Timely Insights from HUD Multifamily DAS

Regulation | July 14, 2017 | by Colleen Bloom

LeadingAge staff met July 12 with Bob Iber, acting deputy assistant secretary (DAS) for multifamily housing, and a broad range of multifamily housing office directors and program heads - and covered a lot of ground on topics of current concern.

During a discussion with LeadingAge and a coalition of other housing provider, HUD staff gave timely updates on a range of topics.

Among the most significant issues, the status of service coordinator grant funding for FY17,   After more than seven months without funding:

HUD gave LeadingAge staff strong assurances that 90% of all FY17 Service Coordinator grant funding will be out and available to properties in all parts of the country (including New York) by the end of July. This includes the batch 1 (60% of initial funding AND the supplemental 40% to fund the contracts for the full 12 most); and batch 2 (100% of funding). So if ANY MEMBER with grants in these two batches does NOT have full funding as of August 1, please send an email to us directly.

Other significant developments include:

  • The CNA e-tool will not become mandatory until October 1, and could potentially be pushed out a bit further (this was later pushed out to November 1 due to the 2017 hurricanes).
  • The Energy Benchmarking mandate is not going into effect at this time, except for the Green MIP program (a very limited FHA insurance product, hopefully you know well if you’ve got it)
  • VAWA documents that expired June 30 can continue to be used until replaced. HUD is preparing some minor tweaks, and a federal register announcement with 60 day comment is expected shortly. The VAWA lease addendum 91067 has still not been modified for the expanded programs. VAWA FAQs are still expected out “soon.” And findings for failure to have an adequate emergency transfer policy have been pushed out until December 2017 (see also new VAWA notice H 2017-05 issued June 30)
  • Recently published proposed FHA Flood Plain changes will not be enacted. A rescission/withdrawal to be published soon.
  • Changes to remove the requirement to use EIV during interim certifications is in the works, as are efforts to revise the problematic “income discrepancy report” and revamp it into a new “income validation tool. As part of this effort, student income will be capped at $480 to eliminate “discrepancies” for incomes above that, and to make EIV more interactive so that bogus deceased tenant reports can be identified and disabled for future “discrepancy” reporting.

Additional items of significant interest:

  • A fully updated Section 8 renewal guide has now been posted – and owners with a short term Option 4 contract can request an early termination and get a longer term renewal. (If you have Debt Service Savings and wish to explore this option, please contact us to discuss implications and options to protect DSS funded programs and services)
  • More chapters from HUD Handbook 4350.1 have been posted for comment – please take a look and give us your feedback a week before the HUD deadlines (current hot topics include combining of rental subsidy contracts (CHAPTER 4.01 Asset Preservation), and interest rate reductions to previously refinanced properties (CHAPTER 6.03 Asset Restructuring ) - comments due to HUD by July 24; a new chapter on oversight of Green Retrofit and Mark-to-Market programs (CHAPTER 8.03 Servicing and Monitoring HUD-Held Mortgages) comments due on Aug 24