HUD FY 2014 OCAF's Published.

Yesterday HUD published FY 2014 state level OCAF's (Operating Cost Adjustment Factors). OCAF's are used to adjust rents for many projects with Section 8 project based rent contracts. Key data:

• Oregon's 2014 2.1% OCAF is higher than the national average of 1.9%.
• Oregon's 10 year average OCAF of 3.2% is identical to the 3.2% 10 year average US OCAF.   

The effective date for these OCAF's is Feb 11, 2014.

I have updated a prior PDF HERE that includes:

• A table showing ALL OCAF's for ALL states from 1999 to 2014.
• The Federal Register publication for each year. 

[This is the only place on web where you will find a 16 year historical table AND FR publication of all state OCAF's].

Originally created and posted on the Oregon Housing Blog.

Updated: Oregon's 2012 OCAF is 2%: Table for All States, 1999-2012.

Update: File link has changed and been updated to also include all Federal Register OCAF publications from 1999-2012. 
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Tomorrow's Federal Register will have HUD's 2012 state level OCAF's (Operating Cost Adjustment Factors). OCAF's are used to adjust rents for many projects with Section 8 project based rent contracts. 

Oregon's 2012 2% OCAF is higher than the national average of 1.8%, but less than the Washington State OCAF of 2.3%. (However, Oregon's 10 year average OCAF of 3.6% is higher than the 3.5% 10 year average OCAF for Washington and California).  The effective date for these OCAF's is Feb 11, 2012.

I likely will have some additional observations and posts later but for now HERE is a table showing ALL OCAF's for ALL states from 1999 to 2012 AND the Federal Register publication for each year. [This is likely only place on web where you will find a historical table of all state OCAF's].

Originally created and posted on the Oregon Housing Blog.

California Releases LIHTC Operating Cost Minimums Based on Survey of 680,000 Units.

Memo from Tax Credit Allocation Committee is HERE.  Actual operating cost minimums by area are HERE.

Originally created and posted on the Oregon Housing Blog.

OCAF Historical Table and All FR Publications, FY 1999 Forward.

Readers may recall that for last two years that I have posted ALL of the actual Federal Register publications of the annual HUD Operating Cost Adjustment Factors (OCAF) from FY 1999 forward, along with a table with the historical OCAF percentages for ALL states. [OCAF's are used to adjust annual HUD subsidized rents in project based Section 8 projects].

I have updated that PDF file HERE; it includes a state table AND the OCAF Federal Register publications for the 13 years from FY 1999 to FY 2011, including today's publication of the FY 2011 OCAF. The table also includes a 5 year and 10 year average OCAF for each state and the US in the far right columns.

I am sure this is the ONLY place you will find this record and comparison of state OCAF's for the past 13 years. 

For easy reference, I have added a permanent link to this document in the right pane, HUD OCAF Increases, Oregon and All States.

Observations: Oregon's OCAF is Higher than US Average this Year, Over 5 Years, and Over 10 Years

1. Oregon's FY 2011 OCAF of 2.6% is HIGHER than the US average OCAF (2.6% vs 1.7%).
2. Oregon 5 year average OCAF is HIGHER the US average  (4% vs 3.8%).
3. Oregon's 10 year average OCAF is HIGHER than the US average 10 year OCAF (3.8% vs 3.7%).

Originally created and posted on the Oregon Housing Blog.

OCAF's Coming Out Monday; Oregon's is Down to 2.6%

Operating Cost Adjustment Factors, used to adjust certain project based Section 8 rents will be in the Federal Register on Monday.  (Draft of that notice is HERE) .

A quick review shows that the Oregon FY 2011 OCAF will be 2.6% , a reduction from the 3.2% FY 2010 Oregon OCAF. 

The quick table I prepared below shows historical OCAF data by Fiscal Year for Oregon, Washington, and Idaho.

FY	Oregon OCAF	Washington OCAF	Idaho OCAF
FY 2011	2.60%	2.70%	3.00%
FY 2010	3.20%	3.90%	4.50%
FY 2009	7.90%	2.30%	4.70%
FY 2008	3.30%	6.00%	6.10%
FY 2007	3.10%	3.10%	3.10%
FY 2006	3.50%	3.50%	3.80%
FY 2005	2.20%	2.40%	1.90%
FY 2004	6.20%	5.50%	5.60%
FY 2003	2.00%	2.80%	2.50%
FY 2002	3.70%	3.60%	3.60%
FY 2001	3.10%	3.30%	3.20%
FY 2000	2.70%	2.40%	2.50%
FY 1999	2.30%	2.60%	2.30%

I will likely do an additional post once I get a chance to look more closely at the notice and data. 

Originally created and posted on the Oregon Housing Blog.

Sunshine Week: Oregon Housing Blog Highlights.

This week is Sunshine Week, an annual national event that attempts to create a dialogue about the importance of open government and freedom of information. Much more about this effort can be found HERE.

I thought it might be useful to highlight some positive Oregon Housing Blog related achievements that have increased public access to housing related information in the past year and to highlight some ongoing challenges.

Short version is that while there are SEVERAL achievements,there is work that still remains.

Achievements.(Not in order of importance)

1. The Oregon Housing and Community Services began posting for their monthly meetings of the Oregon Housing, the full briefing packages as provides to Council members. (Link in right pane: Oregon Housing Council Materials),
2. The Oregon Facilities Authority has begun posting, for their monthly meeting of their Board, the full briefing packages as provided to the Board. (Link in right pane to OFA CY 2010 Meeting Packets).
3. After a several month delay I was able to obtain, for the first time, some limited project expense information from the projects used to determine the Oregon Operating Cost Adjustment Factor. The OCAF determines the amount of annual rent increase permitted for vast majority of HUD project Based Section 8 projects. (See related post HERE).
4. Within 30 days of the completion of the calendar year, I was pleased to provide, for the first time ever, detailed county level year data on FHA single family loans. Timing was good, as this was a record setting $5.7 Billion year for FHA activity in Oregon. (See related post HERE).
5. In my view, the Housing Authority of Portland continues to lead the pack on public disclosure of meeting materials. (Their Board Packets have appeared for several years in the right pane; for the current year, see HAP YTD Board Packages).
6. HUD Regulatory Waivers. I have posted ALL HUD regulatory waivers covering the last 4 FULL calendar years 2006-2009 in ONE document. [On Wednesday I will add 4th quarter 2009 waivers granted, as they are scheduled for publication in the Federal Register then]. (Link in right pane to HUD Waivers-CY 2006-Current).
7. I began a Metro Housing Watch document that includes links to audio, video and text documents I prepared from key Metro meetings, so that advocates can see and hear for themselves what Council is saying and doing about affordable housing. (Link in right pane to Metro Housing Watch).
8. I was also able this year to publish in Excel a comparison of FY 2009 and FY 2010 Fair Market 2 Bedroom rents. This allows easy comparison of rent increases between any area in the country. (See blog post HERE).
9. I was able to publish the first national database of FHA insured loans for the country covering more than 5.7 million units. Database included first FHA project in Oregon, as well as financing details about President Obama's FHA insured apartment home where he lived while attending high school while in Hawaii. (See blog post HERE).
10. Finally, to round out/stop the list at 10, I was able to examine Public Housing data and determine that the proposed FY 2011 HUD budget proposal to transform rental assistance would offer virtually no benefit to Oregon and other Western states. (See blog post HERE).

Challenges.(Not in order of importance).

1. The Oregon Facilities Authority is planning procedural and administrative rule changes that would attempt to reduce public disclosure at a time when their loan volume has substantially increased.
2. Public comments on the OFA agenda have been occurring at the END of their monthly agenda. I hope to get OFA to change this practice as it means that public input will always occur AFTER the Board has made decisions on loan applications and other items on their monthly agenda.
3. HUD has not published a response to the comments it sought on expediting multifamily loan processing back in late April 2009. My comments HERE pointed out that HUD was NOT publishing handbook waivers as it had previously committed. I was please to note there were more comments to HUD from Oregon than in any other state,those comments can be found in the docket (HERE) for this Federal Register published Notice.
4. While the OCAF data received for Oregon was a start, I believe more detail about location and unit size information should be available to the public and I HOPE that HUD will reexamine how it makes more data available as part of their annual publication of state OCAF's.
5. Keeping up with Metro Council developments related to housing needs and local reporting of progress have been a real challenge. Tracking regular meetings of two advisory committees and the twice a week Council agendas is a pain. However it is the only current way to insure that changes in housing related performance measures, or changes in Framework and Function plans, do not slip through the cracks. (See post HERE for an advocate road map that I prepared).

Originally created and posted on the Oregon Housing Blog.

Oregon MF Assisted Operating Expense Data Used to Calculate FY 2010 Oregon OCAF.

With the invaluable assistance of Will White from Senator Merkley's Office, HUD HQS has provided me with some of the data used to make the FY 2010 Oregon Operating Cost Adjustment (AKA, "OCAF").

I appreciate the willingness of HUD HQS to provide the data in the face of other pressing tasks. For me the data provides useful context to help understand how OCAF was/is determined for Oregon. Because of their Privacy Act concerns, HUD did not provide unit counts or county/city locations, so the analysis that can be done is somewhat limited, but still provides some useful insights (I think).

In particular the data provides counts on the number and kinds of projects that HUD used to make Oregon's 3.2% OCAF adjustment for FY 2010. (See my prior OCAF post HERE for more background).

My Take on What the FY 2010 Oregon OCAF Data Shows:

1. 72 projects were used to determine the FY 2010 OCAF for Oregon. Only those projects that file financial statements with HUD are used to determine OCAF. This means that the OCAF determination did NOT include include any OHCS bond financed project based Section 8 projects since these 122 projects do not have FHA insurance and do NOT file financial statements with HUD.
   
2. Bottom line is that only about 22 % of all MF assisted projects in Oregon (72 out of the 332 MF Assisted Projects I count in Oregon) were used to determine the FY 2010 OCAF. Despite this small sample, the OCAF determination is then used for ALL MF assisted projects in Oregon that can use OCAF to adjust annual rents (and I believe this is the vast majority of MF assisted projects in Oregon). [My guess is that Oregon's sample % is toward the low end of other states, which likely have a greater share of FHA insured properties that file financial statements with HUD].
   
3. Older Assisted Projects, including Section 236 and 221d3 projects comprised 53% of the projects sampled.
4. Older Assisted Projects, Including Section 235 and Section 221d3 projects, had lower rates of operating expense increase then the overall HUD OCAF for Oregon. This means that if their operating expenses had increased MORE, the OCAF for ALL MF HUD assisted projects would have been higher than 3.2%.
5. The most recent average operating expenses for Older Assisted Projects like Section 236 and 221d3 were lower than the average for all projects, meaning that increases in expenses in these project would likely still result in average expenses LOWER than the average for the other HUD MF project types in Oregon.
   

Tables Displaying These Results in Detail.
I have prepared the tables HERE to illustrate the results summarized above. Note the IMPORTANT caveats at the bottom of the first two tables, so you understand the limits of the analysis. (For example in Table one you will see a calculated overall average OCAF of 3.52% instead of the actual 3.2% for FY 2010; this occurs because I averaged across projects, since I could not weigh by unit counts which HUD did not provide).

• The first table shows my calculations of the % increase in operating expense by Program and Section of the Housing Act
• The second table shows my calculations of the most recent operating expense average per unit, per annum, by major program and Section of the Act.
• The third table is ALL of the data I received from HUD Hqs for these 72 properties.

Originally created and posted on the Oregon Housing Blog.

Corrected and Updated OCAF Post.

This is a correction and update to my earlier OCAF post from Monday.

In the table I posted Monday HERE I have now made a correction to the calculations of the 5 year and 10 year average OCAF changes in the two far right columns of the OCAF table covering FY 1999-FY 2010. ALL other information in the table, including the annual adjustment for FY 2010, remains the same.

Readers may recall that I last year I posted ALL of the actual Federal Register publications of the OCAF from FY 1999 forward, along with the OCAF comparison

The second file HERE has the table AND the OCAF Federal Register publications for EVERY year from FY 1999 to FY 2010, including today's publication of the FY 2010 OCAF.

I am sure this is the ONLY place you will find this record and comparison of state OCAF's for the past 11 years.

Originally created and posted on the Oregon Housing Blog.

FY 2010 OCAF's Released Tomorrow, at 3.2% Oregon's OCAF is Below National Avg of 4.7%

Tomorrow's Federal Register will include the FY 2010 HUD OCAF's (Operating Cost Adjustment Factors) used to adjust rents in many project based Section 8 programs.

• The national average OCAF adjustment factor for FY 2010 is 4.7%;
• for Oregon it is 3.2%;
• for Washington, 3.9%:
• for Idaho, 4.5%.

If you look carefully at the chart you will see that Oregon's 5 year and 10 average adjustments are at or above the national average for those periods.

I have updated the multiyear OCAF state comparison table I previously constructed HERE-it shows ALL the operating cost adjustments by state since FY 1999.

[I will do an updated post tomorrow once the Federal Register publication actually occurs].

Originally created and posted on the Oregon Housing Blog.

Prior OCAF Comparison Table Amended: Actual Federal Register Pub for All Years Added.

Last week I published a post HERE with a table showing state multifamily OCAF changes from FY 1999-2009 including the 7.9% OCAF for Oregon for FY 2009.

This morning I have added to the table previously posted HERE all of the actual Federal Register publications for those 11 years (including the formal FY 2009 Federal Register multifamily OCAF publication today).

I am confident that it is the only document that you will find with:

1. A table showing all state multifamily OCAF's for last 11 years.
2. The actual Federal Register publications for these years in one place.

Update: Pleasant Surprise: Oregon HUD MF Assisted Projects Get Big OCAF Boost.

Correction: Oregon state increase is third largest in FY 2009, behind Alaska and Mississippi.

Last year I wrote HERE about FY 2008 OCAF (Operating Cost Adjustment Factors) increases that were lower for Oregon than for Washington and Idaho.

Well, this year the picture is reversed. Oregon OCAF's are higher for Oregon than in Idaho and Washington.

In the Monday Federal Register the state OCAF's for Multifamily assisted projects will be published for FY 2009 (which began October 1st.). Some highlights:

• The Oregon OCAF for FY 2009 is 7.9% vs a 3.3% OCAF in FY 2008. The Oregon FY 2009 OCAF is the third largest for any state and is the largest for Oregon in the last 11 years.
• Washington projects get a 2.3% OCAF in FY 2009 vs. a 6.0% OCAF in FY 2009
• Idaho projects get a 4.7% OCAF in FY 2009 vs. a 6.1% OCAF in FY 2009
• Alaska projects get a 12.4% OCAF in FY 2009 vs. a 3.9% OCAF in FY 2008. [Alaska's FY 2009 OCAF is the largest OCAF for any state].
• The U.S. Average OCAF for FY 2009 is 4.3% vs a 4.1% OCAF in FY 2008.
  

Table HERE I constructed shows state annual OCAF's for the last 11 years, from FY 1999-FY 2009. Advance copy of Federal Register publication with FY 2009 state OCAF's is HERE.

Note: OCAF's are NOT the same as rent increases. Contract Rent changes are calculated by applying OCAF to project expenses that EXCLUDE debt services. Unless debt service is zero, the actual contract rent increase will always be lower than the OCAF % increase.

Last 10 Years: Oregon OCAF vs. Voucher FMR Increases.

My recent post on state OCAF [Operating Cost Adjustment Factor] increases got me thinking that I didn't know how those Oregon [expense] increases compared to HUD Oregon housing voucher annual rent increases. I went back and pulled HUD 2 bedroom fair market rent increase data over the last 10 years and created the attached 3 page PDF tables and graph HERE which show those comparisons. Some observations:

1. OCAF % increases (used for some project based assistance rent adjustments) were higher than voucher fair market rent % increases in all of the areas of Oregon that I studied.
2. Just because OCAF % adjustments were higher than voucher FMR % increases does NOT mean that the RENT increases in projects where OCAF was used were higher than were voucher rent increases. OCAF is only applied to the non debt service portion of project expenses and if that expense base was less than the voucher FMR than the resulting project based rent increase could be less than the voucher rent increase even if the OCAF % was the same or higher than the FMR % increase.
3. Voucher landlords likely refinanced their loans during the 10 year period, and this coupled with property tax increase limitations mean the growth in annual expenses was slowed. Along with weak market conditions, this meant that vouchers and modest voucher rent increases were relatively more attractive to landlords over the last 10 years.
4. HUD will announce proposed FY 09 fair market rents sometime this spring. Depending on what those are, how HUD vouchers are funded in the coming year, the movement of families away from homeownership, and the extent of actual market based rent increases now being reported will all impact how useful vouchers continue to be in local housing markets in Oregon.
   

10 Yr. State OCAF Table and Federal Register Publications.

I constructed a single PDF file HERE of the HUD State Operating Cost Adjustment Factors (OCAF's) as published in the Federal Register for the last 10 years. (OCAF's are used to adjust rents for some HUD project based rental assistance projects).

The file consists of a nationwide table showing state OCAF's by fiscal year followed by each of the ten individual Federal Register publications where the statewide OCAF's were first published. (Shameless promotion: Based on my online research and experience I believe this is the only place where you will find such a complete nationwide HUD OCAF history, so download it now for future use).