section 8 HCV program must be identified to administer the vouchers.

To apply for a conversion, eligible PHAs must submit a conversion plan to HUD through the Inventory Management System / Public and Indian Housing Information Center (IMS/PIC). The conversion plan and application must include a PHA plan referencing the proposed conversion; evidence of resident involvement; evidence of board approval; a plan of future use of involved assets; HUD approval of environmental requirements; an impact analysis of the conversion on the neighborhood(s) (in the form of a narrative statement); a summary of information concerning the relocation plan; close-out information; and another Section 8 HCV program identified to receive vouchers, if the applying PHA does not have a Section 8 HCV program. Additionally, certain other requirements must be met (e.g., civil rights reviews, etc.). The Department must respond within 90 days of the PHA submitting the conversion plan.

The full notice can be found here.

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 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.

FY 2018 Housing Trust Fund Allocations Announced

On June 5, HUD will allocate more than $266 million in FY 2018 formula funds to eligible grantees of the National Housing Trust Fund (HTF) program. The HTF is a non-appropriated federal resource that complements existing Federal, State and local efforts to preserve and expand the nation’s supply of affordable homes for very low-income (VLI) and extremely low-income (ELI) households, as well as families experiencing homelessness. Authorized in 2008, lawmakers sought to establish a permanent source of affordable housing funding through annual contributions from Fannie Mae and Freddie Mac (GSEs). Eight years later, the HTF was finally capitalized through its inaugural FY 2016 allocations. HTF grantees include the 50 states, District of Columbia, and five U.S. Insular Areas. Grantees may distribute funds through subgrantees (a unit of general local government or State agency) or directly fund projects proposed by eligible recipients (including PHAs), or a combination of both.

 FY 2018 Housing Trust Fund Allocations

State / Territory

FY18 Allocation % Change (FY17 to FY18)

California

$36,616,277

58%

New York

$22,171,681

50%

Texas

$12,279,085

39%

Florida

$10,442,914

36%

Illinois

$9,812,230

37%

Pennsylvania

$7,759,948

32%

New Jersey

$7,726,903

38%

Ohio

$6,971,712

27%

Michigan

$6,004,558

24%

Massachusetts

$5,720,333

24%

North Carolina

$5,874,191

32%

Georgia

$5,705,499

29%

Washington

$5,197,313

26%

Virginia

$4,672,562

22%

Wisconsin

$4,117,505

18%

Indiana

$3,937,462

17%

Missouri

$3,970,270

18%

Arizona

$3,997,777

21%

Tennessee

$3,688,511

17%

Colorado

$3,563,587

13%

Oregon

$3,654,189

16%

Minnesota

$3,445,781

10%

Maryland

$3,578,771

17%

Connecticut

$3,269,474

9%

Louisiana

$3,068,829

2%

South Carolina

$3,007,655

0%

Alabama, Alaska, Arkansas, Delaware, District Of Columbia, Hawaii, Idaho, Iowa, Kansas, Kentucky, Maine, Mississippi, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Dakota, Oklahoma, Rhode Island, South Dakota, Utah, Vermont, West Virginia, Wyoming

$3,000,000 (Required State Minimum)

Puerto Rico

$1,253,357

42%

American Samoa

$11,995

54%

Guam

$97,028

54%

Northern Marianas

$53,415

54%

Virgin Islands

$104,591

54%

Total $266,775,403

22%