Friday, March 31, 2006
No word yet on how the conversation went this afternoon at the Senate hearing on McKinney-Vento, homelessness, and kindred matters, but the prepared statements are posted for assorted dignitaries from the world of homeless services, federal and otherwise.
The extent of the damage, bean-counted
Wow. The Dept. of Homeland Security is distributing a 45-page report, prepared by HUD researchers last month, with housing damage estimates for the 2005 hurricanes. Included are tables of damage to owner-occupied and rental housing by type, severity, location, and insurance status. Thanks to the HUDUSER listserv for the tip.
New 1-fam default reporting rules and more
- As of May 1, lenders will have to report overdue payments on HUD-insured single-family mortgages when they're 30 days late, instead of the current 90 days. The preamble to the new final rule explains, "The receipt of more up-to-date information will enable HUD to better monitor its loss mitigation program and strengthen the soundness of the Federal Housing Administration (FHA) mortgage insurance funds."
- HUD is inviting comments on Form HUD-92547-A, the multifamily housing owner's budget worksheet for budget-based rent increases.
- In the Craigslist free-speech case, HUD has gotten into the act on the question -- surprisingly difficult to answer -- of whether fair housing laws apply to Internet listings.
- HUD is requesting comments on the financial management template that public housing authorities submit twice a year.
- For managers of buildings serving seniors and others eligible for Medicare, RHIIP is noting this HHS document on a renewed attempt to assist smooth transitions into the famously confusing prescription drug program. (Note: social services people helping recipients of both Medicare and Medicaid -- or a state-managed Medicaid equivalent such as California MediCal -- may want to check which medicines are covered by one program and not the other.)
- HUD is inviting comments on Form HUD-92547-A, the multifamily housing owner's budget worksheet for budget-based rent increases.
- In the Craigslist free-speech case, HUD has gotten into the act on the question -- surprisingly difficult to answer -- of whether fair housing laws apply to Internet listings.
- HUD is requesting comments on the financial management template that public housing authorities submit twice a year.
- For managers of buildings serving seniors and others eligible for Medicare, RHIIP is noting this HHS document on a renewed attempt to assist smooth transitions into the famously confusing prescription drug program. (Note: social services people helping recipients of both Medicare and Medicaid -- or a state-managed Medicaid equivalent such as California MediCal -- may want to check which medicines are covered by one program and not the other.)
Sec'y Jackson before House Financial Services
No video archive at the committee site but at least the hearing page links to the Secretary's 10-page prepared statement backing HUD's portion of the fiscal 2007 White House budget proposal.
[UPDATE: Here's a HUD press release partially describing Jackson's testimony.]
[UPDATE: Here's a HUD press release partially describing Jackson's testimony.]
Thursday, March 30, 2006
HUD relents on some LIHTC/PBV rents
Today's new Public and Indian Housing Notice 2006-16 looks like HUD has partly given in to complaints raised in November over the discovery that the October 2005 final rule on project-based voucher housing apparently overrode PIH Notice 2002-22, thereby cutting the rent amounts owners may claim for some housing that is subsidized both by Sec. 8 project-based vouchers and by low-income housing tax credits (LIHTC).
Today's rule says that for housing receiving both these subsidies, PIH Notice 2002-22 will remain in effect solely for projects that received their written notices of owner selection from their local public housing authorities before Nov. 14, 2005. After that, the new rent caps apply.
Here I have to own up to a mistake I made in the November post I've cited above: I thought the new rule made a change only for projects that receive extra tax credits for being in one of the Qualified Census Tract (QCT) areas of mismatch between incomes and housing costs. I have to admit I misunderstood the Nixon Peabody alert that pointed out the problem. (To read the alert, choose "News & Events," then "Publications," then "Affordable Housing Law Alert," and scroll down to Nov. 14, 2005.)
Based on a contritely thorough reading of relevant regulatory materials, it appears that in fact the October final rule tightened the rent caps in at least these two categories: (1) QCT properties receiving both kinds of subsidies where the formula-derived LIHTC rent is lower than either 110% of local HUD "Fair Market Rent" (FMR), or any applicable HUD exception rent, or rents for comparable nearby market-rate units, and also (2) properties receiving both kinds of subsidies outside QCTs where the LIHTC formula rent is lower than either 110% of FMR or any applicable HUD exception rent.
The October rule appeared to be overriding PIHN 2002-22 and saying properties in these categories had to stick to the formula LIHTC rent even if it was lower than the other two figures. (And from my reading of the Final Rule just now it may not even be clear what becomes of properties where the LIHTC rent exceeds FMR and all units receive project-based voucher subsidies.) If you want to check it yourself, start with the new 24 CFR Secs. 983.301, and 983.304 in the Oct. 13, 2005 Final Rule. Especially the frustratingly backhanded provisions of 983.304(c).
But as of today's rule, this restriction "only" applies to the newest double-subsidized projects, and apparently to all such projects from now on.
Today's rule says that for housing receiving both these subsidies, PIH Notice 2002-22 will remain in effect solely for projects that received their written notices of owner selection from their local public housing authorities before Nov. 14, 2005. After that, the new rent caps apply.
Here I have to own up to a mistake I made in the November post I've cited above: I thought the new rule made a change only for projects that receive extra tax credits for being in one of the Qualified Census Tract (QCT) areas of mismatch between incomes and housing costs. I have to admit I misunderstood the Nixon Peabody alert that pointed out the problem. (To read the alert, choose "News & Events," then "Publications," then "Affordable Housing Law Alert," and scroll down to Nov. 14, 2005.)
Based on a contritely thorough reading of relevant regulatory materials, it appears that in fact the October final rule tightened the rent caps in at least these two categories: (1) QCT properties receiving both kinds of subsidies where the formula-derived LIHTC rent is lower than either 110% of local HUD "Fair Market Rent" (FMR), or any applicable HUD exception rent, or rents for comparable nearby market-rate units, and also (2) properties receiving both kinds of subsidies outside QCTs where the LIHTC formula rent is lower than either 110% of FMR or any applicable HUD exception rent.
The October rule appeared to be overriding PIHN 2002-22 and saying properties in these categories had to stick to the formula LIHTC rent even if it was lower than the other two figures. (And from my reading of the Final Rule just now it may not even be clear what becomes of properties where the LIHTC rent exceeds FMR and all units receive project-based voucher subsidies.) If you want to check it yourself, start with the new 24 CFR Secs. 983.301, and 983.304 in the Oct. 13, 2005 Final Rule. Especially the frustratingly backhanded provisions of 983.304(c).
But as of today's rule, this restriction "only" applies to the newest double-subsidized projects, and apparently to all such projects from now on.
A little hopeful (?) news on homelessness
The Interagency Council on Homelessness reports with pride that in a recent hearing on homeless veterans, the testimony included word that there are some 60,000 fewer homeless veterans in the U.S. than there were ten years ago. Unclear how much of the reason has to do with people getting indoors and how much with the life expectancies of people who don't, but homelessness figures so seldom decline, ya may as well smile.
Also available from USICH: the link to a privately managed Web site of the White House Office of Faith-Based and Community Initiatives that is promoting regional workshops on applying for federal funds. Locations are in Jacksonville, Cincinnati, and Las Vegas, and the earliest registration deadline is April 6.
Also available from USICH: the link to a privately managed Web site of the White House Office of Faith-Based and Community Initiatives that is promoting regional workshops on applying for federal funds. Locations are in Jacksonville, Cincinnati, and Las Vegas, and the earliest registration deadline is April 6.
Wednesday, March 29, 2006
A new community land trust experiment
Now, this genuinely could be a wonderful thing:
King County, Washington opens a pilot program today to rehab a HUD home with the help of Habitat for Humanity. Interestingly, the home will be sold to "a deserving local family" but the land will remain in the hands of the Homestead Community Land Trust. Community land trusts are a really interesting way to help a household build equity rather than paying rent, while also leaving a public service entity in control of the property in question and ensuring that much of the value of a subsidy will stay with the property when the resident homeowners (who own the structure only, not the land) are ready to move on into a market-rate home purchase. For more information see the Web site of the Institute for Community Economics, which is the mothership organization for the community land trust mechanism.
King County, Washington opens a pilot program today to rehab a HUD home with the help of Habitat for Humanity. Interestingly, the home will be sold to "a deserving local family" but the land will remain in the hands of the Homestead Community Land Trust. Community land trusts are a really interesting way to help a household build equity rather than paying rent, while also leaving a public service entity in control of the property in question and ensuring that much of the value of a subsidy will stay with the property when the resident homeowners (who own the structure only, not the land) are ready to move on into a market-rate home purchase. For more information see the Web site of the Institute for Community Economics, which is the mothership organization for the community land trust mechanism.
Wednesday mix: de-hibernation edition
In which yr humble blogmother, having been under the weather for a few days, peers out from under the covers and finds that wonderful things have continued to happen in the world of housing:
- NH&RA links to a detailed state-by-state working paper from the National Housing Trust with new updates on state and local housing preservation using 9% low-income housing tax credits, 4% credits with private activity bonds, state or local housing trust funds, and other regional efforts. Really a good rundown on the state of housing preservation nationwide.
- Sec'y Jackson is quoted by Dow Jones as speaking on Fannie and Freddie at the National Association of Mortgage Brokers legislative conference. Comments include: "HUD is supporting legislation that allows a regulator to limit the GSE's portfolio to those investments necessary to carry out its mission, without trying to cripple or put it out of business."
- HUD nominates members for its Indian Housing Block Grant negotiated rulemaking committee.
- The CDFI Coalition is inviting members to send comment letters because the White House '07 budget proposal is again trying to zero out all the CDFI Fund grant programs and fund the sub-agency only enough to administer the New Markets Tax Credit. They've additionally posted a Senators' sign-on letter backing renewed funding for the grants.
- The CDFI Fund's Community Development Advisory Board, it seems, will be holding a public meeting this April 26 in Washington. Rather strikingly, members of the public who wish to attend are asked to provide advance information "required to facilitate their entry" to the "secured facility" where the meeting happens to have been scheduled.
- NH&RA links to a detailed state-by-state working paper from the National Housing Trust with new updates on state and local housing preservation using 9% low-income housing tax credits, 4% credits with private activity bonds, state or local housing trust funds, and other regional efforts. Really a good rundown on the state of housing preservation nationwide.
- Sec'y Jackson is quoted by Dow Jones as speaking on Fannie and Freddie at the National Association of Mortgage Brokers legislative conference. Comments include: "HUD is supporting legislation that allows a regulator to limit the GSE's portfolio to those investments necessary to carry out its mission, without trying to cripple or put it out of business."
- HUD nominates members for its Indian Housing Block Grant negotiated rulemaking committee.
- The CDFI Coalition is inviting members to send comment letters because the White House '07 budget proposal is again trying to zero out all the CDFI Fund grant programs and fund the sub-agency only enough to administer the New Markets Tax Credit. They've additionally posted a Senators' sign-on letter backing renewed funding for the grants.
- The CDFI Fund's Community Development Advisory Board, it seems, will be holding a public meeting this April 26 in Washington. Rather strikingly, members of the public who wish to attend are asked to provide advance information "required to facilitate their entry" to the "secured facility" where the meeting happens to have been scheduled.
Left Behind: the Baltimore edition
The Baltimore HUD housing desegregation lawsuit has gotten to the point of designing a remedy, and today's news is full of a revelatory debate about who would move to proposed new affordable housing units in the suburbs and what would happen to those who didn't.
Urban planning sizzle moves to Asia
China appears to be rapidly taking the lead position in designing and implementing exciting and futuristic urban designs and construction.
The folks at the Urban Land Institute appear to agree, having published a series of articles in the February 2006 issue of Urban Land magazine on China and Asia's remarkable transformation. Also, the folks at Realcomm are putting on a tour of Asian commercial real estate, the NextGen Best Practices Tour (go here and click on "tours" near the top of the screen), which sounds like it'd be fun and fascinating, if you've got $12,500 to spend (plus spare change for buying anime action figures for your kids).
It reminds me of a China tour some CCIM Institute executives took in the 1990s, in which they were given a first-hand look of the breakneck pace of that country's high-rise growth. (One person told me about being taken up a skyscraper under construction, only to find many, many flights up that there were no guard rails along the edge.)
And while design traditionalists like me mourn the destruction of many old, classic neighborhoods to make way for modern highrises, I'm still enough of a science geek to be excited by some of the cutting-edge designs and dense urban (what we'd call "smart growth") creations that are springing up.
About 100 or 150 years ago, it was cities such as Chicago and New York that were thrilling people with their building innovations and bold urban planning. Before that, it had been the great cities of Europe. Now, it definitely appears to be China and other Asian nations.
The folks at the Urban Land Institute appear to agree, having published a series of articles in the February 2006 issue of Urban Land magazine on China and Asia's remarkable transformation. Also, the folks at Realcomm are putting on a tour of Asian commercial real estate, the NextGen Best Practices Tour (go here and click on "tours" near the top of the screen), which sounds like it'd be fun and fascinating, if you've got $12,500 to spend (plus spare change for buying anime action figures for your kids).
It reminds me of a China tour some CCIM Institute executives took in the 1990s, in which they were given a first-hand look of the breakneck pace of that country's high-rise growth. (One person told me about being taken up a skyscraper under construction, only to find many, many flights up that there were no guard rails along the edge.)
And while design traditionalists like me mourn the destruction of many old, classic neighborhoods to make way for modern highrises, I'm still enough of a science geek to be excited by some of the cutting-edge designs and dense urban (what we'd call "smart growth") creations that are springing up.
About 100 or 150 years ago, it was cities such as Chicago and New York that were thrilling people with their building innovations and bold urban planning. Before that, it had been the great cities of Europe. Now, it definitely appears to be China and other Asian nations.
Tuesday, March 28, 2006
Fed is nothing if not consistent
So you've heard: The Federal Reserve upped interest rates by a quarter-point for the 15th consecutive time, to 4.75%. Not unexpected, but apparently not welcome, either, as all 30 DOW components dropped into the red today, according to MarketWatch.
Just so no one's caught unawares, the Fed has apparently signaled that it's not done raising rates.
Just so no one's caught unawares, the Fed has apparently signaled that it's not done raising rates.
More community banks should invest in LIHTCs, says report
Here's something to pass on to your partners:
The Office of the Comptroller of the Currency published yesterday the Spring 2006 edition of the Community Developments e-zine focusing on low-income housing tax credits.
According to the report, housing tax credits are an investment that many banks do not know are available to them.
Read the issue here.
The Office of the Comptroller of the Currency published yesterday the Spring 2006 edition of the Community Developments e-zine focusing on low-income housing tax credits.
According to the report, housing tax credits are an investment that many banks do not know are available to them.
Read the issue here.
Another OIG report on Sec. 8 waiting lists
Hm, don't know if two data points make a trend, but it looks like the HUD Office of Inspector General has developed an interest in Section 8 waiting lists. Today HUD OIG produced a second report critical of the way a housing authority has managed its waiting list. It's the city of Annapolis Section 8 program this time. We noted earlier this month that the Los Angeles Housing Authority was also recently the subject of an audit criticizing waiting list practices.
Nixon Peabody on Sec. 8, prepayment
The law firm of Nixon Peabody has posted the online edition of an email alert it circulated a few days ago on Sec. 8 renewal requirements. It says HUD has been telling Sec. 8 contract administrators to give their tenants notices with invitations for comment when they seek any kind of rent increase, even one that affects only non-subsidized tenants in the same project.
The firm is further warning private housing entities that do business with HUD to be sure and send in paper 2530 forms while they can, if they have not yet registered with HUD's electronic Active Partners Performance System (APPS) to submit their "previous participation" data, which can be voluminous. The last day to use the paper process appears to be April 30 per the Nixon Peabody memo and this HUD memorandum, but maybe better check with your local HUD office.
Most recently from Nixon Peabody, in the firm's free email distribution today, is a success for its own property-owner clients in the long-running subsidized mortgage prepayment litigation of Anaheim Gardens/Algonquin Heights -- which is, as the court puts it, "intertwined" with another celebrated legal tangle, Cienaga Gardens. The opinion itself is available from the U.S. Federal Circuit appeals court here. With this decision the court allowed the property owners' regulatory takings claim to go forward, reversing a dismissal by the lower Court of Federal Claims. The Nixon Peabody release doesn't seem to be posted publicly yet, but it'll probably turn up soon. In a few days, go to the firm's main site, choose "Publications" in the left column, and then choose "Affordable Housing Alert." That's also a way to reach the analyses cited earlier in this post in case the more direct links don't work for you.
The firm is further warning private housing entities that do business with HUD to be sure and send in paper 2530 forms while they can, if they have not yet registered with HUD's electronic Active Partners Performance System (APPS) to submit their "previous participation" data, which can be voluminous. The last day to use the paper process appears to be April 30 per the Nixon Peabody memo and this HUD memorandum, but maybe better check with your local HUD office.
Most recently from Nixon Peabody, in the firm's free email distribution today, is a success for its own property-owner clients in the long-running subsidized mortgage prepayment litigation of Anaheim Gardens/Algonquin Heights -- which is, as the court puts it, "intertwined" with another celebrated legal tangle, Cienaga Gardens. The opinion itself is available from the U.S. Federal Circuit appeals court here. With this decision the court allowed the property owners' regulatory takings claim to go forward, reversing a dismissal by the lower Court of Federal Claims. The Nixon Peabody release doesn't seem to be posted publicly yet, but it'll probably turn up soon. In a few days, go to the firm's main site, choose "Publications" in the left column, and then choose "Affordable Housing Alert." That's also a way to reach the analyses cited earlier in this post in case the more direct links don't work for you.
Monday, March 27, 2006
NLIHC on current budget agonies and more
S'morning's NLIHC Memo to Members reviews the current early-budget-season posturing including a couple more sign-on letters circulating in Congress, (1) asking that the Sec. 8 voucher program not be backhandedly revised in Appropriations but that any proposed changes be brought up properly in House Financial services (143 House signatures so far), and (2) Asking to please have back the Sec. 515 rural housing budget (24 House signatures so far), which the White House budget proposal calls for funding at the level of zilch.
They also note that Secretary Alphonso Jackson will testify alone before House Financial Services on the HUD budget this coming Thursday, and that afternoon the Senate Banking, Housing and Urban Affairs subcommittee on Housing and Transportation has a hearing on McKinney-Vento reauthorization and "consolidation of HUD's homeless programs" with testimony scheduled from Deputy Secretary Roy Bernardi and federal homelessness czar Phil Mangano among others.
Among the further items, NLIHC has prepared a detailed summary on the substance of the March 21 rule for cost comparisons in converting public housing to tenant-based subsidies.
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In other Monday morning madness, there's not much to write home about in today's Federal Register unless you have been awarded part of HUD's $23.7 million in fiscal 2005 Rural Housing and Economic Development grants, in which case congratulations to you.
They also note that Secretary Alphonso Jackson will testify alone before House Financial Services on the HUD budget this coming Thursday, and that afternoon the Senate Banking, Housing and Urban Affairs subcommittee on Housing and Transportation has a hearing on McKinney-Vento reauthorization and "consolidation of HUD's homeless programs" with testimony scheduled from Deputy Secretary Roy Bernardi and federal homelessness czar Phil Mangano among others.
Among the further items, NLIHC has prepared a detailed summary on the substance of the March 21 rule for cost comparisons in converting public housing to tenant-based subsidies.
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In other Monday morning madness, there's not much to write home about in today's Federal Register unless you have been awarded part of HUD's $23.7 million in fiscal 2005 Rural Housing and Economic Development grants, in which case congratulations to you.
Sunday, March 26, 2006
Waiting lists for shelter beds in Fairfax, VA
Sad news from Fairfax, Virginia: the Post reports homelessness is up to an official 2,077 people. We all know means a lot more unofficially, especially since
Speaking of not counting the "precariously housed," the National Policy and Advocacy Council on Homelessness (NPACH) is campaigning to get the Conference of Mayors to endorse expanding the definition of homelessness to include people who double up informally with family or friends rather than sleep outdoors or in formally organized shelters. Some of the case for the change is here.
The Fairfax survey does not count residents whose circumstances place them on the brink of homelessness. The "precariously housed" include families or individuals facing eviction or those who have been taken in by friends or family.The local shelters, once places of last resort, now have waiting lists of their own:
About 60 families are on the waiting list for county shelters, and at one point late last year, 90 families were on the list. Officials say it can take up to four months to find a spot.Yes, families. And, yes, the problem is the shortage of affordable housing.
Speaking of not counting the "precariously housed," the National Policy and Advocacy Council on Homelessness (NPACH) is campaigning to get the Conference of Mayors to endorse expanding the definition of homelessness to include people who double up informally with family or friends rather than sleep outdoors or in formally organized shelters. Some of the case for the change is here.
RHIIPping good reading
The multifamily housing section of HUD's Rental Housing Integrity Improvement Project (RHIIP) recently posted the first online archive of wide-distribution emails from its rapidly improving listserv. This relatively new service -- the opening welcome is dated Jan. 13, 2006 -- began by simply reminding housing managers of lesser-known regulations, in a manner that yr humble blogmother began by taking in vain. However, it has grown steadily in thoughtfulness and depth of interpretation over the past couple of months.
Unfortunately the public archive only seems to have posted the first ten items thus far, so I can't yet provide a public link to the excellent Listserv #13, which arrived by email this past week. The items I've already posted on tenant income verification and tomorrow's big Mark-to-Market conference call are both out of #13, and the issue also provides recaps of some Federal Register publications that we've covered here otherwise. Further items of possible interest to AHF readers include a link to the "Fair Market Rent (FMR) Documentation System," which details how each set of local FMR figures was chosen, and a note of a new HUD-9624 form for multifamily Section 8 contract renewal requests. But if you're managing HUD-subsidized multifamily housing you should really just subscribe to the thing.
In other recent bursts of official helpfulness:
- The administrators of Mark-to-Market -- the Office of Affordable Housing Preservation (OAHP), formerly OMHAR -- have realized that their online resources are somewhat confusing and have helpfully posted a new site map with a topical index of M2M-related Internet sub-pages.
- The IRS is inviting suggestions for its next Guidance Priority List. Your chance to ask the rule writers for explanations. (Year 15 qualified contract rules, anyone?)
Unfortunately the public archive only seems to have posted the first ten items thus far, so I can't yet provide a public link to the excellent Listserv #13, which arrived by email this past week. The items I've already posted on tenant income verification and tomorrow's big Mark-to-Market conference call are both out of #13, and the issue also provides recaps of some Federal Register publications that we've covered here otherwise. Further items of possible interest to AHF readers include a link to the "Fair Market Rent (FMR) Documentation System," which details how each set of local FMR figures was chosen, and a note of a new HUD-9624 form for multifamily Section 8 contract renewal requests. But if you're managing HUD-subsidized multifamily housing you should really just subscribe to the thing.
In other recent bursts of official helpfulness:
- The administrators of Mark-to-Market -- the Office of Affordable Housing Preservation (OAHP), formerly OMHAR -- have realized that their online resources are somewhat confusing and have helpfully posted a new site map with a topical index of M2M-related Internet sub-pages.
- The IRS is inviting suggestions for its next Guidance Priority List. Your chance to ask the rule writers for explanations. (Year 15 qualified contract rules, anyone?)
In CA, home isn't always where the house is
The SF Chron reports today on residents of the San Francisco Bay Area who are putting their retirement savings into rental real estate in lower-priced markets thousands of miles away -- sometimes without even visiting the properties.
Saturday, March 25, 2006
An extraordinary house in Omaha
HUD's PATH partnership is about to start construction on an extraordinarily adaptable "concept home."
No-bidness, redux
Remember when the folks at FEMA were going to reopen those no-bid Katrina recovery contracts? They haven't and quite possibly they won't.
Friday, March 24, 2006
Apollo gets new president
More big changes are happening at Apollo Housing Capital, a low-income housing tax credit syndication firm acquired this year by RBC Capital Markets. In a new move, Sebastian Corradino has been named president of Apollo.
Tom Rini, who had been president and CEO, was expected to stay and help operate Apollo, but those plans have apparently changed. RBC, however, reported that Jack Griffiths remains with the firm in a senior role.
Corradino had been an executive vice president in Apollo's acquisitions group and managed the firm's Washington, D.C., office. Company officials said he is relocating to Apollo's Cleveland headquarters.
Tom Rini, who had been president and CEO, was expected to stay and help operate Apollo, but those plans have apparently changed. RBC, however, reported that Jack Griffiths remains with the firm in a senior role.
Corradino had been an executive vice president in Apollo's acquisitions group and managed the firm's Washington, D.C., office. Company officials said he is relocating to Apollo's Cleveland headquarters.
HUD fleshes out its operating fund rule
Public and Indian Housing Notice 2006-14, posted this morning on HUDCLIPS, explains, among other things, how local public housing authorities (PHAs) can invoke the "stop-loss" provisions in last September's final rule governing distribution of public housing operating funds. PHAs that would lose money under the new distribution formula are allowed to "limit their losses to 5 percent" if they can prove they are already following the "asset management" approach required by Subpart H of the new rules, which begin at 24 CFR 990.255 et seq.
Also today, PIH 2006-15 renews an existing rule on PHAs' duty to submit audit reports to their local HUD offices.
Also today, PIH 2006-15 renews an existing rule on PHAs' duty to submit audit reports to their local HUD offices.
Details for Monday's Mark-to-Market call
The HUD-hosted Mark-to-Market conference call scheduled for Monday, March 27 may be of interest to housing managers who have heard tantalizing hints that the program may not be really, really going to end on September 30. A "Broadcast Details" email distributed yesterday on the OMHAR/OAHP listserv says the agenda will be:
1. Preparations for OAHP Sunset, September 30, 2006The email says the call-in number is 1-866-783-5359, the conference call will be chaired by Acting Deputy Assistant Secretary Theodore Toon, and the confirmation number is 48702192. Call time is 3 p.m. Eastern on Monday. They say they'll accept only the first 200 callers. Alas, they will not be distributing prizes, but getting onto this call might turn out to be a prize in itself. The email adds:
2. Overview of OAHP Production Results to date
3. Review of Proposed Regulations
4. Conclusion, respond to e-mail questions.
Due to the anticipated size of the audience, it will be impracticable to take direct questions during the call. We encourage anyone with specific questions before the meeting to send them to Norman_Dailey@hud.gov or resourcedesk@oahp.net. In addition, during the call we will monitor e-mails to Norman_Dailey@hud.gov and if we get several questions on a topic that we can easily answer, we will respond before the end of the call. Otherwise by April 5, 2006 we will distribute and post answers to non-property specific questions via the OAHP Resource Desk (OAHP.net)
"TASS Will Not Be Authorized to State..."
TASS will in fact be phased out as of September.
To clarify, the ex-Soviet news service is still going strong. So is an astronomy project called The Amateur Sky Survey. So, apparently, is the Tucson Animation Screening Society.
But HUD's Tenant Assessment Subsystem (also abbrevated "TASS"), which verifies tenants' Social Security pension and disability benefit income, is being folded into the new Enterprise Income Verification (EIV) System, which will do everything TASS did to check up on tenants and more. It not only verifies Social Security and SSI income, but also unemployment benefits, reported wages, and employer-reported new hires.
To clarify, the ex-Soviet news service is still going strong. So is an astronomy project called The Amateur Sky Survey. So, apparently, is the Tucson Animation Screening Society.
But HUD's Tenant Assessment Subsystem (also abbrevated "TASS"), which verifies tenants' Social Security pension and disability benefit income, is being folded into the new Enterprise Income Verification (EIV) System, which will do everything TASS did to check up on tenants and more. It not only verifies Social Security and SSI income, but also unemployment benefits, reported wages, and employer-reported new hires.
CDBG urban county procedures posted
Debate simmers away on whether to revise allocation methods for the Community Development Block Grants, but in the meantime the show must go on -- and accordingly HUD has posted Community Planning and Development Notice 2006-2, which explains how counties or parts of counties can apply for urban "entitlement" status affecting CDBG allocations (and other HUD formula grants such as HOME funding) for 2007 through 2009. The notice sets out a strictly defined timetable for the process, with dates beginning April 21, 2006. Lists at the foot of the notice name currently qualified urban counties, and also counties scheduled to qualify or requalify in each of the next three years, plus urban counties with "non-participating communities" that may need to apply for entitlement status.
...All of which may be moot in a couple of years, given current rumblings about replacing case-by-case urban "entitlement" status with a more uniform CDBG allocation method. But for the time being, this notice applies.
...All of which may be moot in a couple of years, given current rumblings about replacing case-by-case urban "entitlement" status with a more uniform CDBG allocation method. But for the time being, this notice applies.
Thursday, March 23, 2006
A second "battle of Canal Street"?
Mike Davis, urban theory radical, writes up New Orleans for The Nation. Yes, Mr. Davis gets too impressed with the echoingly doomy tones of his own voice, but he's also a smart guy. As background or counterweight, whichever you prefer, here are New Orleans publications of the Urban Land Institute, which the Davis article energetically takes in vain.
IRS posts GO Zone rehab credit guidance
The IRS has just posted Notice 2006-38, detailing the availability of increased rehabilitation tax credits for properties in the three hurricane GO Zones. Credits can run as high as 20% of qualified rehabilitation expenditures on ordinary properties or 26% for historic structures.
Also today:
- A FEMA announcement posted today names "alternative arrangements for critical physical infrastructure in New Orleans" under the National Environmental Policy Act. Looks like it's environmental exceptions for jails, schools, and hospitals. Not necessarily for private housing but maybe worth reading for people in the housing industry there.
- The Christian Science Monitor provides a snapshot of struggling home mortgage debtors in Boston.
[MORE: May as well add one more item to the mix here: Louisiana officials are looking urgently to hire disaster recovery block grant administrators.]
Also today:
- A FEMA announcement posted today names "alternative arrangements for critical physical infrastructure in New Orleans" under the National Environmental Policy Act. Looks like it's environmental exceptions for jails, schools, and hospitals. Not necessarily for private housing but maybe worth reading for people in the housing industry there.
- The Christian Science Monitor provides a snapshot of struggling home mortgage debtors in Boston.
[MORE: May as well add one more item to the mix here: Louisiana officials are looking urgently to hire disaster recovery block grant administrators.]
Is there an LIHTC pricing bubble?
David Smith of Recap Advisors (and the Affordable Housing Institute blog, which is always a good read) writes today with colleague Ethan Handelman on the bubble-like "hyperactivity" of LIHTC prices. It's a good read, whether you agree with him or not that HR 4873 is the cure for the condition.
Could housing providers help NOLA vote?
It seems like FEMA and HUD, as the main federal agencies housing hurricane survivors, would be especially well placed to distribute information on voting procedures for the upcoming New Orleans elections. HUD's Secretary has a history of supporting voting rights with great bravery, too. But quick searches on their Web sites just now do not show such an effort. (Anyone who is aware of such an effort, do please advise.)
Some private efforts along such lines do seem to be in place: the NAACP has organized 15 voter assistance centers in cities where large numbers of hurricane survivors are staying, and People for the American Way appears to be reviving its voter rights hotline, 1-866-OUR-VOTE. But is there going to be a systematic publicly sponsored effort to spread the word?
For the time being here's the useful-looking Times-Picayune elections page, the paper's condensed voter information graphic, some limited voter information on the city's Web site, and the Louisiana state government's more polished "Displaced Voter Information" page. It looks like April 18 is the deadline for already-registered New Orleans voters to request an absentee ballot by mail for the upcoming city primary election.
Some private efforts along such lines do seem to be in place: the NAACP has organized 15 voter assistance centers in cities where large numbers of hurricane survivors are staying, and People for the American Way appears to be reviving its voter rights hotline, 1-866-OUR-VOTE. But is there going to be a systematic publicly sponsored effort to spread the word?
For the time being here's the useful-looking Times-Picayune elections page, the paper's condensed voter information graphic, some limited voter information on the city's Web site, and the Louisiana state government's more polished "Displaced Voter Information" page. It looks like April 18 is the deadline for already-registered New Orleans voters to request an absentee ballot by mail for the upcoming city primary election.
Wednesday, March 22, 2006
Some tasty HAC News bits just now
Today's HAC News has one of the Housing Assistance Council's wonderful programs-and-money summary grids, this one pulling together all the recently announced funding availabilities in rural housing. The most original finds, however, are in the undercard of the newsletter. Scroll nearly all the way down for a look at "rural wealth" through property ownership and a related report on rural philanthropy (incredibly aggravating blinking menus in the left sidebar at this site, but you don't have to look at them while the report is downloading). And at the very bottom there's an extremely helpful-looking Know Your Rights flyer on housing law and benefits for hurricane survivors.
CDBG: a refresher
So the Community Development Block Grant (CDBG) program is heading into another budget cycle with the White House proposing to cut it by nearly a billion dollars -- well, less on paper, but it's nearly a billion if the "cut" is considered to include $200 million that would be set aside for an as yet undefined competitive grant program. (For details, start at the foot of p. 541 in the 2007 budget proposal appendix.)
In view of same, should anyone happen to need a refresher on the state of CDBG policy debate, the following series of documents is recommended as a public service: HUD's Feb. 2005 report finding increasing unfairness in the existing allocation formula and recommending a selection of four new formulas... GAO's spring 2005 commentary on the HUD report... the National Academy of Public Administration report from February 2005 report on designing standard CDBG performance measures, the difficulty of which has led to bad evaluations through OMB's PART process... the hearing transcripts from three hearings held by the House Committee on Government Reform's Subcommittee on Federalism and the Census... directions for GPO Access retrieval of the same subcommittee's excellent summary report... and HUD's own CDBG "budget justification" document.
All these documents are large PDF files. If you've only got time for one, read the subcommittee report -- the one you have to dig up at GPO Access. It's worth the dig. It's a concise, well-written 77 pages. Two-thirds of that is devoted to background, including summaries of the 2005 HUD and NAPA reports and of the hearing testimony. The remainder provides recommendations for change. Some strong, surprisingly bipartisan opinions appear in the report, but as Washington documents go, this one distinguishes fact from argument pretty squarely. It's entirely worth a careful read if you work in this area.
In view of same, should anyone happen to need a refresher on the state of CDBG policy debate, the following series of documents is recommended as a public service: HUD's Feb. 2005 report finding increasing unfairness in the existing allocation formula and recommending a selection of four new formulas... GAO's spring 2005 commentary on the HUD report... the National Academy of Public Administration report from February 2005 report on designing standard CDBG performance measures, the difficulty of which has led to bad evaluations through OMB's PART process... the hearing transcripts from three hearings held by the House Committee on Government Reform's Subcommittee on Federalism and the Census... directions for GPO Access retrieval of the same subcommittee's excellent summary report... and HUD's own CDBG "budget justification" document.
All these documents are large PDF files. If you've only got time for one, read the subcommittee report -- the one you have to dig up at GPO Access. It's worth the dig. It's a concise, well-written 77 pages. Two-thirds of that is devoted to background, including summaries of the 2005 HUD and NAPA reports and of the hearing testimony. The remainder provides recommendations for change. Some strong, surprisingly bipartisan opinions appear in the report, but as Washington documents go, this one distinguishes fact from argument pretty squarely. It's entirely worth a careful read if you work in this area.
Tuesday, March 21, 2006
Some new LIHTC allocations in Colorado
Just posted at the Colorado Housing and Finance Authority tax credit page: its first-round 2006 low-income housing credit allocations, reflecting the state's recent decision to reserve tax credits according to three ordinary definable application rounds as opposed to the unique rolling-acceptance system that they tried for several years. This round grants preliminary reservations of $2.85 million to five projects, the largest being Pinon Terrace TBD, a Mercy Housing development in Durango receiving over $1 million in credits.
Chicago reborn
At the Apartment Finance Today's Developer Conference in San Diego recently, Wharton School of Business Professor Peter Linneman said that a lot of old Rust Belt cities were in a long-term decline because their services simply were not high value-add any longer. One exception he mentioned was Chicago, which has made a strong transition from a city of factories to a city of brain work.
The Economist (requires registration) agrees. In its March 18 issue, the newsweekly has a 20-page survey of Chicago that recognizes its successes in transitioning to a new (well, newer) economy and in urban planning. We here at housingfinance.com have long been touting Chicago's work in reengineering its affordable housing environment. But the city also deserves credit for the way it has long been an exciting case study for urban planning. As any Midwesterner knows, the Great Chicago Fire and the Columbian Exposition spurred rebuilding and planning on a scale large enough and successful enough to make urban planners and grand architects like Daniel Burnham household names (at least in geeky households).
So I disagree with the Economist when it says about Chicago that, "in many ways the city is a monument to the creativity of chaos." Nah. It's a monument to urban planning. You may not like all of it, you may get sick of the city's endless street grid, you may correctly point out the awful planning that created the high-rise horrors of the now-demolished housing projects. But you can't say the city doesn't plan.
As a Midwestern partisan -- born and raised in Wisconsin -- I'd add some other cities that likely have strong futures. Minneapolis and Madison, Wisconsin, for two. Care to add any to the list?
The Economist (requires registration) agrees. In its March 18 issue, the newsweekly has a 20-page survey of Chicago that recognizes its successes in transitioning to a new (well, newer) economy and in urban planning. We here at housingfinance.com have long been touting Chicago's work in reengineering its affordable housing environment. But the city also deserves credit for the way it has long been an exciting case study for urban planning. As any Midwesterner knows, the Great Chicago Fire and the Columbian Exposition spurred rebuilding and planning on a scale large enough and successful enough to make urban planners and grand architects like Daniel Burnham household names (at least in geeky households).
So I disagree with the Economist when it says about Chicago that, "in many ways the city is a monument to the creativity of chaos." Nah. It's a monument to urban planning. You may not like all of it, you may get sick of the city's endless street grid, you may correctly point out the awful planning that created the high-rise horrors of the now-demolished housing projects. But you can't say the city doesn't plan.
As a Midwestern partisan -- born and raised in Wisconsin -- I'd add some other cities that likely have strong futures. Minneapolis and Madison, Wisconsin, for two. Care to add any to the list?
Yet another OIG iffy-mortgage audit
Today, another screamingly unfavorable audit by the HUD Office of Inspector General on another lender -- this time it's Huntington National Bank -- accused of carelessness or worse in giving assurances that requirements for HUD mortgage insurance were met on some home loans that in fact had already become doubtful risks.
Scary stuff, this. The way I see it, the FHA mortgage insurance program is already at risk from struggling borrowers who can barely pay their debts, yet our housing officials continue to market new home mortgage debt to low-paid renters who work two and three jobs to break even, with the fiction that it can make them members of an "ownership society." Ownership? Yeoman self-sufficiency? Control over their destinies? Well, wouldn't it be pretty to think so. The bank owns the house, not the borrower. The mortgage becomes a yoke. These just-barely-floating mortgage borrowers -- the late entries at the foot of the housing market pyramid -- could easily lose everything in a foreclosure. And thanks to the new personal bankruptcy restrictions, subjects of foreclosure may have trouble ever making a fresh start again in this life.
Well, at least in the meantime they won't owe their homes to rent subsidies administered by a Democratic urban mayor.
Scary stuff, this. The way I see it, the FHA mortgage insurance program is already at risk from struggling borrowers who can barely pay their debts, yet our housing officials continue to market new home mortgage debt to low-paid renters who work two and three jobs to break even, with the fiction that it can make them members of an "ownership society." Ownership? Yeoman self-sufficiency? Control over their destinies? Well, wouldn't it be pretty to think so. The bank owns the house, not the borrower. The mortgage becomes a yoke. These just-barely-floating mortgage borrowers -- the late entries at the foot of the housing market pyramid -- could easily lose everything in a foreclosure. And thanks to the new personal bankruptcy restrictions, subjects of foreclosure may have trouble ever making a fresh start again in this life.
Well, at least in the meantime they won't owe their homes to rent subsidies administered by a Democratic urban mayor.
New rules up for public housing conversion
The HUD final rule is out today on procedures to be followed in both "required and voluntary conversion of public housing developments to tenant-based assistance." Another step into privatization accomplished.
Also today, HUD has awarded $41.7 million in HUD housing counseling grants, and the Mississippi Band of Choctaw Indians have a new loan fund of just under a million dollars from a Rural Housing demonstration program.
Also today, HUD has awarded $41.7 million in HUD housing counseling grants, and the Mississippi Band of Choctaw Indians have a new loan fund of just under a million dollars from a Rural Housing demonstration program.
Monday, March 20, 2006
A personal portrait of the Secretary
Skip the first three paragraphs but read the rest of this Washington Post profile on HUD Secretary Alphonso Jackson. Some of what makes him tick, some of what ticks him off, and some of what moves him to tears. Including the story of the honorably acquired scar on his left leg -- a story that has rarely been told in print since his Dallas days.
GO Zone LIHTC population data posted
Well, I don't know what's up with the IRS "Advance Notice" page, but last week's Notice 06-22 on overall official populations is still not posted, and currently only Novogradac has Notice 06-21 for the GO Zone portion of the hurricane-affected Gulf Coast states. Odd that neither of these notices have been officially posted for the general public. At this point maybe better just watch the Internal Revenue Bulletin for the official final versions.
Tough CDBG talk in Appropriations hearing
Today's NLIHC Memo to Members leads with the Senate '07 budget resolution, which has already begun to inch Community Development Block Grant (CDBG) and home energy assistance funding back upward from the deeply cut levels in the White House budget proposal. Next, and juicier, is a description of Secretary Jackson's March 14, 2006 exchanges with members of the House Appropriations Subcommittee on Transportation and Housing and Urban Development (the acronym is "THUD," isn't it?). Sounds like he was pressed to promise stricter accountability for spending but also questioned closely about the justifications for the proposed CDBG cuts -- which, depending how you count, would be just over or just under $1 billion, but anyway deep enough to cause major changes in municipal budgets.
Incidentally, if anyone has access to a tape, transcript, or prepared statements from the March 14 hearing, could you let us know? At present I'm not seeing any of these on the House site or the HUD testimony index. Any help here much appreciated.
Incidentally, if anyone has access to a tape, transcript, or prepared statements from the March 14 hearing, could you let us know? At present I'm not seeing any of these on the House site or the HUD testimony index. Any help here much appreciated.
It's a big day for rural housing
As of today there's a new USDA demonstration housing voucher program under Sec. 542 specifically for rescuing tenants whose landlords choose to prepay their subsidized rural housing mortgages under Sec. 515. Up to $16 million, to be administered by HUD. It's not quite clear, however, how ex-515 tenants are supposed to learn of the possibility. Looks like maybe their local housing authorities just have to be paying attention.
Further NOFAs are posted today for almost $1 billion in rural housing loans and grants, the largest chunk of that being Sec. 521 rental assistance and advances under Sec. 502(c)(5)(C). The main announcement here is followed by specifics on 514/516 farm laborers' housing... the Sec. 515 revolving loan fund demonstration project... the deeply important Sec. 515 rural housing financing in the amount of $99 million, of which just $25.74 million is for new construction... and not quite $10.5 million in Sec. 533 housing preservation funds.
[UPDATE: Here's the Housing Assistance Council rundown on all of the above.]
Further NOFAs are posted today for almost $1 billion in rural housing loans and grants, the largest chunk of that being Sec. 521 rental assistance and advances under Sec. 502(c)(5)(C). The main announcement here is followed by specifics on 514/516 farm laborers' housing... the Sec. 515 revolving loan fund demonstration project... the deeply important Sec. 515 rural housing financing in the amount of $99 million, of which just $25.74 million is for new construction... and not quite $10.5 million in Sec. 533 housing preservation funds.
[UPDATE: Here's the Housing Assistance Council rundown on all of the above.]
Sunday, March 19, 2006
The smallest, coolest apartments
The website "apartment therapy" and the retailer Design Within Reach are now choosing the winners in their 2nd annual Smallest, Coolest Apartment Contest 2006. The contest picks the four best decorated and designed small apartments and homes in the lower 48 states under 650 square feet -- the contenders are now posted online, with pictures.
But the best part of the contest is the growing chain of intelligent and often hilarious critiques that are posted after every entry by visitors to the website.
If you have a model apartment to decorate and you want to know what the kids are thinking, this an obvious place to start.
Also, if you have any doubts the small studios can work in some markets, this is also a good site to visit. "We've never accepted that a lack of space is fatal when it comes to creating an inspiring home," according to the contest organizers.
But the best part of the contest is the growing chain of intelligent and often hilarious critiques that are posted after every entry by visitors to the website.
If you have a model apartment to decorate and you want to know what the kids are thinking, this an obvious place to start.
Also, if you have any doubts the small studios can work in some markets, this is also a good site to visit. "We've never accepted that a lack of space is fatal when it comes to creating an inspiring home," according to the contest organizers.
All the refried housing news you can eat
Been cleaning out the mailbox today. Lots of policy and grant information, a few loud budget complaints, and fourth-quarter HUD data on the housing market. Among other things...
- NH&RA notes the introduction of S. 2366, companion bill to last year's HR 1468, to repeal the surety bond requirements for LIHTC property interests sold inside the 15-year limit.
- Novogradac links to this past week's House Ways and Means subcommittee hearing on "tax-preferred bond financing." Archive page available here. Many witnesses' prepared statements are posted, though no transcript as yet.
- NAHRO has posted a survey of projected local effects of the fiscal 2006 decreases in Community Development Block Grant funding, with a look ahead to the fight over proposed further CDBG reductions for fiscal 2007.
- HUD has posted extensive reports on fourth-quarter U.S. housing market conditions.
- The Texas Congressional delegation is trying to get more federal hurricane money... Gov. Barbour of Mississippi is refusing to allow Internet posting of information on grants to individual homeowners for hurricane recovery...
- The winter edition of the HAC newsletter, "Rural Voices," includes both commentary on current Katrina/Rita policy and examples from past disaster recovery projects.
- HAC is inviting registrations -- limited enrollment, applications accepted this Friday at the latest -- for a March 30 online conference offering guidance on applying for HUD Rural Housing and Economic Development funding in 2006.
A note to non-techie readers about that last item: don't be scared by the idea of an "online conference." If your computer was bought in the last two or three years, it will probably run RealPlayer video software, which you can download in the free "Basic" version as explained in the HAC flyer. The same software is used for HUD webcasts, for video archives of Congressional hearings, and for live C-Span broadcasts of House or Senate debate. RealPlayer is a little nosy about registration information, and the RealNetworks company has in the past been sued over privacy issues -- but most people find their own disclosures are a fair price to pay for the live access RealPlayer offers.
- NH&RA notes the introduction of S. 2366, companion bill to last year's HR 1468, to repeal the surety bond requirements for LIHTC property interests sold inside the 15-year limit.
- Novogradac links to this past week's House Ways and Means subcommittee hearing on "tax-preferred bond financing." Archive page available here. Many witnesses' prepared statements are posted, though no transcript as yet.
- NAHRO has posted a survey of projected local effects of the fiscal 2006 decreases in Community Development Block Grant funding, with a look ahead to the fight over proposed further CDBG reductions for fiscal 2007.
- HUD has posted extensive reports on fourth-quarter U.S. housing market conditions.
- The Texas Congressional delegation is trying to get more federal hurricane money... Gov. Barbour of Mississippi is refusing to allow Internet posting of information on grants to individual homeowners for hurricane recovery...
- The winter edition of the HAC newsletter, "Rural Voices," includes both commentary on current Katrina/Rita policy and examples from past disaster recovery projects.
- HAC is inviting registrations -- limited enrollment, applications accepted this Friday at the latest -- for a March 30 online conference offering guidance on applying for HUD Rural Housing and Economic Development funding in 2006.
A note to non-techie readers about that last item: don't be scared by the idea of an "online conference." If your computer was bought in the last two or three years, it will probably run RealPlayer video software, which you can download in the free "Basic" version as explained in the HAC flyer. The same software is used for HUD webcasts, for video archives of Congressional hearings, and for live C-Span broadcasts of House or Senate debate. RealPlayer is a little nosy about registration information, and the RealNetworks company has in the past been sued over privacy issues -- but most people find their own disclosures are a fair price to pay for the live access RealPlayer offers.
Friday, March 17, 2006
Further Friday reading
- HUD has issued PIH 2006-13 on disability access in federally funded housing.
- Texas reverse mortgage borrowers using federally insured Home Equity Conversion Mortgages are permitted as of this week to take out lines of credit on their home equity -- a change made possible by a Texas initiative petition that passed on the state ballot in November 2005.
- GAO looks at federal management of private contractors for Katrina and Rita recovery.
- Texas reverse mortgage borrowers using federally insured Home Equity Conversion Mortgages are permitted as of this week to take out lines of credit on their home equity -- a change made possible by a Texas initiative petition that passed on the state ballot in November 2005.
- GAO looks at federal management of private contractors for Katrina and Rita recovery.
Average prices posted for MRB issuers
IRS Revenue Procedure 2006-17, just posted today, lists average national purchase prices and average purchase price safe harbors for use in capping the prices of homes bought with mortgage revenue bonds or mortgage credit certificates.
Thursday, March 16, 2006
Thurs. mix: Sec. 515 NOFA and more
- Here's the NOFA requesting applications for the Sec. 515 Multi-Family Housing Preservation and Revitalization Restructuring Demonstration Program for fiscal 2006. Not quite $174 million available, most of it loans, not grants, and there's a tight application deadline of April 17.
- The EPA would like any advice you care to offer on developing test kits to check when people working on old buildings should take lead paint precautions.
- Want to take part in a Commerce Department "Business Investment Mission" to hear about available investments in the Gulf Coast (yes, of the United States)? The said Mission is May 4-5, and to join the delegation you file an application by April 11, 2006. To get in, it looks like you'd better have at least $5 million either already invested there or ready to invest there. It's not clear what other qualifications they consider, nor how many spaces are available. Doesn't seem to be anything like a civil service exam involved.
- For persons not possessed of $5 million to invest in the Gulf Coast (or anywhere else), the National Low Income Housing Coalition has written up detailed policy recommendations for the hurricane recovery supplemental appropriation.
- The EPA would like any advice you care to offer on developing test kits to check when people working on old buildings should take lead paint precautions.
- Want to take part in a Commerce Department "Business Investment Mission" to hear about available investments in the Gulf Coast (yes, of the United States)? The said Mission is May 4-5, and to join the delegation you file an application by April 11, 2006. To get in, it looks like you'd better have at least $5 million either already invested there or ready to invest there. It's not clear what other qualifications they consider, nor how many spaces are available. Doesn't seem to be anything like a civil service exam involved.
- For persons not possessed of $5 million to invest in the Gulf Coast (or anywhere else), the National Low Income Housing Coalition has written up detailed policy recommendations for the hurricane recovery supplemental appropriation.
Wednesday, March 15, 2006
Mark-to-Market conference call coming up
HUD's Office of Affordable Housing Preservation (formerly OMHAR) circulated a few explanatory comments this morning on yesterday's publication of proposed new Mark-to-Market regulations. The comments, delivered via OAHP's email list, say that "Although the proposed rule makes a number of changes to the Mark- to-Market program regulations, a vast majority of these changes have been operational since enactment of the Mark-to-Market Extension Act of 2001." However, they've scheduled a conference call "to provide some background" on the new language. It's to be Monday, Mar. 27, at 3 p.m. Eastern time, with "call-in information and additional details" to be released the previous Thursday, March 23. Questions in the meantime can be sent to Norman_Dailey@hud.gov or resourcedesk@oahp.net. Questions sent to the "Norman Dailey" address during the call will be answered live if possible, or otherwise it says "non-property specific" questions will be answered at OAHP.net by April 5, 2006. Looks like this latter address requires registration but it says "Registration is free and open to all users."
Flood insurance drowning in red ink?
Well, the big housing-related news in today's hearing on "high-risk" federal programs is that the federal flood insurance program has been added to the list. Maybe a bit late.
Not so much about HUD in the prepared testimony for the hearing. OMB deputy director Clay Johnson III only praises HUD for "reducing improper payments by more than $1.8 billion since 2000" in public housing. A statement in report form by GAO chief David Walker mentions HUD by name only in stating that HUD's single-family mortgage insurance and rental housing assistance programs have been on GAO's "high-risk" list since 1994 -- not the longest, but still quite a while.
Walker's testimony may be more interesting for its detailed discussion of the National Flood Insurance Program (NFIP). Among other things, his report says "It is highly unlikely that the NFIP will generate sufficient revenues to repay funds borrowed from the Treasury to cover claims for the unprecedented magnitude and severity of flood losses resulting from hurricanes in 2005, as well as any exposure for future claims coverage in catastrophic loss years..." A graph on Page 10 of his document says claims based on the 2005 hurricane season are likely to run as high as $23 billion -- half again as much as the entire $15 billion the program paid out "from its inception in 1968 until August 2005." Gulp.
If you're really interested it may be worth returning to the link at the top of this item in a day or two for the archived video of the actual hearing, usually available for viewing or listening in RealPlayer.
Not so much about HUD in the prepared testimony for the hearing. OMB deputy director Clay Johnson III only praises HUD for "reducing improper payments by more than $1.8 billion since 2000" in public housing. A statement in report form by GAO chief David Walker mentions HUD by name only in stating that HUD's single-family mortgage insurance and rental housing assistance programs have been on GAO's "high-risk" list since 1994 -- not the longest, but still quite a while.
Walker's testimony may be more interesting for its detailed discussion of the National Flood Insurance Program (NFIP). Among other things, his report says "It is highly unlikely that the NFIP will generate sufficient revenues to repay funds borrowed from the Treasury to cover claims for the unprecedented magnitude and severity of flood losses resulting from hurricanes in 2005, as well as any exposure for future claims coverage in catastrophic loss years..." A graph on Page 10 of his document says claims based on the 2005 hurricane season are likely to run as high as $23 billion -- half again as much as the entire $15 billion the program paid out "from its inception in 1968 until August 2005." Gulp.
If you're really interested it may be worth returning to the link at the top of this item in a day or two for the archived video of the actual hearing, usually available for viewing or listening in RealPlayer.
Wed. mix: the Sec. 8 crunch, CoC, forms
- The Center on Budget and Policy Priorities has posted a free detailed report on the cuts likely to be forced in many local housing authorities' housing voucher programs if the White House budget proposal for Sec. 8 goes through.
- HUDCLIPS has posted new editions of the application forms for HUD homeless programs and the Continuum of Care program, both with extensive substantive instructions. Very much worth a look, not only for applicants, but for anyone who takes an interest in the guts of these programs and may have wondered about some of the rules and definitions.
- Also among recently posted forms: the HUD survey instructions for insured multifamily projects (related separate form here)... and the HUD Sec. 8 multifamily contract renewal request form (MS Word version here).
- USDA has $990,000 available in grants for rural household water wells and $495,000 in grants for rural nonprofit revolving loan funds.
- Federal contractors in Katrina-affected areas are affected by HUD's Office of Labor Relations Notice SL-2006-01 clarifying which contracts are covered by the President's Sep. 8 - Nov. 7 suspension of Davis-Bacon Act prevailing wage standards.
- HUDCLIPS has posted new editions of the application forms for HUD homeless programs and the Continuum of Care program, both with extensive substantive instructions. Very much worth a look, not only for applicants, but for anyone who takes an interest in the guts of these programs and may have wondered about some of the rules and definitions.
- Also among recently posted forms: the HUD survey instructions for insured multifamily projects (related separate form here)... and the HUD Sec. 8 multifamily contract renewal request form (MS Word version here).
- USDA has $990,000 available in grants for rural household water wells and $495,000 in grants for rural nonprofit revolving loan funds.
- Federal contractors in Katrina-affected areas are affected by HUD's Office of Labor Relations Notice SL-2006-01 clarifying which contracts are covered by the President's Sep. 8 - Nov. 7 suspension of Davis-Bacon Act prevailing wage standards.
Tuesday, March 14, 2006
A Mark-to-Market proposed rule and more
- HUD has posted a proposed rule to revise the Mark-to-Market regulations. Comments due in two months, on May 15, 2006. Watch this space for further discussion thereof.
- FEMA apparently fears its trailer parks might get too comfortable.
- Craigslist is being sued for allowing allegedly discriminatory housing listings. The Chicago Lawyers' Committee for Civil Rights Under Law is representing the plaintiffs and has posted their press release and complaint and an FAQ on their side of the issues. See also the Lawyers' Committee Web site and click on the "Fair Housing Project" link. According to the plaintiffs, some postings were as blatant as "no minorities" or "Requirements: Clean Godly Christian Male." But the response from Craigslist says the plaintiffs are "ignoring the fact that craigslist is not a publisher, but rather a community-moderated commons run by and for its users, who self-publish and manage their own ads and use a flagging system to police the site." It also questions whether some of the more ambiguously phrased ads in the complaint, e.g. "near St Gertrude's church," were in fact discriminatory.
- Forgot to mention there's new census data on Americans over 65.
- Tomorrow there's a hearing on "High-Risk Programs", including HUD, featuring top GAO and OMB witnesses before the Senate Committee on Homeland Security and Govermental Affairs. Better start making the popcorn.
- FEMA apparently fears its trailer parks might get too comfortable.
- Craigslist is being sued for allowing allegedly discriminatory housing listings. The Chicago Lawyers' Committee for Civil Rights Under Law is representing the plaintiffs and has posted their press release and complaint and an FAQ on their side of the issues. See also the Lawyers' Committee Web site and click on the "Fair Housing Project" link. According to the plaintiffs, some postings were as blatant as "no minorities" or "Requirements: Clean Godly Christian Male." But the response from Craigslist says the plaintiffs are "ignoring the fact that craigslist is not a publisher, but rather a community-moderated commons run by and for its users, who self-publish and manage their own ads and use a flagging system to police the site." It also questions whether some of the more ambiguously phrased ads in the complaint, e.g. "near St Gertrude's church," were in fact discriminatory.
- Forgot to mention there's new census data on Americans over 65.
- Tomorrow there's a hearing on "High-Risk Programs", including HUD, featuring top GAO and OMB witnesses before the Senate Committee on Homeland Security and Govermental Affairs. Better start making the popcorn.
HUD Tease
The Mark-to-Market program might not end on September 30, according to officers from the Department of Housing and Urban Development (HUD) speaking at the annual meeting of the National Affordable Housing Management Association (NAHMA) held here March 5 through 7.
Housing advocates have been pushing for an extension to the program, which has helped to preserve thousands of units of aging affordable housing.
The program was initially created to lower the project-based contract rents at older subsidized projects where the rents were above market rates. “Mark-to-Market saved money,” said Ted Toon, Associate Deputy Assistant Secretary for Affordable Housing Preservation. “If there is another life to this program, it is largely going to be because to that result.”
In the meantime, the program is still officially scheduled to end Sept. 30. Developers hoping to use the program should get started.
HUD also plans issue the rules governing several Congressional initiatives in the next few weeks. For example, Congress recently passed a law that college students with wealthy parents can not take advantage of their temporary poverty to qualify for Sec. 8 vouchers. Congress also passed legislation that will give housing authorities the ability to reassign the project-based Sec. 8 contract from foreclosed projects to new projects.
Housing advocates have been pushing for an extension to the program, which has helped to preserve thousands of units of aging affordable housing.
The program was initially created to lower the project-based contract rents at older subsidized projects where the rents were above market rates. “Mark-to-Market saved money,” said Ted Toon, Associate Deputy Assistant Secretary for Affordable Housing Preservation. “If there is another life to this program, it is largely going to be because to that result.”
In the meantime, the program is still officially scheduled to end Sept. 30. Developers hoping to use the program should get started.
HUD also plans issue the rules governing several Congressional initiatives in the next few weeks. For example, Congress recently passed a law that college students with wealthy parents can not take advantage of their temporary poverty to qualify for Sec. 8 vouchers. Congress also passed legislation that will give housing authorities the ability to reassign the project-based Sec. 8 contract from foreclosed projects to new projects.
SuperNOFA webcast running, um, right now
Sorry not to mention this one sooner. The webcast on the SuperNOFA is running here, and it will be archived at the same site for viewing later via the free "Basic" version of RealPlayer. By the way, a troubleshooting side page notes that even if you use a Windows system you still need RealPlayer to view the webcasts.
'Naive money' surprises MIPIM
As we've reported for a while in Apartment Finance Today's capital markets coverage, "naive" -- just don't call it "stupid" -- money has been distorting certain property markets for some time, primarily the overheated condo market in some cities. But a report in the Financial Times (requires registration, sorry) says that the European commercial property markets are being flooded with this not-so-intelligent money from investors hoping to get in on the boom. "[T]he public, for whom commercial property was once as alluring as halitosis, cannot get enough of it as an asset class."
That's from the FT's report from MIPIM, which is the French acronym for Marche International SomethingSomethingSomething (I don't know; it's in French). Helping things along with this popularizing of commercial real estate will be the expected creation of real estate investment trusts (REITs) in Germany and the U.K. FT reports that it's currently office, retail and industrial that is attracting this money, but I think one of the places to watch is Germany, where massive housing estates with hundreds of thousands of units are in the process of being sold off by their corporate owners looking for cash to expand their non-real estate businesses.
That's from the FT's report from MIPIM, which is the French acronym for Marche International SomethingSomethingSomething (I don't know; it's in French). Helping things along with this popularizing of commercial real estate will be the expected creation of real estate investment trusts (REITs) in Germany and the U.K. FT reports that it's currently office, retail and industrial that is attracting this money, but I think one of the places to watch is Germany, where massive housing estates with hundreds of thousands of units are in the process of being sold off by their corporate owners looking for cash to expand their non-real estate businesses.
Monday, March 13, 2006
New interim housing director in Oregon
In the latest of several personnel changes at Oregon Housing and Community Services, Rick Crager, the former CFO, has been appointed acting director. Crager is a lifelong Oregonian with a long background in state agency accounting and financial administration work. Today he introduced himself in a letter circulated to OHCS' "E-News" list, asking for public input in the currently pending state budget process and setting out the following additional priorities:
"- Protection of manufactured dwelling park residents through financing of homeowner purchasing and other means to ensure stability for these individuals.
- Implementation of the upcoming Governor’s executive order acknowledging the state’s homelessness problem and establishing OHCS as the lead for this issue.
- Addressing the inequitable impact of Oregon’s prevailing wage law on affordable housing developers.
- Preservation of Section 8 housing inventory which serves the most needy Oregonians.
- Reestablishing the funding cycle for the Small Community Incentive Fund."
Monday mix: debenture rates, budget, etc.
- The main effective interest rate on HUD debentures has risen from 4-1/2% back to 4-7/8% for the six months that began Jan. 1 2006. The rate for 221(g)(4) debentures is 5-1/8%.
- The NLIHC Memo to Members has updates on the start of fiscal '07 budget season, the latest hurricane recovery hearings, news of a letter signed by 177 members of the House seeking to preserve CDBG funding, and a look at newly introduced HR 4873. This last bill would actually allow low-income housing tax credits to serve lower-income tenants but it would change the program's name to "Affordable Housing Tax Credit," NLIHC says, "in order to gain additional public acceptance of the program and to help combat NIMBYism. "
- Better late than never, here's a pocketful of automatic and available waivers for HUD programs under the Public and Indian Housing office in areas affected by Hurricane Wilma. Local authorities can request waivers using the checklists already established for Hurricanes Katrina and Rita but they must be sent to a new email address, Pih_Wilmadisaster_Relief@hud.gov . See HUD's PIH page for more details.
- Texas housing officials have posted a Multifamily Housing Needs Assessment for the Houston area that takes into account needs created by Hurricanes Katrina and Rita. They've also posted 2006 deadlines for the Texas multifamily bond program.
- David Smith looks at the slow financial strangulation of the New York City Housing Authority.
- The NLIHC Memo to Members has updates on the start of fiscal '07 budget season, the latest hurricane recovery hearings, news of a letter signed by 177 members of the House seeking to preserve CDBG funding, and a look at newly introduced HR 4873. This last bill would actually allow low-income housing tax credits to serve lower-income tenants but it would change the program's name to "Affordable Housing Tax Credit," NLIHC says, "in order to gain additional public acceptance of the program and to help combat NIMBYism. "
- Better late than never, here's a pocketful of automatic and available waivers for HUD programs under the Public and Indian Housing office in areas affected by Hurricane Wilma. Local authorities can request waivers using the checklists already established for Hurricanes Katrina and Rita but they must be sent to a new email address, Pih_Wilmadisaster_Relief@hud.gov . See HUD's PIH page for more details.
- Texas housing officials have posted a Multifamily Housing Needs Assessment for the Houston area that takes into account needs created by Hurricanes Katrina and Rita. They've also posted 2006 deadlines for the Texas multifamily bond program.
- David Smith looks at the slow financial strangulation of the New York City Housing Authority.
USDA housing relief, but not for renters
USDA has a notice out today implementing Congress' special appropriation of grants and loans for hurricane recovery through the Rural Housing Service, Rural Business-Cooperative Service, and Rural Utilities Service. It looks pretty much like assistance for infrastructure and single-family owner-occupied housing. If there's anything for rural rentals it's not spelled out in so many words.
The funds available include almost $1.3 billion in Sec. 502 homeownership guarantees, almost $176 million in Sec. 502 direct homeownership funding, $34 million in Sec. 504 repair/rehabilitation loans, and $20 million in Sec. 504 repair/rehabilitation grants. The usual 62+ age restriction for Sec. 504 is lifted only for the $20 million in grants.
The notice says USDA will not exercise a special power it was given to waive the usual matching requirements for nonprofit grants, because the power lasts for only six months from the enactment of the law and the grants will not be announced until that period is over. However, "Should the authority to waive the matching funds requirement be extended, USDA Rural Development will contemplate reducing the matching funds requirement for successful applicants located in the designated disaster areas, as long as the proposed projects would still be viable with the reduced matching funds requirement."
The funds available include almost $1.3 billion in Sec. 502 homeownership guarantees, almost $176 million in Sec. 502 direct homeownership funding, $34 million in Sec. 504 repair/rehabilitation loans, and $20 million in Sec. 504 repair/rehabilitation grants. The usual 62+ age restriction for Sec. 504 is lifted only for the $20 million in grants.
The notice says USDA will not exercise a special power it was given to waive the usual matching requirements for nonprofit grants, because the power lasts for only six months from the enactment of the law and the grants will not be announced until that period is over. However, "Should the authority to waive the matching funds requirement be extended, USDA Rural Development will contemplate reducing the matching funds requirement for successful applicants located in the designated disaster areas, as long as the proposed projects would still be viable with the reduced matching funds requirement."
IRS posts official state population data
The folks at Novogradac have posted an advance copy of IRS Notice 2006-22, which as of today states the official population figures that will be used in combination with Revenue Procedure 2005-70 to calculate the states' 2006 volumes of low-income housing tax credits and private activity bond cap. The official Advance Notice copy of the IRS document is not yet posted online but it will probably appear at this link shortly.
The high cost of parking
One of the most provocative talks at the recent California Redevelopment Association conference centered on the usually humdrum topic of parking.
Donald Shoup, an urban planning professor at the University of California at Los Angeles, pointed out at the cost of free parking is free only to motorists. For cities and everyone else, it’s very expensive.
The author of The High Cost of Free Parking, Shoup outlined three reforms in parking policy. He said cities need to charge the right price for curb parking, they need to return the parking meter revenue to the neighborhoods that generate it, and cities should not require additional parking when a building’s use changes.
Many cities have stringent parking requirements, which have resulted in vast asphalt deserts. These lots are not most people's idea of good land use, but Shoup pointed out one possible upside to these parking lots. By accident, they are potential land banks for affordable housing, he said. Shoup showed a photo of a Silicon Valley office complex and its massive parking lot. Affordable housing could be built on the edges of the lot, he said, noting that it would increase the housing supply and reduce commute time.
Donald Shoup, an urban planning professor at the University of California at Los Angeles, pointed out at the cost of free parking is free only to motorists. For cities and everyone else, it’s very expensive.
The author of The High Cost of Free Parking, Shoup outlined three reforms in parking policy. He said cities need to charge the right price for curb parking, they need to return the parking meter revenue to the neighborhoods that generate it, and cities should not require additional parking when a building’s use changes.
Many cities have stringent parking requirements, which have resulted in vast asphalt deserts. These lots are not most people's idea of good land use, but Shoup pointed out one possible upside to these parking lots. By accident, they are potential land banks for affordable housing, he said. Shoup showed a photo of a Silicon Valley office complex and its massive parking lot. Affordable housing could be built on the edges of the lot, he said, noting that it would increase the housing supply and reduce commute time.
Sunday, March 12, 2006
"He has never been convicted of a crime..."
The Cleveland Plain Dealer introduces Frank Chapman II, who may or may not be about to receive a large HUD real estate contract.
2005 filers to get $600M of Katrina NMTCs
The Community Development Financial Institutions (CDFI) Fund announced on Friday that it will award $600 million of the $1 billion in special hurricane relief New Markets Tax Credits (NMTC) on the basis of applications already filed. The credits are available only to Community Development Entities (CDEs) that have "a significant mission of recovery and redevelopment of" the Hurricane Katrina Gulf Opportunity Zone (GO Zone). The official deadline for the most recent NMTC application round was Sep. 21, 2005 but CDEs in the hurricane regions were allowed to file as late as Dec. 12, 2005. See the CDFI Fund site for more information, including details of the eligible area. The initial $600 million in credits consists of $300 million that Congress designated for allocation in calendar 2005, plus $300 million designated for allocation in calendar 2006. A CDFI Fund press release says the last $400 million will be available for the same area based on an application process to be announced in summer 2006 for the 2007 calendar year.
Meet HUD's chief data wrangler
Worth a read for HUD-watchers: this FCW profile of HUD's Chief Information Officer, Lisa Schlosser. It says that in just one year on the job she has gotten a solid start on the unenviable task of modernizing the agency's computer systems and data handling. The article doesn't mention that she must have had to define a new position for the HUD CIO during the past year, since the CIO role was only recently separated from the role of the Assistant Secretary for Administration. The previous assistant secretary for Admin., Vickers B. Meadows, held both titles. Schlosser, however, reports to Deputy Secretary Roy Bernardi rather than the current Assistant Secretary for Administration, Keith Nelson.
Saturday, March 11, 2006
HUD is high up on "faith-based" funding list
A ten-page White House statement says HUD awarded 24% of its available "federal competitive funding" to "faith-based organizations" in fiscal 2005 -- the highest such percentage for any agency whose religious grants and other funding are described in the report. The dollar amount named, however, is not the highest: it says religious groups got just under $521 million from HUD, compared with $591 million from USAID and almost $781 million from the Dept. of Health and Human Services.
It's not fully clear, however, just how much of the overall faith-based funding is described by these figures. The statement names the whole amount of funding to such groups as $2.15 billion, but at the same time it cautions prominently that "These results do not reflect the full extent of Federal funding awarded to faith-based organizations." Footnotes and endnotes in the statement say the figures are based only on "competitively awarded funding" and are incomplete for other reasons. The endnotes explain among other things that some groups with religious affiliations said they did not consider themselves "faith-based" and hence were left out of the computations.
If formula grants -- as opposed to "competitive" funding awards -- were not counted, that would make the figures substantially incomplete. It would mean they left out all the formula-allocated Community Development Block Grant money and also, for example, the formula-based Emergency Shelter Grants, even though many religious groups do run shelters. (McKinney-Vento grants are made competitively for housing but by formula for the ESGs.)
And it really is looking like formula grants were left out, based on the way Page 9 of the White House statement discusses the Housing Opportunities for Persons with AIDS (HOPWA) program in a small list of "Some Programs Where Faith-Based Organizations Fare Poorly." The "total" of HOPWA funding is given as $22.5 million, so that certainly looks like it's referring to the small competitive part of the HOPWA program, since HOPWA distributes mainly formula-based funding, and the total formula HOPWA awards made Dec. 8, 2004 for fiscal 2005 added up to more than $251 million. Except then there's a further footnote saying "Note: all figures exclude continuation awards," so we may have a case of apples and oranges here.
Maybe better just conclude that persons professing faith in a higher power have been receiving substantial earthly funding, amounts not yet entirely clear.
It's not fully clear, however, just how much of the overall faith-based funding is described by these figures. The statement names the whole amount of funding to such groups as $2.15 billion, but at the same time it cautions prominently that "These results do not reflect the full extent of Federal funding awarded to faith-based organizations." Footnotes and endnotes in the statement say the figures are based only on "competitively awarded funding" and are incomplete for other reasons. The endnotes explain among other things that some groups with religious affiliations said they did not consider themselves "faith-based" and hence were left out of the computations.
If formula grants -- as opposed to "competitive" funding awards -- were not counted, that would make the figures substantially incomplete. It would mean they left out all the formula-allocated Community Development Block Grant money and also, for example, the formula-based Emergency Shelter Grants, even though many religious groups do run shelters. (McKinney-Vento grants are made competitively for housing but by formula for the ESGs.)
And it really is looking like formula grants were left out, based on the way Page 9 of the White House statement discusses the Housing Opportunities for Persons with AIDS (HOPWA) program in a small list of "Some Programs Where Faith-Based Organizations Fare Poorly." The "total" of HOPWA funding is given as $22.5 million, so that certainly looks like it's referring to the small competitive part of the HOPWA program, since HOPWA distributes mainly formula-based funding, and the total formula HOPWA awards made Dec. 8, 2004 for fiscal 2005 added up to more than $251 million. Except then there's a further footnote saying "Note: all figures exclude continuation awards," so we may have a case of apples and oranges here.
Maybe better just conclude that persons professing faith in a higher power have been receiving substantial earthly funding, amounts not yet entirely clear.
White House housing advisor arrested
In the Washington Post today (requires free registration), a very interesting article notes the arrest on retail crime charges of Claude Allen, who until last month was a top White House policy advisor. A high-ranking African-American who was also a leading proponent of the hard right's agenda, Allen is reported as having been an advisor on issues including housing. Has anyone heard of this guy before? And shouldn't Alphonso Jackson be Bush's top advisor on housing? I mean, disagree with Jackson all you want, but the guy knows the housing industry.
Anyway, this would be the appropriate point to extend our sympathies to Mr. Allen and his family, who must be enduring a trying time, except that after reading the article, my heart goes out more to Target and Hecht's stores.
Anyway, this would be the appropriate point to extend our sympathies to Mr. Allen and his family, who must be enduring a trying time, except that after reading the article, my heart goes out more to Target and Hecht's stores.
Friday, March 10, 2006
New CRA Q&A answers critics on housing
We have a new question-and-answer guidance document today from the three federal banking regulators that have been working together on the long-running rewrite process for the rules governing Community Reinvestment Act (CRA) enforcement. Among other provisions, the guidance clarifies that the Aug. 2, 2005 loosening of CRA exam procedures will not allow housing activities that benefit moderate- or upper-income households to count toward CRA compliance unless "the housing directly helps to revitalize or stabilize the community by attracting new, or retaining existing, businesses or residents and, in the case of a designated disaster area, is related to disaster recovery." Commenters associated with community development groups, led by the National Community Reinvestment Coalition, have been expressing fears for some time that new CRA rules could allow loans and investments benefiting the more comfortable citizens of a given area to qualify in categories that were established to serve low-income Americans.
You'll recall that back on Nov. 10, 2005, the FDIC, Federal Reserve and Comptroller of the Currency issued a notice and request for comment setting out clarifications in Q&A form to their Aug. 2, 2005 joint final rule on CRA examinations. The three regulators received nearly 200 letters each. (The FDIC's copies of its comment letters are, as usual, tidily presented for public review.) In response the regulators have issued today's revised Q&A text.
The August 2, 2005 joint final rule increased the threshold distinguishing "large" from "small" institutions to $1 billion in assets, meaning all but the very biggest financial entities would get less thorough CRA scrutiny, but it developed a new examination approach to "intermediate small banks" of $250 million to $1 billion in assets. The fourth CRA-enforcing institution, the Office of Thrift Supervision, has been making its own way separately on CRA enforcement. OTS unilaterally decided in summer 2004 to raise the "small institution" threshold to $1 billion, with no difference in scrutiny for institutions on the larger side in the "small" category. OTS further allowed CRA institutions more control over their own exams in a rather defensively phrased final rule announcement of March 2, 2005. The three other institutions have adopted somewhat less dramatic changes along the lines established by OTS.
You'll recall that back on Nov. 10, 2005, the FDIC, Federal Reserve and Comptroller of the Currency issued a notice and request for comment setting out clarifications in Q&A form to their Aug. 2, 2005 joint final rule on CRA examinations. The three regulators received nearly 200 letters each. (The FDIC's copies of its comment letters are, as usual, tidily presented for public review.) In response the regulators have issued today's revised Q&A text.
The August 2, 2005 joint final rule increased the threshold distinguishing "large" from "small" institutions to $1 billion in assets, meaning all but the very biggest financial entities would get less thorough CRA scrutiny, but it developed a new examination approach to "intermediate small banks" of $250 million to $1 billion in assets. The fourth CRA-enforcing institution, the Office of Thrift Supervision, has been making its own way separately on CRA enforcement. OTS unilaterally decided in summer 2004 to raise the "small institution" threshold to $1 billion, with no difference in scrutiny for institutions on the larger side in the "small" category. OTS further allowed CRA institutions more control over their own exams in a rather defensively phrased final rule announcement of March 2, 2005. The three other institutions have adopted somewhat less dramatic changes along the lines established by OTS.
And the winner is ...
Several affordable housing developments were recognized at the California Redevelopment Association conference in Monterey, Calif., this week.
Via Roble in Escondido received an award of excellence for mixed-use development. Developed by Trinity Housing Group and Wakeland Housing and Development Corp., Via Roble features 72 affordable apartments, 10 single-family homes and nine shopkeeper units. The project replaced a dilapidated, crime-ridden trailer park. The city redevelopment agency was involved in the project.
Mandela Gateway in Oakland was recognized in the new residential construction category. The 168-unit family project was developed by BRIDGE Housing Corp., with the assistance of the Oakland Housing Authority and the city's redevelopment agency. Mandela Gateway transformed underutilized lots and a distressed public housing project into a new transit-oriented village.
Las Brisas won in the residential rehab category. This project was the made possible by the city of Signal Hill’s redevelopment agency and the Los Angeles Community Design Center. Their efforts transformed a struggling project into a neighborhood with 90 affordable residential units, courtyards, a park and a community center.
The Poway Redevelopment Agency was recognized in the education and marketing category for its "Housing Solutions" campaign, which is helping to dispel the myths about affordable housing. City leaders worked with a partnership of local nonprofits.
Via Roble in Escondido received an award of excellence for mixed-use development. Developed by Trinity Housing Group and Wakeland Housing and Development Corp., Via Roble features 72 affordable apartments, 10 single-family homes and nine shopkeeper units. The project replaced a dilapidated, crime-ridden trailer park. The city redevelopment agency was involved in the project.
Mandela Gateway in Oakland was recognized in the new residential construction category. The 168-unit family project was developed by BRIDGE Housing Corp., with the assistance of the Oakland Housing Authority and the city's redevelopment agency. Mandela Gateway transformed underutilized lots and a distressed public housing project into a new transit-oriented village.
Las Brisas won in the residential rehab category. This project was the made possible by the city of Signal Hill’s redevelopment agency and the Los Angeles Community Design Center. Their efforts transformed a struggling project into a neighborhood with 90 affordable residential units, courtyards, a park and a community center.
The Poway Redevelopment Agency was recognized in the education and marketing category for its "Housing Solutions" campaign, which is helping to dispel the myths about affordable housing. City leaders worked with a partnership of local nonprofits.
Trend-setters at the AFT conference, redux
In this blog item yesterday, I noted that Trammell Crow Residential Chairman and CEO Ron Terwilliger stoked some controversy over whether or not he was being too aggressive by trending rents. The practice is used when planning and justifying to lenders new multifamily deals, and Terwilliger got a lot of ribbing at the conference for his aggressive production of multifamily housing.
But Terwilliger defended himself well on Thursday. Speaking as the second keynote in the morning session with Wharton School's Dr. Peter Linneman, Terwilliger pointed out that the fundamentals for rental housing -- stabilization of the loss of renters to homeownership, a net increase of national population of about 3 million a year, and more -- were solid. But on the downside are huge land costs and other construction costs, so when he tries to finance a deal, he's having to forecast rents out four or five years, because that's how long it'll take to get the project entitled and then built. "We've got to find invesors who are willing to trend rents out four or five years. That's hard; they like to use current rents," Terwilliger said.
But Terwilliger defended himself well on Thursday. Speaking as the second keynote in the morning session with Wharton School's Dr. Peter Linneman, Terwilliger pointed out that the fundamentals for rental housing -- stabilization of the loss of renters to homeownership, a net increase of national population of about 3 million a year, and more -- were solid. But on the downside are huge land costs and other construction costs, so when he tries to finance a deal, he's having to forecast rents out four or five years, because that's how long it'll take to get the project entitled and then built. "We've got to find invesors who are willing to trend rents out four or five years. That's hard; they like to use current rents," Terwilliger said.
The eight-year gov't itch (From AFT conference)
The national economy will keep going at a pretty good clip for the next three years because, frankly, the folks in Washington are too distracted to mess it up too badly, said Dr. Peter Linneman, professor of real estate at the Wharton School of Business at the University of Pennsylvania. Linneman, keynote speaker on Day Two of Apartment Finance Today's Developer Conference in San Diego, told a packed room of multifamily executives that between the war (remember that?) and the roiling Jack Abramoff scandal, Congress and the White House simply haven't got the time or energy to make any radical interventions in the economy.
Ah, but in three years! Linneman said a new Congress and White House -- of either party -- in 2008 will feel duty bound to change stuff, whether or not it needs changing. The good doctor is, of course, an economic libertarian, but he noted that the basic economic, social and immigration trends all point to steady growth for the foreseeable future, until it is mucked up by human intervention.
Now, if we could only get the White House to stop trying to "save" HUD so much...
Ah, but in three years! Linneman said a new Congress and White House -- of either party -- in 2008 will feel duty bound to change stuff, whether or not it needs changing. The good doctor is, of course, an economic libertarian, but he noted that the basic economic, social and immigration trends all point to steady growth for the foreseeable future, until it is mucked up by human intervention.
Now, if we could only get the White House to stop trying to "save" HUD so much...
Feds squeeze illegal tax shelters
Illegal tax shelters cost Deutsche Bank $300 million in legal costs alone in 2005, according to this New York Times story.
This might not seem like great news for the tax credit business – but it is. Businesses have a limited number of ways to decrease their tax burden. As illegal tax shelters become harder to use because of criminal investigations, legitimate tax benefits like the low-income housing tax credt become more valuable.
This might not seem like great news for the tax credit business – but it is. Businesses have a limited number of ways to decrease their tax burden. As illegal tax shelters become harder to use because of criminal investigations, legitimate tax benefits like the low-income housing tax credt become more valuable.
Thursday, March 09, 2006
From the CRA conference
How do you get the attention of a room full of redevelopment officials? Just say “eminent domain.” Those two words were drawing lots of attention at the California Redevelopment Association (CRA) meeting taking place in Monterey, Calif.
Redevelopment officials are carefully watching several state bills, including SB 1206 and SB 1210, which they say could threaten local governments’ ability to eradicate blight and build affordable housing.
Eminent domain has become an increasingly hot-button issue across the nation in the wake of the Supreme Court decision in Kelo v. City of New London, which affirmed that local government could use its powers of eminent domain to acquire property for economic development. The case has made many people, including lawmakers, more sensitive about the use of eminent domain laws.
Redevelopment officials are carefully watching several state bills, including SB 1206 and SB 1210, which they say could threaten local governments’ ability to eradicate blight and build affordable housing.
Eminent domain has become an increasingly hot-button issue across the nation in the wake of the Supreme Court decision in Kelo v. City of New London, which affirmed that local government could use its powers of eminent domain to acquire property for economic development. The case has made many people, including lawmakers, more sensitive about the use of eminent domain laws.
NCSHA helps make the case for housing

The next day, NCSHA members swarmed Capitol Hill, visiting their representatives armed with NCSHA's packet of information on why affordable housing programs are imprtant and what Congress can do to help.
This just in: more low-cost housing needed
Lately we've been buried in scholarly studies on poverty and housing, of which a surprising number seem to announce common knowledge that official verifiers have lately gotten around to verifying. The Harvard Joint Center for Housing Studies finds that there are plenty of apartments but not enough low rents... Comptroller General David Walker of GAO says they need more housing in New Orleans (actually, see p. 33 for some good statistics), Abt Associates via HUDUSER finds FHA mortgage borrowers are poorer and viewed as worse credit risks than GSE borrowers but not as much so as subprime borrowers... A different Abt team via HUDUSER discovers that subprime lenders, pawnbrokers, and payday lenders take advantage of redlined customers, who are likely to live in poor or "minority" neighborhoods (they get into some specifics in a Dallas case study)... Via HAC News, the National Fair Housing Alliance notes there has been race-based housing discrimination against hurricane survivors (warning: clicking for the main report file crashes a Firefox OS X browser).... Second Harvest, in its 2006 U.S. hunger study, finds 35% of clients of food programs have had to choose between paying for food or housing, and the figure rises to 42% for food versus utilities... and the Center for Responsible Lending says state laws against predatory lending actually do some good...
...but this next study does go beyond common knowledge and I can't bring myself to be flip about it: it's a study, via HUDUSER, by UPenn mental health experts on recently homeless mentally ill tenants who left or were asked to leave "permanent" supportive housing after a few months. There are some helpful, thoughtful details here, including the view that many were still helped by the stay even if it didn't work out for them. For readers who want to think carefully about the possibilities and limits of current supportive housing programs, this study is a good place to start. Interestingly, Dr. Darlene Williams, HUD's Assistant Secretary for Policy Development and Research, herself took the time to write an introduction to this study.
(A thought of my own, based on many long talks with formerly homeless tenants and their counselors: this program-leavers' study has a lot to say, and says it well and carefully -- but I do wonder if it neglects the anxiety that the experience of moving indoors can itself cause to people who have been homeless a long time. Readjusting to housing after a long stint of urban homelessness, especially for people who suffered violence while homeless, has things distantly in common with a demobilized soldier's return to civilian life. It can take time and courage and help to come all the way in from the cold.)
...but this next study does go beyond common knowledge and I can't bring myself to be flip about it: it's a study, via HUDUSER, by UPenn mental health experts on recently homeless mentally ill tenants who left or were asked to leave "permanent" supportive housing after a few months. There are some helpful, thoughtful details here, including the view that many were still helped by the stay even if it didn't work out for them. For readers who want to think carefully about the possibilities and limits of current supportive housing programs, this study is a good place to start. Interestingly, Dr. Darlene Williams, HUD's Assistant Secretary for Policy Development and Research, herself took the time to write an introduction to this study.
(A thought of my own, based on many long talks with formerly homeless tenants and their counselors: this program-leavers' study has a lot to say, and says it well and carefully -- but I do wonder if it neglects the anxiety that the experience of moving indoors can itself cause to people who have been homeless a long time. Readjusting to housing after a long stint of urban homelessness, especially for people who suffered violence while homeless, has things distantly in common with a demobilized soldier's return to civilian life. It can take time and courage and help to come all the way in from the cold.)
New updates in HUD's LIHTC database
HUD serves notice that it has updated its database on projects financed with the low-income housing tax credit (LIHTC). New details include information on mixed-finance arrangements: the new form notes whether projects involve CDBG or HOME funding or FHA insurance. The data still only covers the period from the 1980s through 2003, but it's progress and probably good reading. Better yet, there's a 167-page companion report from Abt Associates that crunches a bunch of the numbers.
Overheard at the AFT developers conference...
From a few hours' worth of chatting in the halls, at the cocktail party, at the VIP reception, and in the exhibit hall:
Best way to get a serious and composed FHA lender's eyes to bug out and for him/her to start talking nonstop: Mention the proposal by HUD to nearly double the mortgage insurance premiums. It'll "kill business." It's "designed to shrink HUD." It "will never pass [Congress]." It will pass Congress and it will "flatten" the market.
So, is the student housing boom past its prime, still in its prime, or yet to see its prime? Mostly bullish thoughts came from several developers and lenders I spoke with, but also some caution expressed about making sure it's a big university or college in a solid market. (I don't have the link on me -- sorry -- but I read recently about some trouble one big student housing developer ran into in USC, in part because of an overly risque advertising campaign that suggested students who live in their units will, um, er, uh, "get lucky" a lot. It also apparently didn't have the greatest relationship with the university. Unlucky strategy, that.)
Best way to get a serious and composed FHA lender's eyes to bug out and for him/her to start talking nonstop: Mention the proposal by HUD to nearly double the mortgage insurance premiums. It'll "kill business." It's "designed to shrink HUD." It "will never pass [Congress]." It will pass Congress and it will "flatten" the market.
So, is the student housing boom past its prime, still in its prime, or yet to see its prime? Mostly bullish thoughts came from several developers and lenders I spoke with, but also some caution expressed about making sure it's a big university or college in a solid market. (I don't have the link on me -- sorry -- but I read recently about some trouble one big student housing developer ran into in USC, in part because of an overly risque advertising campaign that suggested students who live in their units will, um, er, uh, "get lucky" a lot. It also apparently didn't have the greatest relationship with the university. Unlucky strategy, that.)
Hud and those pesky GSE portfolios
A follow-up to the item in yesterday's blog about HUD Sec. Alphonso Jackson definitely NOT backpedaling just because he sounded like he was when he discussed whether Fannie Mae and Freddie Mac should be forced to reduce their portfolio investments.
Freddie Mac multifamily housing exec Adrian Corbiere, speaking at the opening roundtable to the first day of Apartment Finance Today's Developer Conference in San Diego, noted that sharply curtailing the GSE's portfolios could be a significant problem. "We're a portfolio lender. Practically everything we do goes into our portfolio," said Corbiere. He added that Freddie would be hurt more than Fannie Mae, which does more securitization of its mortgage investments.
Freddie Mac multifamily housing exec Adrian Corbiere, speaking at the opening roundtable to the first day of Apartment Finance Today's Developer Conference in San Diego, noted that sharply curtailing the GSE's portfolios could be a significant problem. "We're a portfolio lender. Practically everything we do goes into our portfolio," said Corbiere. He added that Freddie would be hurt more than Fannie Mae, which does more securitization of its mortgage investments.
The trend toward -- or away from? -- trending
At the opening roundtable session of the Apartment Finance Today's Developer Conference yesterday in San Diego, the issue of trending rents in underwriting multifamily properties came up. And up. And up again. Quite a controversial topic, that.
Ron Terwilliger of Trammel Crow Residential got it rolling. Terwilliger is a proponent of using trends, but some of the other roundtable participants (lenders, perhaps as expected) disliked the use of rent trending. Not dependable, said some.
What do you think? To whose advantage is rent trending? Should it be used more widely? And does it work best or only in markets that are historically very stable, or would opponents oppose its use even there?
Ron Terwilliger of Trammel Crow Residential got it rolling. Terwilliger is a proponent of using trends, but some of the other roundtable participants (lenders, perhaps as expected) disliked the use of rent trending. Not dependable, said some.
What do you think? To whose advantage is rent trending? Should it be used more widely? And does it work best or only in markets that are historically very stable, or would opponents oppose its use even there?
Wednesday, March 08, 2006
An anxious HUD clarification on GSEs
Hm, looks like some backpedaling from HUD on Secretary Alphonso Jackson's opinion of GSEs regulation. First, we have the Secretary quoted briefly in the Atlanta Journal Constitution like this:
Fannie Mae and Freddie Mac shouldn't be ordered by Congress to cut their $1.4 trillion combined mortgage portfolios and should only get such a directive from their regulator, the head of Department of Housing and Urban Development said Tuesday. "The regulator should decide" the appropriate size of the holdings, which generate about two-thirds of the companies' profits, HUD Secretary Alphonso Jackson said in an interview in Washington. "We will have faith and confidence in the regulator to look at the issue and come up with a conclusion" that Fannie Mae and Freddie Mac "can live with."and in the Washington Post like this:
HUD Secretary Alphonso Jackson said Fannie Mae and Freddie Mac should not be ordered by Congress to cut their $1.4 trillion combined mortgage portfolios and should get such a directive only from their regulator. His comments differ from those of Treasury Secretary John W. Snow, who has called on Congress to require a new regulator to reduce the mortgage portfolios at the two government-chartered firms. Shifts in interest rates and other risks could undermine the holdings and trigger widespread financial market turmoil, Snow said...Comes now the HUD public relations department with this conspicuously terse press release saying:
Hm. It looks like the AJC and the Post are both quoting from an interview in another publication that hasn't hit the wires yet. Anyone know what it was?HUD STATEMENT ON GSE REFORM
ALPHONSO JACKSON
SECRETARY
HUD's position on a strong GSE regulator remains unchanged. I believe strongly in the need for a world-class regulator to ensure the soundness of the GSEs. We look forward to working with Congress to develop a regulator that will provide strengthened oversight. Legislation to mandate a reduction in the retained portfolios to reduce systemic risk is also a critical part of this equation.
2006 income limits out today too
Here are the tables at HUDUSER. (Thanks to Novogradac for spotting this one.)
SuperNOFA out this morning
The meaty second section of the HUD SuperNOFA, with the amounts and deadlines for most of HUD's grant and loan programs is in this morning's Federal Register. HTML edition here, PDF edition here. For the summary table, pick the PDF version and go to its fourth page. The "general section" of application instructions, which appeared Jan. 20, is in HTML here, PDF here.
The timing, again, is earlier. Last year's announcement was March 21. But remember, of course, this year nearly all applicants are required to go through the cranky Grants.gov system -- which doesn't work with Macintosh computers and which caused galloping delays on some of last year's SuperNOFA application processes. Applicants were urged to get their Grants.gov registrations in place during the winter.
Good luck, all.
The timing, again, is earlier. Last year's announcement was March 21. But remember, of course, this year nearly all applicants are required to go through the cranky Grants.gov system -- which doesn't work with Macintosh computers and which caused galloping delays on some of last year's SuperNOFA application processes. Applicants were urged to get their Grants.gov registrations in place during the winter.
Good luck, all.
Tuesday, March 07, 2006
John Cox nominated to be HUD CFO
John Wallace Cox was nominated on Friday to succeed Carin Barth as Chief Financial Officer at HUD. Per the potted bio at GCN and the official paragraph accompanying his nomination, he's a tax specialist who has worked for BMC Software and Ernst & Young. (It's a background similar to that of HUD General Counsel Keith Gottfried, but Gottfried worked in Pennsylvania and California before entering government, and the new man is a Texan.)
[MORE: According to the Houston Business Journal and Edgar Online, Mr. Cox resigned from BMC "to pursue other interests" as of September 2004.
The official descriptions say he has most recently been a consultant. The only corporate connection that comes up quickly online for the period since 2004 is Benchmark Electronics, Inc. This code of conduct document for Benchmark names Mr. Cox as the contact for the company's audit committee, and he is also listed as a member of Benchmark's board of directors. Is anyone reading here familiar with his other work since 2004?]
[MORE: According to the Houston Business Journal and Edgar Online, Mr. Cox resigned from BMC "to pursue other interests" as of September 2004.
The official descriptions say he has most recently been a consultant. The only corporate connection that comes up quickly online for the period since 2004 is Benchmark Electronics, Inc. This code of conduct document for Benchmark names Mr. Cox as the contact for the company's audit committee, and he is also listed as a member of Benchmark's board of directors. Is anyone reading here familiar with his other work since 2004?]
New CPD evaluation rules and more
- HUD today publishes new final "outcome measurement" procedures for Community Planning and Development formula grant programs: Community Development Block Grants, Emergency Shelter Grants, HOPWA and the HOME Investment Partnerships Program.
- A proposed rule is out on self-insurance in connection with Indian housing block grants.
- USDA is proposing homeownership counseling requirements for its single-family home borrowing programs.
- Just wondering: does anyone know why the HUD email list for "faith-based and community initiatives" is described on this directory of HUD listservs as a "closed list" requiring permission to join?
- A proposed rule is out on self-insurance in connection with Indian housing block grants.
- USDA is proposing homeownership counseling requirements for its single-family home borrowing programs.
- Just wondering: does anyone know why the HUD email list for "faith-based and community initiatives" is described on this directory of HUD listservs as a "closed list" requiring permission to join?
Tuesday mix: modest proposals edition
- A HUD press release today showcases the agency's recent advocacy for legislation in a meeting with state housing officials, including Sec'y Jackson's call to "fix" Sec. 8 with the "State and Local Housing Flexibility Act" (S. 771 and HR 1999), which among other "flexibilities" would allow and encourage local programs to raise rents in federally subsidized housing.
- NLIHC's Memo to Members says the Congressional Research Service agrees that the anti-voter-registration conditions that were attached to the House version of the HR 1461 GSE's bill are unconstitutional. (See here and here for last October's drama.) Also, they summarize the last Senate budget hearing, in which Sec'y Jackson apparently suggested it was a bad thing for tenants to continue receiving Sec. 8 voucher housing assistance for long periods; they note a petition to preserve the Community Development Block Grants is circulating in the House; and they've caught a GAO report we missed (sorry!) criticizing the fairness of HOPWA funding distribution.
- The folks at the U.S. Interagency Council on Homelessness (USICH) thought so well of this NPR interview with New Yorker columnist Malcolm Gladwell on "A Scientific Approach To Helping The Homeless" that they transcribed the whole thing in their most recent newsletter. It's not posted yet at their site, but if you're not able to listen to the NPR recording online, you might check back at this archive in a few days. Mr. Gladwell's scientific approach is to take the view that "The problem is concentrated in a very small number of people who are profoundly troubled," and to note that the problems of this most troubled "hard core" are not really solved with housing alone. This is where he speaks warmly of the USICH technique -- elsewhere known as "housing first" or, at hospitals, as a "frequent flyer program" -- that concentrates on the most badly deteriorated street sleepers who tend to be the biggest consumers of emergency medical services. It gets them indoors, then works hard to stabilize them with counseling, medical care, detox, and so on. Asked what should be done for less troubled people who are merely without housing, he says:
- The Los Angeles Housing Authority, recently under a new director, got HUD's Inspector General to agree that the previous director allowed its Sec. 8 waiting list to get out of hand. The said waiting list, after climbing well into the five figures, had been closed since 2004, and it appears the new director was preparing to reopen it in early 2006.
- Legal columnist Noah Leavitt calls the Katrina non-relief fiasco a "human rights failure" and links to international efforts of experts and advocates along those lines. He cites a study for the UN High Commissioner on Human Rights that concludes, regarding extreme poverty in the U.S. generally (not just the unequal Katrina recovery):
- NLIHC's Memo to Members says the Congressional Research Service agrees that the anti-voter-registration conditions that were attached to the House version of the HR 1461 GSE's bill are unconstitutional. (See here and here for last October's drama.) Also, they summarize the last Senate budget hearing, in which Sec'y Jackson apparently suggested it was a bad thing for tenants to continue receiving Sec. 8 voucher housing assistance for long periods; they note a petition to preserve the Community Development Block Grants is circulating in the House; and they've caught a GAO report we missed (sorry!) criticizing the fairness of HOPWA funding distribution.
- The folks at the U.S. Interagency Council on Homelessness (USICH) thought so well of this NPR interview with New Yorker columnist Malcolm Gladwell on "A Scientific Approach To Helping The Homeless" that they transcribed the whole thing in their most recent newsletter. It's not posted yet at their site, but if you're not able to listen to the NPR recording online, you might check back at this archive in a few days. Mr. Gladwell's scientific approach is to take the view that "The problem is concentrated in a very small number of people who are profoundly troubled," and to note that the problems of this most troubled "hard core" are not really solved with housing alone. This is where he speaks warmly of the USICH technique -- elsewhere known as "housing first" or, at hospitals, as a "frequent flyer program" -- that concentrates on the most badly deteriorated street sleepers who tend to be the biggest consumers of emergency medical services. It gets them indoors, then works hard to stabilize them with counseling, medical care, detox, and so on. Asked what should be done for less troubled people who are merely without housing, he says:
I mean what we're trying to show here is, can we, in a relatively short period of time, strike at the core of the problem? And if we can show that we can do that, then I would hope, I would hope that we would then take a step back and say, okay, let's start dealing with people who are also troubled but just not in the same immediate dire straits. I hope we don't stop at this.- Sec'y Jackson announces the release of $5 million in university grants for the Katrina recovery.
- The Los Angeles Housing Authority, recently under a new director, got HUD's Inspector General to agree that the previous director allowed its Sec. 8 waiting list to get out of hand. The said waiting list, after climbing well into the five figures, had been closed since 2004, and it appears the new director was preparing to reopen it in early 2006.
- Legal columnist Noah Leavitt calls the Katrina non-relief fiasco a "human rights failure" and links to international efforts of experts and advocates along those lines. He cites a study for the UN High Commissioner on Human Rights that concludes, regarding extreme poverty in the U.S. generally (not just the unequal Katrina recovery):
Resource constraints have limited the reach of the assistance programmes, and social discrimination has aggravated the problems in many situations resulting in poverty clearly seen as a violation of human rights. If the United States Government designed and implemented the policies according to the human rights standards much of the problem of poverty could be resolved.
FEMA not run by rocket scientists
I wish I could be more sympathetic and come up with something nice to say about FEMA's leadership in the Gulf Coast recovery effort, but then comes this story from yesterday's LA Times (site requires free registration). It seems a Mississippi mayor wanted to build some of the new so-called "Katrina cottages" in her community, and FEMA objected. To quote the article by Times staff writer Richard Fausset, "The issue wasn't cost: The cottage could probably be had for about the same price as a trailer. The problem was that the cottage would be permanent — and FEMA is not in the business of providing permanent housing."
Wasn't this government supposed to be the one to clear away bureaucracy? Wasn't this the gang that was going to get the federal government out of the way so local leaders could determine what's best for their communities instead of federal mandates?
Guess not.
Wasn't this government supposed to be the one to clear away bureaucracy? Wasn't this the gang that was going to get the federal government out of the way so local leaders could determine what's best for their communities instead of federal mandates?
Guess not.
Monday, March 06, 2006
Soldiers' housing bill could affect LIHTC
Quite some bill, this HR 3186. It would make more members of the military eligible for subsidized housing by exempting military housing allowance payments from the income calculations for federal low-income housing programs. The exemption would include subsidy programs outside HUD, including the low-income housing tax credit (LIHTC). They're calling it "the `Build Houses for Our Military's Enlisted Servicemembers Act' or the `Build HOMES Act'," but it looks like the disregard would apply to existing rentals. There's no direct mention of new construction but then again this bill might stimulate some new construction if it goes through.
The bill was introduced last June by Rep. Jim Ryun, R-Kan. and heard in the House Subcommittee on Housing and Community Opportunity last month. The Nat'l Association of Home Builders testified in its favor, specifically highlighting its possible effects on military households currently ineligible for LIHTC housing.
This is definitely worth a look for LIHTC planners.
The bill was introduced last June by Rep. Jim Ryun, R-Kan. and heard in the House Subcommittee on Housing and Community Opportunity last month. The Nat'l Association of Home Builders testified in its favor, specifically highlighting its possible effects on military households currently ineligible for LIHTC housing.
This is definitely worth a look for LIHTC planners.
Fair(er) Market Rents
Revisions are published today to HUD's official "Fair Market Rents" (FMRs) based on new data for a small grab bag of places: Burlingon, VT, St. Mary's County, MD, San Jose and San Benito, CA and... yes, New Orleans and Baton Rouge. For comparison, the main Oct. 3, 2005 announcement table is here.
Burlington's new FMR figures are actually lower, e.g. from $745 to $660 for a one-bedroom unit. Same for the Maryland county, with the 1BR figure dropping from $720 to $631.
San Jose drops from $1103 to $1059 for a 1BR, but the $1103 figure was a 50th-percentile rent that HUD was preparing to drop to 40th-percentile level, so people in and over the voucher system there must already have begun preparing for smaller rent caps. San Benito County actually gets an increase: from $796 to $831 for a 1BR.
At least the New Orleans FMRs are up. Not quite as up as the GSA-approved upward departures from $133 per night for federal employees -- but, well, they're higher than they were. A 1BR unit, if one can be found there, would be subsidized as voucher housing at a rent up to $803, which beats the previous figure of $595. Baton Rouge FMRs rose from $532 for a 1BR to $624 -- significant especially because, as of Aug. 25, 2005, the Baton Rouge FMRs were about to be dropped from 50th-percentile levels.
Burlington's new FMR figures are actually lower, e.g. from $745 to $660 for a one-bedroom unit. Same for the Maryland county, with the 1BR figure dropping from $720 to $631.
San Jose drops from $1103 to $1059 for a 1BR, but the $1103 figure was a 50th-percentile rent that HUD was preparing to drop to 40th-percentile level, so people in and over the voucher system there must already have begun preparing for smaller rent caps. San Benito County actually gets an increase: from $796 to $831 for a 1BR.
At least the New Orleans FMRs are up. Not quite as up as the GSA-approved upward departures from $133 per night for federal employees -- but, well, they're higher than they were. A 1BR unit, if one can be found there, would be subsidized as voucher housing at a rent up to $803, which beats the previous figure of $595. Baton Rouge FMRs rose from $532 for a 1BR to $624 -- significant especially because, as of Aug. 25, 2005, the Baton Rouge FMRs were about to be dropped from 50th-percentile levels.
Sunday, March 05, 2006
Another nice design idea, as yet unused
Yes, more of the San Francisco Chronicle on design. Sorry, it's just hard to ignore a good story right there on the breakfast table.
A local architect, with a nod to San Francisco's own past, introduces the charming "Katrina cottage".
Alas, there doesn't seem to be anywhere you can get one. Sadly, that often seems to be true about nifty designs created to help the destitute -- the worse problem is usually finding money and land to make them work. Cf. some of the shelter designs in this winter's MOMA exhibit Safe: Design Takes On Risk.
A local architect, with a nod to San Francisco's own past, introduces the charming "Katrina cottage".
Alas, there doesn't seem to be anywhere you can get one. Sadly, that often seems to be true about nifty designs created to help the destitute -- the worse problem is usually finding money and land to make them work. Cf. some of the shelter designs in this winter's MOMA exhibit Safe: Design Takes On Risk.
Inclusionary Zoning spreads…
Inclusionary zoning laws got some positive attention in the latest New York Times. (Inclusionary zoning is the practice of requiring new developments to include some percentage of affordable housing.)
Saturday, March 04, 2006
HUD strategic plan pending -- who knew?
Guess what? You have 14 days left to comment on HUD's proposed new strategic plan for 2006-2011. Better hurry up and digest the 66 pages thereof and speak now, by email to StrategicPlan@hud.gov, or forever hold your peace.
It seems a 30-day comment period on the proposal has been running for quite some time now, without a peep in the Federal Register (here, you try searching), nor on HUDCLIPS "What's New," nor in the HUD "Newsroom" press releases, nor on any of a whole passel of HUD's listservs. Let this be a lesson to us HUD-watchers that it also pays to take regular close looks at HUD's front Web page, and the site of HUD's Chief Financial Officer.
But, hey, waitaminnit, can it really be quite OK with the Administrative Procedure Act -- specifically, 5 U.S. Code 552(a)(1), to set up something as important as a strategic plan for an entire federal agency for five years without requesting public comment in the Federal Register?
Readers, please advise: am I missing something here?
It seems a 30-day comment period on the proposal has been running for quite some time now, without a peep in the Federal Register (here, you try searching), nor on HUDCLIPS "What's New," nor in the HUD "Newsroom" press releases, nor on any of a whole passel of HUD's listservs. Let this be a lesson to us HUD-watchers that it also pays to take regular close looks at HUD's front Web page, and the site of HUD's Chief Financial Officer.
But, hey, waitaminnit, can it really be quite OK with the Administrative Procedure Act -- specifically, 5 U.S. Code 552(a)(1), to set up something as important as a strategic plan for an entire federal agency for five years without requesting public comment in the Federal Register?
Readers, please advise: am I missing something here?
Friday, March 03, 2006
Lead paint lawsuit allowed to proceed
Looks like today a California appeals court allowed several claims in a public lawsuit to proceed against lead manufacturers over damage caused by lead paint. However, it upheld a lower court's decision to bar "unfair competition" claims under Cal. Business & Professions Code Sec. 17200. This "unfair competition" statute has been widely used in California to bring lawsuits similar in effect to class actions, but its scope was reduced by the 2004 passage of California Proposition 64. Today's decision, however, doesn't seem related to Prop. 64: the Sec. 17200 claims were rejected on statute of limitations grounds.
A green project gets a good review in SF
SF Chron architecture critic John King has a glowing review today of the green-designed Plaza Apartments at Sixth and Howard Streets in San Francisco. This project was locally quite controversial for a while -- see here... and here... but he's quite right that the end result is a lot more original than it would have had to be. His choice of the word "humane" makes sense. South of Market in San Francisco -- especially Howard Street -- has been an extremely popular location for tax-credit housing in recent years, and despite attempts at architectural innovation like the skinny windows at 1166 Howard, most of the tax credit buildings have a basic family resemblance that includes a little institutional edge. The Plaza Apartments genuinely do look different.
Friday mix: Who Ya Gonna Tell?
- A HUD study on public awareness of fair housing law finds that since 2001 people have become more aware of laws banning discrimination based on family size or by means of racial "steering," but less so of laws against discrimination by religion. The study further considers "why so few people who perceive they have been discriminated against do nothing about it." Mainly, it seems, they figure it's pointless to try or they don't know how to file a complaint.
- The IRS is inviting applications to serve on the Taxpayer Advocacy Panel.
- One more electronic paperwork requirement: USDA Rural Development's latest handbook updates say RD-subsidized buildings of eight units or more must provide their tenant certifications electronically.
- The IRS is inviting applications to serve on the Taxpayer Advocacy Panel.
- One more electronic paperwork requirement: USDA Rural Development's latest handbook updates say RD-subsidized buildings of eight units or more must provide their tenant certifications electronically.
Thursday, March 02, 2006
Housing mix: 2006-11 comments, anyone?
Sufficient unto the day are the minutiae thereof:
- At HUD, Sec'y Jackson is promoting Native American home purchase subsidies and the deadline has been moved back to March 31 to nominate "local governments who aggressively work to reduce regulatory barriers to affordable housing" for HUD's Woodson Awards.
- The IRS is soliciting comments after the fact on its Notice 2006-11, which created exceptions from LIHTC income and residency rules for tenants displaced by Hurricane Rita.
- There's a new claim form for residents displaced by federally funded projects to claim rental or housing downpayment help. They say they've canceled a Spanish-language version, not clear why.
- At HUD, Sec'y Jackson is promoting Native American home purchase subsidies and the deadline has been moved back to March 31 to nominate "local governments who aggressively work to reduce regulatory barriers to affordable housing" for HUD's Woodson Awards.
- The IRS is soliciting comments after the fact on its Notice 2006-11, which created exceptions from LIHTC income and residency rules for tenants displaced by Hurricane Rita.
- There's a new claim form for residents displaced by federally funded projects to claim rental or housing downpayment help. They say they've canceled a Spanish-language version, not clear why.
Figuring income when you employ tenants
HUD's RHIIP multifamily listserv has a useful tip on employing tenants: if a subsidized building hires tenants to do work around the property such as lawn mowing or desk clerking, the first $200 per month doesn't count at all against their annual income for rent calculation purposes, but from $201 on up, the whole amount has to be counted. The tip cites to good old Handbook 4350.3, chapter 5, Paragraph 5-6.L. If this link to the Handbook doesn't work, try this one to the chapter, or look it up in the "Library" section at www.hudclips.org.
---
Some additional notes from an old welfare lawyer:
Landlords may want to consider Social Security income disregard rules when they offer even very modest part-time employment to senior or disabled tenants. SSA has posted summaries for the separate rules affecting Social Security disability... Social Security retirement pensions... and Supplemental Security Income (SSI). Some of these begin to cut benefits well before the $200/month mark is reached.
Tenants receiving social security disability or SSI benefits may be eligible to keep all their earned income for a while as part of special trial work periods, but they should be very careful to follow the rules of such programs. In particular, the SSI "PASS" plan, which requires tenants to identify and meet a goal that will be served by extra earned income, is subject to very strict enforcement. The goal must be realistic and must be met very precisely or the result can be whopping administrative hell and overpayment deductions out of future benefits from here to eternity.
For further Social Security benefit details, try (in increasing order of complexity) the online Red Book... 20 CFR Parts 404 and 416... and the Program Operations Manual System (POMS). If those don't help, better put the tenant in touch with your local legal aid office.
---
Some additional notes from an old welfare lawyer:
Landlords may want to consider Social Security income disregard rules when they offer even very modest part-time employment to senior or disabled tenants. SSA has posted summaries for the separate rules affecting Social Security disability... Social Security retirement pensions... and Supplemental Security Income (SSI). Some of these begin to cut benefits well before the $200/month mark is reached.
Tenants receiving social security disability or SSI benefits may be eligible to keep all their earned income for a while as part of special trial work periods, but they should be very careful to follow the rules of such programs. In particular, the SSI "PASS" plan, which requires tenants to identify and meet a goal that will be served by extra earned income, is subject to very strict enforcement. The goal must be realistic and must be met very precisely or the result can be whopping administrative hell and overpayment deductions out of future benefits from here to eternity.
For further Social Security benefit details, try (in increasing order of complexity) the online Red Book... 20 CFR Parts 404 and 416... and the Program Operations Manual System (POMS). If those don't help, better put the tenant in touch with your local legal aid office.
Wednesday, March 01, 2006
Inter alia, "absolute disdain" in Texas
A sampling from the wires and announcements:
- Gov. Blanco of Louisiana says she fears conditions on a proposed $4.2 billion dollop of federal aid could "mitigate" human beings out of whole sections of New Orleans -- "If (the proposal) stays like it is, it will be New Orleans National Park."
- HUD is asking for comment on its multifamily mortgage insurance application.
- The CDFI Fund wants comments to help design a survey of its programs' effectiveness, and is further inviting comments on the application for Community Development Entity status in the New Markets Tax Credit program.
- The Texas Dept. of Housing and Community Affairs March newsletter includes a note that per state legislative action it is taking over the licensing and inspection of migrant laborers' housing from the Dept. of State Health Services.
- Sec'y Jackson is to tour Hurricane Rita damage per this report by a local Texas news station, which explains: "...The bi-partisan Texas congressional delegation was unified in their message of absolute disdain for the unfair amount of recovery assistance from the federal agency. "
- Gov. Blanco of Louisiana says she fears conditions on a proposed $4.2 billion dollop of federal aid could "mitigate" human beings out of whole sections of New Orleans -- "If (the proposal) stays like it is, it will be New Orleans National Park."
- HUD is asking for comment on its multifamily mortgage insurance application.
- The CDFI Fund wants comments to help design a survey of its programs' effectiveness, and is further inviting comments on the application for Community Development Entity status in the New Markets Tax Credit program.
- The Texas Dept. of Housing and Community Affairs March newsletter includes a note that per state legislative action it is taking over the licensing and inspection of migrant laborers' housing from the Dept. of State Health Services.
- Sec'y Jackson is to tour Hurricane Rita damage per this report by a local Texas news station, which explains: "...The bi-partisan Texas congressional delegation was unified in their message of absolute disdain for the unfair amount of recovery assistance from the federal agency. "
Fear of GSEs "systemic consequences"
This from Under Secretary For Domestic Finance Randal Quarles today, in a speech prepared for the Global Association of Risk Professionals:
...Third, and analogously, the rapid growth of the housing GSEs in the United States and the increased demand for their securities over the last decade have greatly exacerbated the potential for events at these institutions to have systemic consequences...There's more non-happy stuff about Fannie and Freddie in the text of the speech. Go read.
Mayor Bloomberg blasts HUD cuts
NYC Mayor Michael Bloomberg said in a speech to the National Low Income Housing Coalition that he wants members of Congress "to reject the proposed shortsighted cuts" to HUD's budget, proposed by the Bush Administration. (See New York Times story, which requires free registration.) Those cuts include major reductions in Community Development Block Grants, among others.
The mayor, who recently upped his commitment to creating or rehabilitating housing in the city to 165,000 units by 2013, called the federal government's involvement in housing matters "without a doubt, a matter of social justice."
Bloomberg reportedly isn't interested in national office, according to the article. Shame, that, because his approach is needed there.
The mayor, who recently upped his commitment to creating or rehabilitating housing in the city to 165,000 units by 2013, called the federal government's involvement in housing matters "without a doubt, a matter of social justice."
Bloomberg reportedly isn't interested in national office, according to the article. Shame, that, because his approach is needed there.
(see links in right-hand column).






