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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

HUD Multifamily Housing Compliance

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

May 10-11, 2007

slide2
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
slide3
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!
slide4
Administrative Issues
  • Flags
  • LDP
  • Suspension And Debarment -- EPLS
slide5
*

Regulatory Requirements

  • Audits, Inspections, Reviews
  • Tax Credits -- 8823s Follow HUD Handbook 4350.3 Plus New 8823 Guide
slide6
2530 – Previous Participation Review
  • 24 CFR Part 200 Subpart H
  • Plus Memos, Unpublished “Lore”
slide7
Key Concepts
  • MPRC Process
    • Principles
    • Properties
    • Officers
    • GPs
    • LPs
    • LLCs
    • Baseline
slide8
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
slide9
*

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
slide10
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
slide11
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
slide12
USE AGREEMENTS
  • Vary Widely – Seen Only In Some Programs, Such As
    • Flexible Subsidy Program
    • Property Dispositions
    • Non-Profit Prepayments
slide13
*

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
slide14
*

YOUR FHA LOAN IS NONRECOURSE – SORT OF

  • REACs
  • MOR
  • Integrity Of Site Records
  • Managers – Good Samaritan Can Hurt
  • Use Agreements
slide15
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!