Transcription
U. S. DEPARTMENT OF HOUSING ANDURBAN DEVELOPMENTCAPITAL FUND GUIDEBOOK TRAININGCAPITAL FUND GUIDEBOOKAN INTRODUCTION24 CFR PART 905INTRODUCTIONS Trainers Local HUD Field Staff Public Housing Agencies (PHAs)National Training Center21
OVERALL TRAINING OBJECTIVESBy the end of this training, you should: Understand the key changes of the Capital Fund program,based on the Final Rule. Know eligible and ineligible activities under the CapitalFund program. Understand the annual Capital Fund submissionrequirements and how the funds will be distributed byHUD. Understand how the Capital Fund Formula is allocated andyour requirements for certification within the PIHInformation Center (PIC). National Training Center3OVERALL TRAINING OBJECTIVES Describe the changes in the Replacement Housing Factor(RHF) grant program, including Demolition and DispositionTransitional Funding (DDTF).Identify the general program requirements of the CapitalFund.Know the requirements for obligating and expendingCapital Funds, how to process budget amendments, andwhen to perform close‐out activities.Understand the requirements of the emergency, non‐presidentially declared natural disaster and safety andsecurity grants.National Training Center42
OVERALL TRAINING OBJECTIVES Describe the key components of public housingdevelopment.Understand the basic relationship of the RAD and MTWdemonstration programs to the basic Capital FundProgram.Know the requirements for providing a primary securityinterest and financing activities allowed under the CapitalFund Program.Appreciate the penalties and sanctions within the programfor non‐compliance.National Training Center5LOGISTICS Training Packets and Materials Questions Breaks Agenda Overall Training and Site LogisticsNational Training Center63
CHAPTER 1: BACKGROUND ANDINTRODUCTIONCHAPTER 1: TOPICS Capital Fund Program Overview Changes Based on the Capital Fund Final Rule84
CAPITAL FUND BASICS U.S Housing Act of 1937 Development No subsidies ‐ just low rentsU. Brooke Amendment ‐ 1968 No more than 25% originally, later 30% of low incomefamilies income in rent Modernization (CIAP) and Operating subsidies added CIAP application based program9CAPITAL FUND BASICS, CONTINUED Comprehensive Grant Program (CGP) ‐ 1993 PHAs 250 and more Small PHAs continue to receive CIAPU. Quality Housing and Work Responsibility Act (QHWRA) ‐ 1998 Public Housing Agency (PHA) Plan Capital Fund Operating Fund105
TYPES OF CAPITAL FUNDS Formula Replacement Housing Factor (RHF) Demolition and Disposition Transitional Funding (DDTF) Emergency and Non‐Presidentially Declared Natural Disaster Emergency Safety and Security Capital Fund Education and Training Community Facilities(CFCF)11WHAT IS THE CAPITAL FUND RULE/GUIDEBOOK TRYINGTO ACCOMPLISH? More effective use of Capital Funds by PHAs and residentsthrough increased understanding of program requirements; More efficient and consistent management of Capital FundProgram by HUD Headquarters and Field Offices; Increased use of funds for modernization given the limited fiscalenvironment; and Use of Capital Funds to better address energy efficiency.126
BACKGROUND Final regulation combines and streamlines former legacyprograms into the Capital Fund Program: Original limited Capital Fund (24 CFR 905) – only included theformula and eligible expenses Modernization programs (24 CFR 968) Public Housing Development (24 CFR 941) Mixed Finance Development (24 CFR 941 subpart F)Capital Fund Final Rule incorporates Capital Fund FinancingProgram (CFFP) requirements at 24 CFR 905.500, Subpart E13Capital Fund Rule – BenefitsBEFORECGP(RULE PUBLISHED)StatutesCIAPStatutesPDEVPHAs mustsearch differentHUDregulations andmultiple statutesStatutes147
Capital Fund Rule – BenefitsAFTER(RULE PUBLISHED)CGPPDEVCIAPCFPStatutes(one source)15Capital Fund Rule – Benefits NEW! Decouples (Separates) CapitalFund submission requirements from thelarger PHA plan requirements NEW! PHAs now receive Demolition andDisposition Transitional Funding (DDTF)instead of Replacement Housing Factor(RHF) funds NEW! Focuses on more comprehensivestrategic planning for the future byadopting standards for physical needsassessments168
Capital Fund Rule – Benefits NEW! Focuses use of Funds on PhysicalImprovementsNEW! Simplifies Mixed‐Finance (combinedPublic/Private) Finance RequirementsNEW! Allows TDC exception forCost Saving Energy Initiatives17Capital Fund Rule – Modification to Part 903 PHA Plan Rule ‐ § 903.3 modified to add a definition of aQualified PHA A Qualified PHA is: One with 550 or fewer publichousing units/HCVs Not troubled or have a failingSEMAP score in the past 12months189
WRAP UP AND QUESTIONS10
U. S. DEPARTMENT OF HOUSING ANDURBAN DEVELOPMENTCAPITAL FUND GUIDEBOOK TRAININGELIGIBLE ACTIVITIES (CHAPTER 2)CHAPTER 2: TOPICS Eligible Activities Ineligible Activities Costs and Other Limitations21
ELIGIBLE ACTIVITIESELIGIBLE CAPITAL FUND ACTIVITIES Eligible activities in 24 CFR 905.200 Specified in an approved 5‐Year Action Plan Approved by HUD for emergency/natural disaster Identified in a Moving to Work (MTW) Agreement42
WHAT IS A BUDGET LINE ITEM (BLI)? Budgets have specific accounts which HUDcalls "Budget Line Items (BLIs)". PHAs must classify eligible expenses into oneof the HUD defined BLIs in their budgets.5BLI QUICK REFERENCE CHARTCapital Fund ActivityTransfer to OperationsManagement ImprovementsEconomic Self‐Sufficiency (soft cost)Administrative CostsCapital Fund Program FeeAuditFees and Costs, LegalFinancing CostsHomeownershipForce Account LaborSafety and SecurityEconomic Self‐Sufficiency 01430BLI for associated activity*BLI for associated activity*BLI for associated activity*BLI for associated hard costactivity*63
BLI QUICK REFERENCE CHARTCapital Fund ActivityBLIPhysical Needs Assessment & Energy AuditSite Acquisition14301440Site ImprovementDwelling StructureDwelling equipment, nonexpendableNondwelling structures1450146014651470Nondwelling equipmentDemolitionResident Relocation and Mobility CounselingDevelopment1475148014951499CFFP Debt Service PaymentsRAD1501 (by PHA) 9000 (byLOCCS)1503 and 15047ELIGIBLE ACTIVITY: DEVELOPMENTEligible Development CostsConstruction and acquisition with or without rehabilitationDevelopment of Mixed-Finance Projects,Resident consultation and meetingsEnvironmental reviewConsultants necessary for any public housing aspect of the projectInitial operating period expenses – lease up, initial occupancyPredevelopment and planning costs for public housingSite preparation, abatement, demolition, water/gas distribution systems, siteand infrastructureCost certification costsDevelopment activity financing costsAmenity structures and fixture costs including parking lots and laundryProject specific administrative costs, within Section 2.4 limitsPhysical Needs Assessment (PNA)84
ELIGIBLE ACTIVITIES: FINANCINGEligible Public Housing Financing CostsPreparing applications for funding (e.g. Choice Neighborhoods andLIHTC)Legal services for PHAConstruction period interestDue diligence, such as market study and environmental testingFairness opinionOther development and modernization activities needed to obtainfinancing9ELIGIBLE ACTIVITIES: MODERNIZATION‐PHYSICALWORKModernization – Physical WorkDemolitionReconfigurationPlanningSite AcquisitionSite ImprovementRelated dwelling structuresDwelling equipmentNon-dwelling structureNon-dwelling equipmentDemolition for a PH modernization or development project105
ELIGIBLE ACTIVITIES: MODERNIZATION – NON‐DWELLING EQUIPMENT ‐ VEHICLESModernization – Non-dwelling equipmentPurchase or Lease of vehiclesNon-passenger vehiclesPassenger vehicles11PREMATURE REPLACEMENT Must use public housing facilities and relatedequipment for the entire useful life. Premature replacement is limited to circumstanceswhere a cost analysis shows it is cost effective,based on a simple 10 year payback.126
QUESTIONSELIGIBLE ACTIVITIES: MODERNIZATION‐EMERGENCY WORK Capital Fund‐related activities identified as EmergencyWork. Upon determining the need for Emergency Work, PHAshould perform the work147
ELIGIBLE ACTIVITIES: ENERGY EFFICIENCYEnergy Efficiency WorkNew or updated Energy Audits – only when audit part of Capital Fundprogram and not otherwise covered by Operating Funds.Implementation of energy and water conservation per Energy AuditIntegrated utility management and capital planningInstallation of energy/water-use efficiency fixtures and fittingsInstallation and use of Energy Star appliances – part of replacementprogramAutomation of utility & energy management systems – master toindividual metering if installed as a part of a mod. activity to upgradeutility systems15ELIGIBLE ACTIVITIES: NON‐ROUTINEMAINTENANCE Work items ordinarily performed regularly in the course ofproperty management and maintenance, but nowsubstantial in scope and expense due to postponement.Note: Avoid premature replacement unless payback analysisindicates it is more cost‐effective.168
ELIGIBLE ACTIVITIES: PLANNED CODECOMPLIANCE.Planned Code ComplianceLocal building code or the Uniform Physical Condition Standards(UPCS) under PHASNational building code, such as those developed by theInternational Code Council or the National Fire ProtectionAssociation2009 International Energy Conservation Code (IECC), or ASHRAEstandard 90.1-201017ELIGIBLE ACTIVITIES: VACANCY REDUCTION Physical improvements to reduce number of vacant publichousing units Vacancy reduction activities must remedy a defined vacancyproblem detailed in the PHA’s 5‐Year Action Plan.189
VACANCY REDUCTION EXAMPLEProject 19‐001100 units 20 units chronically vacant due todeferred long and short termmaintenance. Management deficiencyPlan calls for: Team 3 (supervisor and two maintenance staff) PHA staff (Force Account).Assessment of physical needs of each unit.Preparation of a scope of work and cost estimates for each unit.Schedule of work for each unit.Purchase of all supplies and materials.Implementation: 2 units per week for 10 weeks.19GENERAL ELIGIBLE ACTIVITIES: SOFT COSTSSoft CostEconomic Self-SufficiencySafety and SecurityManagement ImprovementsTraining and Technical Assistance (TA)Resident Relocation/Mobility Counseling Dueto CF ActivityNote: Capital Funds may not be used to fund the salaries andbenefits of security guards or ongoing security costs.2010
ELIGIBLE ACTIVITIES: OTHER COSTSOther CostAdministrative Costs/Capital Fund Program Fee (CFP Fee)AuditLegalHomeownershipNote: CFP Fee does not cover costs for construction,supervisory, and inspection functions that are front‐lineproject costs.21[DISCUSSION Is the Community Building only for Section 8 Residents aneligible cost? Community Building for both Section 8 and PH residents? A new boiler for a public housing project? A new boiler for a Section 8 project? The cost of implementing a Section 3 program for thePHA?2211
[DISCUSSION A new roof on a public housing project? A new truck for the PHA Capital Fund Director? The cost of energy improvements included in an EnergyPerformance Contract? The daily cost of PHA Police? Physical improvements included in a defined vacancyreduction.23QUESTIONS12
INELIGIBLE ACTIVITIESINELIGIBLE ACTIVITIES Not Related to Public Housing Not in 5‐Year Action Plan Fail to meet OMB Circular A‐87/2 CFR Part 200 requirements An otherwise eligible cost that is funded by another sourceand would result in duplicate funding Other Activities and Costs that HUD may deny case‐by‐case2613
INELIGIBLE ACTIVITIES, CONTINUEDActivities/CategoriesNot Modest DesignOperating AssistanceBenefitting Other ProgramsOn-going Security ServicesSupportive Services27DISCUSSIONAre these Eligible or Ineligible Activities? Training Security Guards on new systemsSecurity Guard SalariesWhirlpool BathtubsThe full cost of a vehicle used for both HCV and the Capital FundProgramsCosts for the portion of the annual audit covering the CapitalFund ProgramHiring a social workerSecurity Cameras2814
MOVEMENT BREAK/QUESTIONSCOST AND OTHER LIMITATIONS15
COST AND OTHER LIMITATIONSCategoriesLimitationAllocation of Costswith Other ProgramsAmount directly attributable to publichousing program even if other programsbenefit.Modernization CostsUnder 90% of published TDC/ ReasonableCost.AdministrativeCosts/CFP FeeUp to 10% for non-asset management (AM)PHAs. CFP Fee - percentage of the annualCapital Fund formula grant(s) amount withexclusions for AM PHAs.Development3% of the total project budget, or, withHUD’s approval, up to 6%31COST AND OTHER LIMITATIONS, CONTINUEDCategoriesLimitationModernization FeeCapNo more than 10%.Force AccountLabor (includingmaterials andequipmentMust be in a 5-Year Action Plan. HUDapproval PHAS Standard Performers andbelow.Total DevelopmentCost (TDC)the maximum amount of Public HousingCapital Assistance for use for HCC andCommunity Renewal Costs on a Project,absent a waiver from HUD.3216
COST AND OTHER LIMITATIONS, CONTINUEDCategoriesLimitationTDC LimitExceptionsMay request and exception to the TDC limitfor select activities associated with energyefficiency and conservation.RMC ActivitiesNo Capital Funds for any administrative orother reason when entire developmentproject is RMC run, unless under contractwith PHACommunity RenewalCostsWhere the maximum amount is thedifference between allowed TDC andcalculated HCC.33COST AND OTHER LIMITATIONS, CONTINUED Management Improvement Cost Limits 10%, annual reductions fortransition period per chart.FY% Allowed201418%201516%201614%201712%2018 Forward10%3417
COST AND OTHER LIMITATIONS, CONTINUED Capital Funds identified for operations are obligated once the fundshave been budgeted and drawn down.Once funds are transferred, PHAs must follow the requirements of 24CFR Part 990 – the Operating Fund Rule.PHA CategoryBLI 1406 Cost LimitLarge PHA (250 units)20% of CFP GrantSmall Non-troubled PHA (1-249units)100% of CFP GrantSmall Troubled PHA (1-259units)20% of CFP Grant35QUESTIONS18
KNOWLEDGE CHECK: QUESTION #1How much can a PHA that has 150 units and is designatedas troubled transfer to BLI 1406 Operations?37KNOWLEDGE CHECK: ANSWER #1Small non‐troubled PHAs may transfer up to 100%. Sincethe PHA is troubled, HUD must approve any transfer. HUDwill consider the reasons for its troubled status as well ascurrent need for Capital Improvements.3819
KNOWLEDGE CHECK: QUESTION #2For Development work with Capital Fund and RHF grants,what is the administrative cost limit chargeable by anasset management PHA without HUD approval?39KNOWLEDGE CHECK: ANSWER #23% of the total project budget, or, with HUD’s approval,up to 6% of the total project budget4020
KNOWLEDGE CHECK: QUESTION #3Does the HCC limit apply to the rehabilitation of PublicHousing Projects?41KNOWLEDGE CHECK: ANSWER #3No except for Mixed Finance Modernization.4221
KNOWLEDGE CHECK: QUESTION #4List an example of an activity that qualifies for a TDCexception.43KNOWLEDGE CHECK: ANSWER #4Emergency Work;Essential maintenance necessary to keep a Public HousingProject habitable until a demolition or dispositionapplication is approved; orThe costs of maintaining the safety and security of a sitethat is undergoing demolition.4422
WRAP UP AND QUESTIONS23
U. S. DEPARTMENT OF HOUSING ANDURBAN DEVELOPMENTCAPITAL FUND GUIDEBOOK TRAININGPLANNING, ANNUAL SUBMISSION ANDDISTRIBUTION OF FUNDS (CHAPTER 3)CHAPTER 3: TOPICS Planning Capital Fund Submission and Amendments Fund Disbursement21
CHAPTER OVERVIEW PHAs are responsible for the long term physical andfinancial viability of the PHA and their properties. The Capital Fund plays a pivotal role in financing activitiesto achieve the PHA’s mission and goals.3CAPITAL FUND PROGRAM (CFP) ANNUAL FORMULAGRANT PROCESS 45 DayNotice PublicHearing &ResidentAdvisoryBoard (RAB)Consultation BoardResolution IMS/PICCertification DUNSNumber andCurrent SAMRegistration PhysicalNeedsAssessment(PNA) AnnualContributionsContract (ACC)Amendment(s) Performance andEvaluation Report(P&E Report) 5-Year ActionPlan Statement ofSignificantAmendment AdditionalCertifications Field Office (FO)confirmsEnvironmentalRequirements are met Executes ACCAmendment andmaintains CFPrequired paperworkfor recordsmanagement Spreads initial budgetin the Line Of CreditControl System(LOCCS) and respreads Budget LineItems (BLI) accordingto HUD approvedbudget Maintainingobligations withinBLI thresholds LOCCS Monthlyreporting EPIC annualreporting Annual Performanceand Evaluation(P&E) Report Obligation End Date(OED) 90%Obligated within 24Months of OSD Disbursement EndDate (DED) 100%Disbursed within 48Months of OSDPHA Submits AMCC or ADCCand P&E Report Includes AMCC and P&EReport in Audit, ifnecessary Monthly LOCCS until“Pre-Audit” statusField Office Reviews, ApprovesAMCC/ADCC and P&EReport Enters Pre-Audit Date inLOCCS Transmits completedClose out package toCFO Ft. Worth AccountingCenter to place grant inPost Audit Status inLOCCS42
PLANNINGCAPITAL FUND GRANT PLANNING REQUIREMENTS Physical Needs Assessment Energy Audit 45 Day Notice Public Hearing & RAB Consultation Board Resolution approving 5‐year action plan IMS/PIC Certification DUNS renewal in SAM63
PLANNING: PHYSICAL NEEDS ASSESSMENT (PNA) A PNA identifies all of the work that a PHA needs toundertake to bring each of its developments up to theapplicable modernization and energy conservationstandards.7PLANNING: PNA, CONTINUEDPNA Rule ‐ Public Housing: Physical Needs AssessmentProposed Rule, 76 Federal Register 43219 (July 20, 2011) Requires PHAs to conduct a PNA every 5 years incoordination with the Energy Audit An annual updated submission of the PNA data will likelyalso be required, timed to the PHA’s fiscal year. Failure to submit PNA data will trigger CFP Final Rulesanctions including withholding of Capital Funds.84
PLANNING: PNA – WHERE ARE WE NOW?Section 233 of the FY 2015 HUD Appropriations Act Prohibits HUD from requiring PHAs to conduct a PNAduring FY 2015 and prohibits HUD from enforcing a PNArequirement in FY 2015. Does not prohibit the use of Capital Funds or OperatingFunds by a PHA to perform a voluntary PNA.9PLANNING: ENERGY AUDIT Energy Audit identifies the types and costs of PHA energyuse for “use analysis” and identification of cost reductionalternatives. Currently required by 24 CFR Part 965, all PHAs must conductan energy audit every 5 years.105
PLANNING: ENERGY AUDIT, CONTINUEDProposed Rule ‐ Public Housing Energy AuditsProposed Rule, 76 Federal Register 71287 (Nov. 17, 2011) Requires PHAs to complete an Energy Audit at least onceevery 5 years for each PHA‐owned project. Proposes Energy Conservation Measures (ECMs) PHAsmust consider, at a minimum, when performing an energyaudit.11QUESTIONS6
PLANNING: PUBLIC HEARING Hold a public hearing regarding the proposed Capital FundSubmission. Meet and consult with RAB. Capital Fund Submission must include copy of RABrecommendations and how PHA addressed them.PHA may not fund work items not approved by this process.13PLANNING: BOARD RESOLUTION PHA must have a copy of a Board Resolution on fileapproving its 5‐Year Action Plan. May use the public hearing and board resolution from itsmost recent 5‐Year Action Plan if no current Board meetingheld. PHA may not access reserved Capital Funds until boardresolution provided to HUD and HUD approval provided.147
PLANNING: IMS/PIC DATA CERTIFICATION Each year, PHA must certify data accuracy in the InventoryManagement System/Public Housing Information Center(IMS/PIC). The Capital Fund formula is based on unit information inIMS/PIC . HUD may suspend access to all Capital Fund LOCCS accountsfor that year until IMS/PIC certification complete.15PLANNING: IMS/PIC DATA CERTIFICATION HUD will run the formula based on uncertified data issue an ACC Amendmentsuspend grant until certification completeHUD will not increase funding amount after calculation basedon uncertified dataIncorrect or Untimely Data Incorrect/Less Capital Funding168
PLANNING: DUNS NUMBER AND CURRENT SAMREGISTRATIONSAM, formerly Central Contractor Registration or CCR: PHAs must update SAM annually. HUD will suspend access to Capital Funds withoutcurrent SAM registration.17REJECTION OF CAPITAL FUND GRANTS To reject a Capital Fund Grant (including RHF) a PHA must: Submit a written statement from the Executive Director tothe FO – grant # and dollar amount. Hold Board Resolution for the Capital Fund rejection on file.FO will hold grant in reserve for 90 days after Capital FundSubmission date, then the grant will no longer be available tothe PHA.189
CAPITAL FUND PLANNING CHECKLISTPlanning ActionYesN/APhysical Needs Assessment (PNA)Energy Audit (complete within 5 years)Public Hearing (45 day notice)RAB ConsultationCertification of IMS/PIC DataBoard Resolution Approving 5-Year ActionPlanDUNS NumberCurrent SAM Registration19QUESTIONS10
KNOWLEDGE CHECK: QUESTION #1Are all PHAs required to conduct a physical needsassessment (PNA)?21KNOWLEDGE CHECK: ANSWER #1Only PHAs with 250 units or more are required to have aPNA, until further guidance is issued.2211
KNOWLEDGE CHECK: QUESTION #2How often are PHAs required to conduct an Energy Audit?23KNOWLEDGE CHECK: ANSWER #2PHAs are required to conduct an Energy Audit every 5years.2412
KNOWLEDGE CHECK: QUESTION #3Once a PHA certifies its building and unit characteristics inIMS/PIC, is it required to recertify only when changesoccur?25KNOWLEDGE CHECK: ANSWER #3PHAs must recertify every year in accordance with theHUD schedule.2613
CAPITAL FUND SUBMISSION ANDAMENDMENTSCAPITAL FUND SUBMISSIONDocumentACC Amendment5-Year Action Plan/BudgetP&E ReportStatement of Significant AmendmentAdditional Certifications2814
CAPITAL FUND SUBMISSIONACC Amendments: Three originals, signed and datedYesN/AYesN/AYesN/AYesN/AYesN/AACC Amendment for Capital Fund formula grantACC Amendment for First Increment RHF GrantACC Amendment for Second Increment RHF GrantCFP Budget and Capital Fund 5-Year Action PlanCFP Budget (Form HUD-50075.1 (Parts I and II))5-Year Action Plan (fixed or rolling) (Form HUD-50075.2)P&E Report (Form HUD-50075.1), if troubled or not in compliance with 24 CFR §905.306Statement of Significant AmendmentCertificationsLobbying Form – SFLLLCertification of Compliance w/Public Hearing: (copy of one of the following)Non-Qualified PHAs - Form HUD-50077(1) Qualified PHAs - A statement certifying that the PHA conducted a public hearing incompliance with 24 CFR Part 905, signed and dated by the executive director.Certification of Payments to Influence Federal Transactions (Form HUD-50071)Civil Rights Certification (copy of one of the following)(1) Non-Qualified PHAs - Form HUD-50077(2) Qualified PHAs - Form HUD-50077-CROtherRecommendations made by the RAB(s) and a description of how the PHA will address therecommendations (if applicable)Board Resolution approving 5-Year Action Plan (if PHA is troubled)Environmental ReviewNot submitted, but on file at the PHAEvidence of Completion of Environmental Review for proposed activitiesPhysical Needs Assessment (PNA)Energy Audit (every 5 years)29AMENDING 5‐YEAR ACTION HA BoardapprovesamendmentHUD reviewsamendmentNoNo HUDapprovalneededPHA implementsamendment uponHUD approval3015
SIGNIFICANT AMENDMENTS After "the approval process" is complete, the PHA mayamend the CF 5‐Year Action Plan at any time. It must go through "the approval process" again if itconstitutes a significant amendment The minimum definition of significant amendment does notinclude addition of new work items. Remember: A PHA can not add new work items without RABcomments and a public hearing.31DECOUPLING CAPITAL FUND SUBMISSION ANDPHA PLAN PHAs that submit Annual Plans must include “statement ofcapital improvements needed” in Annual Plan not copy of 5‐Year Plan. Must reference most recently approved 5‐Year Action Planin Annual PHA Plan Approved 5‐Year Action Plan included in public hearingmaterials. FO does not review 5‐Year Action Plan in Annual Planreview.3216
DECOUPLING CAPITAL FUND SUBMISSION ANDPHA PLAN While “decoupled from the actual PHA Plan,” the Capital Fund stillplays a pivotal role in financing activities to achieve the PHA’smission and goals The PHA should examine the PNA and EA in conjunction with itsoverall Capital planning and determine priorities and futureCapital Activity (demo/dispo, redevelopment with tax credits,RAD, maintain inventory‐modernize)33QUESTIONS17
KNOWLEDGE CHECK: QUESTION #4When should a Significant Amendment be used?35KNOWLEDGE CHECK: ANSWER #4A significant amendment should be made when, at aminimum, a demolition, disposition, homeownership,CFFP, development, RAD or a mixed finance transactionhas occurred that was not previously approved in the 5Year Action Plan.3618
KNOWLEDGE CHECK: QUESTION #5Are all PHAs required to submit a Performance andEvaluation Report (P/E) with its Capital Fund annualsubmission?37KNOWLEDGE CHECK: ANSWER #5Only troubled PHAs must submit the P/E with the annualsubmission. Non‐troubled PHAs prepare the P/E butmaintain in its files unless requested by HUD3819
FUND DISBURSEMENTLOCCS INITIAL BUDGETLOCCS Initial BudgetBLI 0100‐ReservedBudget72% of the grant authorizedamountNotdisbursableContact Field OfficeBLI 1408‐ManagementImprovements2014 – 18%DisbursableAuto‐review ifgreater than thepercentagepermitted for thefiscal year.DisbursableAuto‐review ifgreater than 10%2015 – 16%2016 – 14%2017 – 12%2018 and later – 10%BLI 1410‐AdministrativeCosts10% of grant authorizedamount4020
LOCCS INITIAL BUDGET & ENVIRONMENTAL REVIEW Must complete Environmental Review (ER) prior to PHAobligation/expenditure of funds. Site‐Specific Planning Activities can be funded prior to completionof a full ER. Field Office can review request for current year Capital Funds foractivities and work items in 5‐Year Plan and part of a completedER. Other Activities ‐ PHA must complete all necessary ERs beforesubmitting draw request documentation to Field Office.41DISBURSEMENT OF CAPITAL FUNDSOnly when suchfunds are due &payablePHARequisitionsCapital FundsFO UpdatesBudget LineItemFOFOVerifiesVerifies ERERisis completecompletePHA VouchersExpense/FO VerifiesERDrawsDown fromis completeLOCCSFORejectsRequestFO NotifiesPHA inWritingFOReviewsRequestFO ApprovesRequest inWritingPHA MustExpend in 3BusinessDaysPHA ShowProgress ofCF Activities4221
MTW PHAS Standard MTW Agreement establishes planning, annualsubmission, and distribution of funds requirements. Submit Annual MTW Plan and Annual MTW Report. Timing and contents established by MTW Agreement.43KNOWLEDGE CHECK: QUESTION #6Can a PHA drawdown funds without completing anEnvironmental Review?4422
KNOWLEDGE CHECK: ANSWER #6A PHA may only drawdown Administrative Costs (BLI1410)and /or Management Improvements (BLI1408).45KNOWLEDGE CHECK: QUESTION #7Is the entire budget spread by HUD in LOCCS when annualCapital Funds are awarded?4623
KNOWLEDGE CHECK: ANSWER #7No, the annual Capital Fund grant is initially spread asfollows:BLI 1408 – 14% in 2016BLI 0100 – 76% of the grantBLI 1410 – 10% of the grantBLI 1408 decreases by 2% each year in 2017 and 2018, and BLI0100 increases by 2% each year in 2017 and 2018.47WRAP UP AND QUESTIONS24
U. S. DEPARTMENT OF HOUSING ANDURBAN DEVELOPMENTCAPITAL FUND GUIDEBOOK TRAININGCAPITAL FUND FORMULA CALCULATION(CHAPTER 4)CHAPTER 4: TOPICS General Capital Fund Formula Overview How Can PHAs Ensure Capital Fund Grant Accuracy? PIC/IMS Certification Review Faircloth Limits Review High Performer ListWhat should PHAs do after Capital Fund grantannouncements?21
GENERAL CAPITAL FUND FORMULAOVERVIEWFORMULA OVERVIEW The Capital Fund Formula calculates annual Capital Fundgrant awards including formula grants, DemolitionDisposition Transitional Funding (DDTF), and ReplacementHousing Factor (RHF). The formula allocates to each PHA a share of the fund. Shares are calculated with mathematical formulas describedin 24 CFR 905.400.42
FORMULA OVERVIEW, CONTINUED Grant calculations rely on development and unit inventoryinformation from IMS/PIC. PHAs are responsible for submitting accurateinformation in the IMS/PIC system and certifyingannually.Grant calculations also rely on additional data sources.Data drives the formula, so data accuracy is key!5HOW ARE CAPITAL FUND GRANTS CALCULATED? HUD calculates each PHA’s share of capital funds using themathematical formulas described in 24 CFR Part 905.400.50% ExistingModernizationNeed50%AccrualNeed63
CALCULATION OF EXISTING MODERNIZATION NEED 24 CFR 905.400(c) outlines the calculation of existingmodernization need. However, 905.400(d)(6) freezes the calculation at FFY 2008levels, adjusted for changes in inventory and for the costindex of rehabilitating property in the area. Units with a Date of Full Availability (DOFA) date of October1, 1991, or after are considered to have no existingmodernization need.7CALCULATION OF ACCRUAL NEED 24 CFR 905.400(e) outlines calculation of accrual need. The regulation details 3 different calculations: The per‐unit accrual need for New York City Housing Authorityand Chicago Housing Authority is set in regulation. Calculation for PHAs with less than 250 units (“Small PHAs”). Calculation for PHAs with 250 or more units (“Large PHAs”).* Only used for PHAs greater than 250 units.84
CALCULATION OF ACCRUAL NEED, CONTINUED These variables are used for small and large PHAs:Average number of bedrooms in the units in a development.B. The extent to which the buildings in a development have fewerthan 5 units.C. The age of the development as determined by the DOFA Date.D. Whether the development is a family development.E. The cost index of rehabilitating property in the area.F. The extent to which the units of a development were
2 OVERALL TRAINING OBJECTIVES By the end of this training, you should: Understand the key changes of the Capital Fund program, based on the Final Rule. Know eligible and ineligible activities under the Capital Fund program. Understand the annual Capital Fund submission requirements and how the funds will be distributed by
