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1st Edition: 12/30/13-1/6/14
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Reno & Cavanaugh's Housing Notices Newsletter contains weekly notices, proposed rules and relevant information on HUD policy and regulations. For more information, please visit www.renocavanaugh.com and R&C's Housing Policy Group's webpage. |
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Happy New Year!
We will be back on our regular Friday newsletter schedule starting this Friday. The following are notices from 12/30/2014-1/6/2014. |
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News of Note:
1. R&C Closes the First RAD "Mixed-Finance" Conversion. During the busy holiday season, R&C attorneys closed the first conversion of an existing public housing mixed-finance project, Ashford Landing, under HUD's Rental Assistance Demonstration (RAD) program. A second, similar conversion, Ashford Parkside, will close within a few days. Both projects were sponsored by the Housing Authority of Dekalb County, Georgia, whose affiliates are also the general partners of the project owners. Ashford Landing involves 36 units of elderly public housing as part of a 117-unit low-income housing tax credit project. Ashford Parkside involves 30 units of elderly public housing in a 151-unit tax credit project. The original transactions closed in 2008 and 2006, respectively, and in addition to both federal and state tax credit equity, included private first mortgage financing and subordinate financing from HADC's public housing funds. Through these RAD conversions, Section 8 project-based voucher (PBV) assistance replaces public housing ACC subsidies. R&C worked with HUD, the current investors and lenders, and other parties to conform the existing mixed-finance documents to RAD requirements, as needed. HADC believes that this swap in subsidy and program platform will enhance both projects' cash flow and stability for the remainder of the tax credit compliance period and beyond.
2. The IRS has issued updated procedures for reinstating the tax-exempt status of organizations that have had their tax-exempt status automatically revoked for failure to file required Annual Returns or notices for three consecutive years. While the guidance does not specifically discuss public housing authority (PHA) instrumentalities, this guidance may be helpful to PHAs whose instrumentalities have lost their Section 501(c)(3) tax-exempt status for failure to file their Form 990s.
3. EPC Section 30 Guidance. HUD recently released an Energy Performance Contract (EPC) Section 30 Reviews and Approvals Guidebook that provides guidance on streamlined Section 30 approvals, updated forms and other information for PHAs that wish to encumber PHA property as part of their EPC transactions.
4. PIH 2013-28: Guidance to PHAs on the Use of Outside Sources of Funds for Housing Assistance Payments (HAP) expenses in the Housing Choice Voucher (HCV) Program. |
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H O U S I N G N O T I C E S
12/30/2013 - 1/6/2014 | |
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NAME OF NOTICE |
TITLE |
ISSUE DATE OR PAGE NUMBER |
INFORMATION | |
CPD Notices |
No new notices |
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PIH Notices |
No new notices |
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Housing Notices |
No new notices |
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Mortgagee Letters |
Delay in Effective Date for Home Equity Conversion Mortgage (HECM) Financial Assessment Requirements and Funding Requirements for the Payment of Property Charges |
13-45
Issued: December 20, 2013 |
In Mortgagee Letters 2013-27 and 2013-28, HUD issued guidance to HECM mortgagees regarding Financial Assessment Requirements and Funding Requirements for the Payment of Property Charges. The effective date for compliance with those requirements was for new HECM case numbers assigned on or after January 13, 2014.
HUD received comments after publishing the Mortgagee Letters and its Notice in the Federal Register. As a result, HUD is updating its HECM Financial Assessment Requirements and Funding Requirements for the Payment of Property Charges. HUD will issue updated guidance by Mortgagee Letter and the new guidance will be effective for HECM case numbers assigned no sooner than ninety days from the date of the Mortgagee Letter. | |
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FHA's Tier Ranking System II; Final Notice and Responses to Comments |
13-46
Issued: December 30, 2013 |
Announces the implementation of FHA's Tier Ranking System II (TRS II) and to provide responses to public comments. TRS II will be used to evaluate a mortgagee's compliance with FHA's Loss Mitigation guidance, default servicing regulations, and default reporting requirements. | |
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Federal Register Notices | |
Rules and Regulations |
Partial Section Eight Management Assessment Program (SEMAP) Indicator Waiver; Family Self-Sufficiency (FSS) Program Demonstration |
PDF | Text | More
Issued: December 30, 2013
Pages 79310 - 79312 |
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Proposed Rules |
No new notices |
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Notices |
60-Day Notice of Proposed Information Collection: Certification of Domestic Violence, Dating Violence, Sexual Assault, or Stalking |
PDF | Text | More
Issued: December 26, 2013
Pages 78375 - 78376 |
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60-Day Notice of Proposed Information Collection: Exigent Health and Safety Deficiency Correction Certification |
PDF | Text | More
Issued: December 26, 2013
Pages 78376 - 78377 |
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60-Day Notice of Proposed Information Collection: HUD Environmental Review Online System (HEROS) |
PDF | Text | More
Issued: December 27, 2013
Pages 78998 - 78999 |
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60-Day Notice of Proposed Information Collection: Consolidated Public Housing Certification of Completion |
PDF | Text | More
Issued: December 27, 2013
Pages 78999 - 79000 |
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60 Day Notice of Proposed Information Collection for Public Comment: Reporting for HUD Research, Evaluation, and Demonstration Cooperative Agreements |
PDF | Text | More
Issued: December 30, 2013
Pages 79473 - 79474 |
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30-Day Notice of Proposed Information Collection: Father's Day |
PDF | Text | More
Issued: December 30, 2013
Pages 79474 - 79474 |
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30-Day Notice of Proposed Information Collection: The Impact of Housing and Services Interventions on Homeless Families-36-Month Follow-Up Data Collection |
PDF | Text | More
Issued: December 30, 2013
Pages 79475 - 79476 |
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60-Day Notice of Proposed Information Collection for Public Comment: Applications for HUD Research, Evaluation, and Demonstration Cooperative Agreements |
PDF | Text | More
Issued: December 30, 2013
Pages 79476 - 79476 |
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Announcement of Funding Awards, Choice Neighborhoods Grant Program, Fiscal Year 2013 |
PDF | Text | More
Issued: December 30, 2013
Pages 79477 - 79478 |
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60-Day Notice of Proposed Information Collection: Congressional Earmark Grants |
PDF | Text | More
Issued January 6, 2013
Pages 660 - 661 |
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For more information about the attorneys at Reno & Cavanaugh, please follow this link.
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Compiled by Reno & Cavanaugh, PLLC. This newsletter is intended for informational purposes and should not be viewed as specific legal advice. The sources cited above include tested links that lead to external websites. By sending these links in the newsletter, Reno & Cavanaugh does not claim any affiliation with or opinion of the external websites or the content there within. Except for your personal use (such as forwarding this newsletter), the contents of this newsletter may not be reproduced, transmitted, or distributed without the express written consent of Reno & Cavanaugh. If you have questions about the newsletter or would like to subscribe, please email inquiry@renocavanaugh.com or click "Subscribe" above.
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