Oregon Allocated 1,582 HUD Emergency Homeless/Domestic Violence/Human Trafficking Vouchers, With 37%/587 Available in 3 County Portland Metro Area

HUD's Emergency Voucher webpage is HERE and includes links to presentations, notes, and webinars. 

The initial overview presentation is HERE. Eligible populations are:

• Homeless; 
• At-risk of homelessness; 
• Fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking; and 
• Recently homeless, as determined by the Secretary, and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.

PHA's have until MONDAY MAY 24th to accept or decline the HUD tentative allocation

The Oregon HUD tentative allocation totals 1.582 vouchers with 582/37% allocated to the three Oregon Portland metro counties. 

The table pasted below shows the allocation by Oregon housing authority. 

Estimated Total New Oregon Rental Assistance Since April 2020: $801 Million.

In recent testimony in the Oregon Legislature the total new funding made available for rental housing since April 2020 was estimated at $801 million (this doesn't include ongoing rental assistance programs). It's not clear if the $12 million+ HUD funding for these vouchers is included in these totals. 

Originally posted on the Oregon Housing Blog. 

First List of 80 MTW Agency Voucher and Public Housing Counts by State, Including This Years MTW Expansion Agencies.

In my prior post I provided counts of Public Housing and Voucher counts by HUD region with a breakout of those counts for the now 80 approved HUD MTW agencies. 

In the 3 page PDF HERE and embedded below I breakout those counts by state. 

The listing starts with Vouchers, then Public Housing, and then the combination of both. 

Columns show MTW subtotals and state MTW percentage rankings. 

I'm confident that this is the first public posting of these counts. I used unit counts from the PHA data found in the HUD Picture of Subsidized Housing annual publication HERE.   

Some observations: 

1. Oregon has the 6th highest percentage of PH units in MTW agencies, the 7th highest percentage of voucher units, and the 6th highest percentage of combined PH and voucher units. Oregon's  combined total of 15,331 MTW units is higher than Ohio's 11,555 combined MTW units AND North Carolina's combined 12,279 MTW units. 
2. Washington has the 2nd highest percentage of PH units in MTW agencies, the 3rd highest percentage of voucher units, and the 3rd highest percentage of combined PH and voucher units. Washington's 33,341 voucher MTW units are slightly higher than the 33,148 MTW voucher units in Texas.
3. California has the largest number of voucher units in MTW agencies at 72,299 units.
4. Pennsylvania has the largest number of public housing units in MTW agencies at 16,145 units.
5. New York, with a combined count of 461,790 public housing and voucher units, has ZERO MTW units. Ditto for Michigan with a combined count of 83,646 public housing and voucher units and ZERO MTW units. 

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Latest MTW Expansion Includes Washington County and Brings MTW Share of ALL US Vouchers to 16% and 10% of All Public Housing Units.

HUD has announced the latest 10 PHA's approved as Moving to Work agencies, bringing the MTW total to 80 PHA's. The latest limited scope MTW approvals test various rent variations as explained in the HUD PR HERE.  The HUD MTW landing page is HERE.

The Housing Authority of Washington County [HAWC] was one of the agencies approved for MTW participation; Home Forward is the only other MTW agency in Oregon. 

HAWC's approval for a tiered rent structure will extend regular income reviews to 3 years and band tenant rents by $2,500 income increments to simplify the rent setting process. The HAWC application, with many more details, is HERE. 

I compiled a count of public housing and HUD voucher units within the 80 MTW agencies and put together a summary by HUD region in a PDF file HERE and embedded below. [The unit count data source was the 2020 HUD picture of subsidized housing data found HERE].

Observations:

• Region 10 [which includes Oregon and Washington] has the highest regional percentage of both public housing (57.2%) and voucher units (46.7%) in MTW agencies. 
• In contrast Region 2 (think NYC), with 223,167 public housing units has only 394 of those units in MTW agencies. 
• There are now 98,525 public housing units in MTW agencies and 425,079 voucher units. 
• The latest 10 MTW agencies just added have a total of 59,556 units; 11,325 public housing units and 48,231 voucher units. 
• The two MTW 2021 expansions this year to date have added a total of 75,596 units; 15,875 public housing units and 59,721 voucher units 
• I count a total of 2,861 public housing agencies. The 80 MTW agencies are only 3.7% of total agencies, but have a substantially higher 10.3% of all public housing units and 16.2% of all voucher units.

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New OHCS Proposed Annual 5% Rent Increase Limit Raises a Large Number of Questions/Issues.

For the first time OHCS is proposing a rent increase limit of 5% annually for tenants in projects that OHCS finances, including LIHTC projects. Owners can appeal for increases beyond that level, according to the proposal scheduled to be considered by the Oregon Housing Stability Council at their Friday April 6th meeting. The 3 page proposal from the meeting packet is HERE and embedded below. 

The proposal raises a large number of impact, transparency, and process questions and issues, including these:

1. When will the new rule go into effect? Since the effective date for the HUD FY 2018 income limits was April 1, 2018 can we assume the proposed rule does not impact rents that do not exceed the allowable maximums that result from those new income limits?  IF the rent increase restrictions apply to projects 45 days after April 1st-or May 15th/16th, does that provide owners enough time to understand and generate a complete package of information necessary to request a rent increase? 
2. IF an owner wants to adopt up to a 5% increase, AND if that rent is within the maximum rent permitted by the relevant current fiscal year HUD income limits, does a rent increase of 5% or less require any submission/notice to OHCS?  
3. If allowable rents are restricted at a specific project, will income restrictions match the restricted rents for new tenants (as well as existing tenants)?  If not then new tenants at maximum incomes could pay less than 30% of income at admission. 
4. Will the rule require administrative rule making and an opportunity for public comment?
5. What are the planned public disclosure provisions for requests, processing times, and approvals?  Should performance measures be adopted to track this activity?
6. Which specific OHCS programs are subject to this rule?
7. How many total projects and units are subject to the rule? (OHCS table HERE shows 28 pages of just LIHTC projects, at conservative count of 40 per page, that would be in excess of 1,000 projects?). 
8. Does OHCS have the staff capacity and the skills to handle rent increase requests every year from all of the projects subject to this rule? Will an increase in admin fee be required to pay for the extra costs of rent reviews? 
9. Do owners have the staff capacity and the skills to generate budget based rent requests annually?
10. Will a new 5% annual rent increase limit decrease the value of tax credits to investors and thus increase the need for additional public gap financing?
11. What are the standards/metrics that will be used to make rent increase determinations? For example, what updated market data will be use to determine comparable rents?, what is a reasonable reserve for replacement level, and how will capital needs be determined? What specific exhibits will be required to submit a rent increase request? 
12. Are their new or existing mechanisms to insure that increased project income from increases in median income levels stay with the project to benefit the tenants?
13. How will the public, and existing or prospective tenants know the maximum rent they can be charged at an individual project? What rent limit will be used for prospective tenants or existing tenants who want to move into a larger bedroom sized unit/ the same bedroom size but in a different floor or building?
14. 100% LIHTC projects-Over income tenants and rent equity issues: I assume that the vast majority of LIHTC projects have 100% LIHTC assisted units. After the first year annual recertification with third party documents my understanding is that there is no effective restriction on the income of these tenants (even if they self certify and disclose higher incomes). 

• Does imposing a 5% annual cap increase the likelihood that over income tenants will continue to occupy (for years) units intended for lower income families? [Staying in a unit with a annual rent increase limit would be more seemingly more attractive than competing NON LIHTC units without annual rent increase restrictions]. 
• IF the income of these post year 1 tenants increases more than 5% [or the approved rent increase %], the share of their income for rent will decline, and perhaps below 30% . In contrast, a low income voucher holder paying 30% of their income for rent could end up paying a greater percentage of income for rent. 
• For 100% LIHTC projects how will OHCS measure rent burdens as part of the evaluation process for rent increase requests? 
• With new income averaging rules will there be any effective limit on future incomes for long term LIHTC residents in 100% LIHTC projects?  

Originally created and posted on the Oregon Housing Blog 

HUD Reorg Will Wipe Out Spokane Office, and MF Staff in Seattle and Portland.

HUD PR is HERE, more to follow I am sure. 

Originally created and posted on the Oregon Housing Blog.

HUD Behind Schedule, Again.

In prior post HERE I reported the planned "Mid January" roll out of a new HUD funded Housing Transportation Affordability portal. This mid January date was an extension of a previously planned December 2012 roll out date. 

Were now at mid March, 90 days past mid December and 60 days past mid January, and the portal has not yet been announced and no updated date is provided on HUD's related website HERE. 

HUD NOFA on Time Performance Lagging
HUD acknowledges in its Summary of Performance report HERE that it badly missed its target of obligating 90% of NOFA's within 180 days of budget enactment, obligating only 46% of NOFA's within 180 days for funding enacted in FY 2012.

Glaring HUD Regulatory On Time Performance Lag Example
HUD's most glaring missed schedule is for it's proposed affirmatively furthering fair housing regulation, yet to arrive nearing 3 and 1/2 years after the initial target date of November 2009. (See prior post HERE). 

If I could offer a piece of advice that I learned, sometimes painfully, in my 30+ years at HUD it is:

 " UNDER promise, OVER deliver". 

Originally created and posted on the Oregon Housing Blog.

HUD Stuff: Small Apartments and Local Market at a Glance Reports.

First, Oregon HUD web site has summary of recent news stories about small apartments in Portland (including FHA financed Freedom Center project) and elsewhere HERE. 

Second, I ran across new HUD resource that provides some localized housing market data [Market at a Glance Reports] HERE using pull down menus at the metro and county levels. Sample PDF 2 pager for Portland metro is HERE.  Latest data is from August, not clear how frequent updates are done.

Originally created and posted on the Oregon Housing Blog.

HUD Rental Demonstration Notice Out on Thursday; Advance Copy Here.

Advance copy is HERE, and will be published in Federal Register on Thursday. 

RAD page is HERE; HUD says:

Upon the notice’s release, owners will have 90 days to apply to be considered for the Initial Application period. Additionally, owners of Rent Supp, RAP, and Mod Rehab properties looking to participate in RAD’s second component, which allows the conversion of assistance to the PBV program, will be able to apply immediately under revised rules

Originally created and posted on the Oregon Housing Blog.

 

HUD Publishes Comprehensive List of Exclusions from Income.

While this information may be in other existing HUD administrative guidance, HUD has published FR Notice with a comprehensive listing of sources of income that are NOT counted when computing eligibility and tenant share of income for rent payments in HUD programs. (Last prior notice in Federal Register was in 2001).

FR Notice with listing of exclusions from income is HERE; some examples of income excluded are food stamps, WIC payments, and veteran's disability payments. (Some exclusions are limited to specific HUD programs so read the Notice carefully).

Originally created and posted on the Oregon Housing Blog.

OMB/HUD Delays on Fair Housing Regs and Demos Continue.

There are three regulatory fair housing actions still pending at HUD or OMB.

At HUD

A notice of a affirmatively furthering fair demonstration program in the Baltimore MSA was sent to OMB on January 17, 2012. Five months later, OMB cleared the notice on May 16, 2012, but nearly 30 days later HUD has yet to publish the notice in the Federal Register. 

AGENCY: HUD-OH  RIN: 2502-ZA13 
TITLE: Notice of Intent to Conduct Affirmatively Furthering Fair Housing Demonstration in Baltimore, Maryland, Standard Metropolitan Statistical Area (FR-5617) 
STAGE: Notice  

RECEIVED DATE: 01/17/2012    
COMPLETED: 05/16/2012  

COMPLETED ACTION: Consistent with Change 
 

At OMB

Two Rules are Pending at OMB, one a FINAL rule and the second a proposed rule. The final disparate impact rule has been at OMB for approaching two months, while the proposed affirmatively furthering fair housing reg has been at OMB for 5 months.

 

AGENCY: HUD-FHEO  RIN: 2529-AA96 
TITLE: Implementation of the Fair Housing Act--Disparate Impact (FR-5508) 
STAGE: Final Rule  

RECEIVED DATE: 04/25/2012  
Note : A meeting this past Monday (June 11) concerning this rule was held with advocates, HUD, and OMB; details about attendees are HERE.

AGENCY: HUD-HUDSEC  RIN: 2501-AD33 
TITLE: Affirmatively Furthering Fair Housing (FR-5173) 
STAGE: Proposed Rule  

RECEIVED DATE: 01/17/2012     

Originally created and posted on the Oregon Housing Blog.

Corrected:New VA Report on Risk of Homelessness Indicates Female Veterans Use HUD-VASH at Higher Rate than Male Veterans.

Corrected incorrect link to prior post about use of HUD rental assistance by women heads of households
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From VA IG, report is HERE.

Lots of details, one caught my eye. Female veterans use HUD VASH housing program at a substantially higher rate (looks to be almost double) than male veterans. (PDF page 51, hard copy page 40). 

My prior post pointing out high use of HUD rental assistance programs by women is HERE. 

Originally created and posted on the Oregon Housing Blog.

Updated: HUD New Comp Plan Tool Resources; Maps Include Census Tract Level Voucher Counts and Share of Housing Units.

Update: 
Link to PDF of HUD slide show/webinar [w/o audio] from Monday is HERE. 
------------
Related to today's HUD webinar on their new consolidated planning tools, you will find several related resources on the HUD consolidated planning website HERE. (I would bookmark this site as it will be no doubt updated in the future).

One of resources is new CPD Notice HERE that describes timetable for using new planning tool.

The webinar from today is not yet posted but should appear shortly at the bottom of the page; look for "Introductory Webinar". 

CT Level Voucher Maps
I have started to look at content from mapping site and was surprised to see census tract level voucher data, although it appears it may be from HUD 2009 Picture of Subsidized Housing. Some CT level voucher counts are not shown as they are below the threshold of vouchers reported for privacy purposes and it is not clear whether total housing units used to calculate concentrations in the current voucher maps are from 2000 or 2010 Census data.

Originally created and posted on the Oregon Housing Blog.

Fomer St Louis HUD Multifamily Director Indicted.

Story is HERE, giving us former HUD MF Directors a bad name...

Originally created and posted on the Oregon Housing Blog.

HUD/FHA MF Processing Changes; Expedited Processing Keeps Evolving From Portland's FastTrack Orgins.

Many many years ago the Portland Office was the first office in the country to use waiver authority to improve the speed of multifamily insurance loan application processing. 

In Portland we actually used a money back guarantee of timely service to induce developers and lenders to use this expedited method of loan processing. We called if FastTrack and one of our marketing slogans was "Unlike fine wine, loan applications do not improve with age" :)

Subsequently many offices adopted their own version of FastTrack processing, and that eventually morphed into a unified national process called MAP. 

In tomorrow's Federal Register HUD is proposing new rules for MAP processing; an advance copy is HERE, but check the Federal Register tomorrow for the final version along with new MAP lender eligibility requirements.

Originally created and posted on the Oregon Housing Blog.

All New HUD Choice Neighborhood Grantees East of Mississippi

That's what it looks like to me; HUD PR HERE. 

Originally created and posted on the Oregon Housing Blog.

FY 2012 HUD/Transportation Appropriations Now Law, Includes Some Reg Relief for PHA's and FHA Mortgage Limit Increases.

Entire 457 page bill text of  HR 2112 is HERE.(HUD Section starts on page 355).

NLIHC has posted an additional table of comparisons of selected program funding levels HERE; it includes FY 2012 comparisons to FY 2010, FY 2011, and the FY 2012 President's requested budget. 

Fixed Income PHA Income Re-certifications Can Move to a 3 Year Cycle. Contrary to what I said in yesterdays post  the final bill does include a Section 236 [page 432] that has some PHA changes related to income eligibility. A key regulatory relief provision allows, subject to tenant self certification, 3 year income recerts for those with "fixed incomes". There are also changes to the definition of income limits for extremely low income families (it will be the higher of 30% of median family income or the poverty level). I am sure that industry groups and HUD will have more to follow on these and other eligibility changes in the coming days.

FHA mortgage limits are included in the bill [page 437], mortgage  limits did NOT increase for Fannie and Freddie. Realtor PR is HERE.

Originally created and posted on the Oregon Housing Blog.

HUD Conference Committee FY 2012 Budget vs FY 2011 Enacted and President's Proposed FY 2012.

Using NLIHC budget table , I have prepared a PDF file HERE that shows my calculation of the differences between FY 2012 conference committee reported HUD budget and FY 2011 enacted and FY 2012  budget request by the President.

Biggest loser I see are CDBG and HOME programs which were cut 12% and 38% from FY 2011 levels.   Tenant based voucher did better than expected with a more than 3% increase, but admin fees were cut by nearly 7%. Project based Section 8 increased by less than 1%.

Based on my read of report it does not look like any of the changes in public housing/voucher eligibility and reduction in frequency of income verification for fixed income recipients made it into the final bill. [Difficult to cut voucher admin costs by 7% without some regulatory relief...].

Full conference committee report is HERE. 

Originally created and posted on the Oregon Housing Blog.

HUD FY 2012 Conference Committee Report Out,

The House/Senate Conference Committee Report that includes FY 2012 HUD appropriations has been published in the Congressional Record.

Title II, the HUD portion of the bill, starts at page 33 HERE. Lots of different provisions, I note that it includes FHA mortgage increases and $125 million for HUD/NRC mortgage counseling.

I expect NLIHC will have a comparison table up today or tomorrow on their web page HERE. Both the House and Senate will have to pass the legislation before it goes to the President for signature, presumably by the end of this week.

Originally created and posted on the Oregon Housing Blog.

FHA's Official FY 2011 Financial Report Issued.

HUD PR is HERE.  

HUD report to Congress is HERE.

More detail (links not in HUD PR)

• Actuarial review, excluding HECM loans, is HERE.
• The HECM Actuarial Review is HERE. [Section 2, the "Findings" Section, appears to be missing from this file; I have alerted HUD HQS staff].

From HUD's PR:

...barring a further significant downturn in home prices, the MMI Fund will start to rebuild capital in 2012, and return to a level of two percent by 2014 – outpacing last year’s prediction....The independent actuarial reviews of the MMI Fund estimate FHA’s capital reserve ratio to be 0.24 percent of total insurance-in-force this year, falling from 0.50 percent in 2010. FHA’s total liquid assets (cash plus investments) grew by $800 million since last year, to $33.7 billion. That amount is $1.9 billion higher than at the end of FY 2009, and is also $7.7 billion higher than was predicted last year by the independent actuaries. At the same time, the economic net worth of the Fund fell by $2.1 billion this year, from $4.7 billion to $2.6 billion, as FHA continued to build loss reserves to prepare for greater claims in the coming years.

 Losses on loans insured through the first quarter of fiscal year 2009 continue to place a significant strain on the Fund and are expected to reach $26 billion within a few more years. Though they were prohibited in 2009, the ongoing effect of so-called “seller-funded downpayment assistance loans” is still significant. The net expected cost of those loans, as projected by the independent actuaries, grew by $1.8 billion over the past year to $14.1 billion. Conversely, the actuaries found that the FY2010 and FY2011 books are expected to be very profitable, providing significant net revenues to offset losses on earlier books. Loans insured to-date under the Obama Administration are providing $18 billion in economic value for the MMI Fund. Under the base-case forecast used by the independent actuaries, the FY 2012 book will add an additional $9 billion in economic value to the Fund.

Originally created and posted on the Oregon Housing Blog.

View Federal Spending Trends: Oregon HUD Example.

The USASpendingGov.spending website has a feature that allows viewing of trends in spending for last several fiscal years. Very cool.

Users can select by FY, agency, geography, type of assistance, or program starting at web page HERE.  Looks like lowest geography in this view is by Congressional District.

Example HERE shows grants and direct spending by HUD program in Oregon from FY 2003 to FY 2012.  (List is sorted by CFDA number). 

If you click on data for specific program for specific FY you will see more detail, including largest recipients for that year and the ALL recipients for that FY.

If you click on FY heading, list will sort from largest to smallest amount by program for that FY.

Some data is clearly missing from earlier years, but peak year to date was FY 2009 when HUD spending in Oregon topped $500 million, led by $199 million in Housing Choice Voucher spending.

Originally created and posted on the Oregon Housing Blog.