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HUD Multifamily Housing Compliance. What Every Tax Credit Investor, Loan Server, and Borrower Needs to Know May 10-11, 2007. WHAT KINDS OF PROGRAMS ARE WE DISCUSSING? Grants To Local Government – HOME, CDBG Multifamily Mortgage Insurance

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HUD Multifamily Housing Compliance

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Hud multifamily housing compliance l.jpg

HUD Multifamily Housing Compliance

What Every Tax Credit Investor, Loan Server, and Borrower Needs to Know

May 10-11, 2007


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WHAT KINDS OF PROGRAMS ARE WE DISCUSSING?

  • Grants To Local Government – HOME, CDBG

  • Multifamily Mortgage Insurance

  • Section 8 – Project-based, AAFs, FMRs, OCAFs, Budget Based, 50 Percent Incomes

  • Vouchers

  • HOPE VI

  • Public Housing


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Introductory Regulatory Issues In Non-Procurement Government Contracts. You Are In The Real Estate Business, But So Much More!

  • You Have Extra Civil, Criminal Law Requirements

    • False Statements Act

    • False Claims Act

    • 666 – Watch out for Faustian bargains!


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Administrative Issues

  • Flags

  • LDP

  • Suspension And Debarment -- EPLS


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Regulatory Requirements

  • Audits, Inspections, Reviews

  • Tax Credits -- 8823s Follow HUD Handbook 4350.3 Plus New 8823 Guide


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2530 – Previous Participation Review

  • 24 CFR Part 200 Subpart H

  • Plus Memos, Unpublished “Lore”


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  • Key Concepts

  • MPRC Process

    • Principles

    • Properties

    • Officers

    • GPs

    • LPs

    • LLCs

    • Baseline


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  • Paper v. Electronic – APPs History Of Delay, Problems

  • Substantive Changes Along With APPs – Federal Register Change

  • Pending Bill, Recent Memos – January Memo, March Memo On Investors, H.R. 1675


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Starting Point For Using APPS:

  • Quick Tips, Glossary

  • “Absolution,” HUD “Absolves” You Of Your Sins – Sets the tone

  • REMS And Interpreting With Flags – Leads To Field Office Confession


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KEY BUSINESS AGREEMENTS

  • Regulatory Agreement – Key Documents In FHA Loans.

  • Read It All But Focus on:

    • Limits – Para 2 – deposits

    • Para 4 – rent schedule

    • Para 6-Transfers (TPA), distribution (surplus cash, inspection)

    • Para 7-Maintenance, Inspection

    • Para 9-Management Contract, MOR, Audits

    • Para 10-Fair Housing, but that applies in law by own force too


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HAPs – Housing Assistance Payments

  • Many Of The Same Requirements As Regulatory Agreement

  • HAP Forms Can Differ Substantially In Different Section 8 Programs. Always Check The HAP:

    • Part II in example paras. 2.4 to 2.6, 2.10, 2.17, 2.20

    • Renewals – MAHRA, Section 8 Renewal Guide


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USE AGREEMENTS

  • Vary Widely – Seen Only In Some Programs, Such As

    • Flexible Subsidy Program

    • Property Dispositions

    • Non-Profit Prepayments


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Audits – This Is A Regulatory Agreement And Increasingly, HAP Requirement (usually)

  • 4370.2

  • Hot topic – Repayment of Advances

  • Project v. Owner – 4381.5 – Common concept creating conflict


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YOUR FHA LOAN IS NONRECOURSE – SORT OF

  • REACs

  • MOR

  • Integrity Of Site Records

  • Managers – Good Samaritan Can Hurt

  • Use Agreements


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CASE STUDIES

  • How Enforcement Center Works

  • Harvey Case – Project v. Owner Expenses – Penalties May Not Be Worth The Principle!

  • David Case – Pays To Avoid Controversial Programs and Acts (coinsurance and default), Or Be Prepared Ahead Of Time

  • Livecchi Case – Owner Advances And Repayments – Respect Surplus Cash, Get Approvals and Keep Receipts!


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