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Texas Department of Housing and Community Affairs. Disaster Recovery Division. SESSION 5: IMPLEMENTING OUR PLAN – TDHCA CHALLENGES TO GETTING FUNDS OUT QUICKLY. CDBG Disaster Program Challenges. Program Challenges Staffing and building an unprecedented program Duplication of Benefits

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Presentation Transcript
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SESSION 5:

IMPLEMENTING OUR PLAN –

TDHCA CHALLENGES TO GETTING FUNDS OUT QUICKLY

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CDBG Disaster Program Challenges

Program Challenges

  • Staffing and building an unprecedented program
  • Duplication of Benefits
  • Integrating floodplain requirements (not required under annual block grant program)
  • Responding to intense interest in program activities
cdbg disaster program challenges
CDBG Disaster Program Challenges

Program Challenges – Staffing

  • State legislated caps on staff and budget
  • Round I originally designed to be integrated into existing TDHCA staffing structure
  • Round II necessitated creation of new Disaster Recovery Division
  • Anticipated that all housing under Round I will be done by Labor Day
    • Approx. 550 homes
  • All $503 million under Round I & II will be fully used within the next 2 ½ years
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • Round I & II assistance amounts are lesser of the maximum program limits or the amount needed to repair/replace the house
  • Assistance amount is reduced by the DOB amount
    • If damage remains to be addressed after repairs have been made, the assistance equals the amount necessary to ensure livability standards are met
    • Damage and normal wear and tear are addressed
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • HUD clarified that a “duplication of benefits” does not occur if a household used all funds from FEMA to make a home temporarily livable and CDBG funds will be used to reconstruct that housing unit
  • In such instances, assistance to the household is not reduced to cover the DOB
    • Project is eligible for the full amount necessary to repair/reconstruct that unit
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • Deductions: Sources of funding that duplicates benefits are deducted from the assistance amount including the following primary sources:
    • FEMA
    • SBA
    • Insurance
  • Homeowner is required to disclose all sources and CDBG Administrators verify information provided
    • Referrals have been made to HUD OIG when appropriate
cdbg disaster program challenges4
CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • Credits: Verified expenditures are credited back to homeowner if consistent with intended use of funds:
    • FEMA
      • Repair
      • Replacement
      • Permanent Housing Construction
    • Eligible uses identified by SBA and Insurance
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

Calculation Examples

  • Example 1: Maximum assistance is $65,000. The household received $10,000 from other funding sources. Determination made that $10,000 worth of repairs have been completed, but the house must be replaced. A replacement unit will cost $50,000. The household’s eligible assistance amount is $50,000.
  • Calculation:
    • Lesser of Max. Assist. or Damage: $50,000
    • Deductions: – $ 0
    • Assistance Level $50,000
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

Calculation Examples

  • Example 2: Maximum assistance is $65,000. The household received $10,000 from other sources. Households has $50,000 in damage but cannot prove that any of the $10,000 was used to fix the home. The household’s eligible assistance amount is $40,000.
  • Calculation:
    • Lesser of Lesser of Max. Assist. or Damage: $50,000
    • Additional Deductions: – $10,000
    • Assistance Level $40,000

Gap Funding Needed: $10,000

cdbg disaster program challenges7
CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

Calculation Examples

  • Example 3: Maximum assistance is $40,000 for rehab and $75,000 for reconstruction. The household received $5,2000 from FEMA for housing repair and replaced their roof for $3,200 ($2,000 DOB). The cost to address remaining damage is $60,000, exceeding the $40,000 rehab limit. The household is eligible to receive replacement housing that will actually cost $75,000, but must cover the $2,000 DOB amount.
  • Calculation:
    • Amount Needed: $75,000
    • Additional Deductions: – $ 2,000
    • Maximum Assistance $73,000

Gap Funding Needed: $2,000

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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

Calculation Examples

  • Example 5: The preliminary assistance calculation for a household resulted in approval of reconstruction assistance totaling $70,000. The household has been approved for an SBA loan totaling $25,000 but closed the loan before drawing any funds.
  • Calculation:
    • Amount Needed : $70,000
    • Additional Deductions: – $ 0
    • Assistance Level $70,000
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CDBG Disaster Program Challenges

Housing Trust Fund (HTF) Disaster Recovery Gap Financing Program

  • The CDBG Disaster Recovery Program can provide CDBG funding necessary to rehabilitate or reconstruct a home unless the funding represents a duplication of benefits, which is prohibited.
  • Gap financing has been a major barrier to moving the program forward
  • Most households only received FEMA funding, and they used it to live on after the storm
  • Because Texas is administering a construction program, the household has to make up the difference between the amount needed to repair/replace the home and the DOB amount
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CDBG Disaster Program Challenges

HTF Disaster Recovery Gap Financing Program

  • TDHCA Governing Board set aside $1 million in HTF dollars in September 2007 for Round I
    • Unrestricted State of Texas General Revenue
    • Maximum per household award is $10,000
      • Average need per household is $3,200
  • Necessary for households to complete their recovery by covering the gap representing a duplication of benefits
    • Approximately 72% of households under Round I have accessed the program since it became available
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CDBG Disaster Program Challenges

HTF Disaster Recovery Gap Financing Program

  • DOB gap-financing for homes being repaired, replaced, or reconstructed under Round I
  • Allows families to take advantage of CDBG funding by ensuring full coverage of home repair, replacement, or reconstruction cost
  • 0% loans and grants
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • Gap financing is a major barrier to moving the Round II HAP/SPRP program forward
  • Looking into HTF, private loans, and other sources
  • If same as Round I, there will be over 3,000 households affected in Round II
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CDBG Disaster Program Challenges

Program Challenges – Duplication of Benefits

  • RECOMMENDATION TO HUD:
    • Rather than dollar-for-dollar reduction from SBA loans, clarify for all states that DOB equals the amount of interest savings from SBA’s below market interest rates.
    • Allow proof of expenditures for any eligible FEMA assistance category to “credit” against DOB. For example, if a household is provided $5,200 for home repairs, and can prove that they spent $8,000 on other eligible FEMA cost categories (such as personal property, medical, dental, etc.), no duplication of benefit.
    • Federal database of previous and current disaster funding for DOB checks.
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CDBG Disaster Program Challenges

Program Challenges – Floodplain

  • TDHCA originally planned to provide grants only
  • 42 U.S.C. 5154a requires the maintenance of flood insurance on assisted properties, regardless of property transfer
    • For loans, evidence of coverage must be continued for the term of the loan
    • For grants, evidence coverage must be continued for the life of the property
  • Grantees are required to maintain a complete, up-to-date listing evidencing coverage
  • TDHCA opted to loan funds when assistance will be in the floodplain
    • 3-year, zero percent interest, deferred forgivable loan
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