Tuesday, April 13, 2010

1st Round Hardest Hit State HFA Grantees: Lack of Public Disclosure Prior to Friday App Submission is Embarassing.

Treasury public disclosure guidelines for state HFA applicants for $1.5 billion Hardest Hit TARP funding are incredibly weak. This may reflect Treasury's penchant for protecting financial information from disclosure and/or the past practice for the TARP program.

Treasury guidelines for first round applicants HERE:
  1. Do NOT require a public hearing or publication of the plan for public comment.
  2. Allow, but do not require, Treasury to post ANYTHING about the Hardest Hit applications or subsequent modifications or monitoring results (see page 5).
  3. Restrict HFA's from disclosing any application feedback from Treasury unless Treasury authorizes disclosure (see page 7).
(Treasury's announcement [HERE] of funding but NOT the guidelines, says "All funded program designs will be posted online" and " To create accountability for results, program effectiveness measures and results will be published online.").

My Minimal Expectation for Public Input
My view of minimum public disclosure requirement would be publication of the draft Treasury application (no more than 50 pages, as per Treasury requirements) for public comment and review prior to submission to Treasury. [Application requirements are found on pages 3-5 of the Treasury Guidelines].

Unfortunately, State HFA Hardest Hit Application Public Disclosure to Date: Embarrassing
Following Treasury's weak lead, the 5 HFA's in the first round of Hardest Hit funding have provided a truly embarrassing level of disclosure of how they plan on spending $1.5 billion in TARP funds. Note that a substantial amount of that funding likely will flow through banks and other financial institutions as part of loan modifications and other foreclosure avoidance mechanisms. [To be fair, Florida has done better than other states, but there still is no complete draft plan posted for public comment].

(It is possible that some states may post additional information in the next 4 days remaining to the April 16 application submission deadline, and if they do I will update/amend this post).

Public disclosure details/links TO DATE for each of the 5 states in the first round of Hardest Hit funding is below:


Receiving $125.1 million
Public Hearing Announcement, seating limited, advance registration required.
Held one public hearing on April 7th, but reservations were required.
There was NO information posted on the web, NO draft of the plan.

Receiving $699.6 million
Public Announcement
Did not see any public hearing.
NO draft plan posted.

Receiving $418 Million
Material for April 5th Public Hearing
Draft Allocation and Strategies
Held a public hearing on April 5th
Did NOT include a draft plan.
DID include a DRAFT allocation formula and a "strategies" paper.
NEW ADD: Florida HAS added two audio links from their April 5th hearing
Audio 1
Audio 2

Receiving $154.5 million
Announcement of Receipt of Funding
I did not see any notice of public hearing.
NO draft plan posted

Receiving $102.8 million
Announcement of public hearing, with SOME presentations (some links don't work)
Held one public hearing on March 5th
NO draft plan posted.
[Their entire website needs redesign].

What About Oregon's $88 Million Application?
I HOPE that Oregon sets the standard for public disclosure, including discussions of alternatives in public forums, and the publication of a formal draft application (that addresses ALL of the Treasury requirements) for public comment well in advance of the June 1st application deadline. (Guidelines for second round states are HERE as a MS Word document).

Oregon already does better than some first round states in publishing information about ongoing Housing Council meetings.

It would be surprising to me if the Oregon Housing Council was not required to approve the application for this extra ordinary level of funding (see prior post HERE for some perspective on funding levels). The $88 million Oregon Hardest Hit application would then become a matter of public record.

Given my work with OHCS staff in the past and the culture of government openness in Oregon I remain optimistic that OHCS and the Oregon Housing Council will provide a benchmark example of how to engage the public in preparing an application for the largest housing grant in Oregon's history. This is especially important because of the likely formation of a brand new non profit or LLC (a "financial institution") to administer the Hardest Hit funding, whose jurisdictional scope and standards for public accountability are currently unknown.

Originally created and posted on the Oregon Housing Blog

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