OHCS Has Formed NEW Hardest Hit Non Profit With BROAD Jurisdiction; Special Organization Meeting MONDAY AM August 2nd.

I have previously posted that OHCS was to be commended for the transparency shown prior to submission of the Hardest Hit proposal to Treasury.

However, since then there has been little information made available to the public about the new non profit being formed to receive the largest housing grant in the history of Oregon. 

After I inquired this week OHCS has advised that there will be a special meeting of the new non profit next week and also sent me a copy of the Articles of Incorporation for that non profit, which was incorporated TODAY. 

From their website , the following notice was provided today:

Notice of a Special Meeting of Board of Directors of Oregon Affordable Housing Assistance Corporation
A special meeting of the Board of Directors of the Oregon Affordable Housing Assistance Corporation, an Oregon nonprofit benefit corporation (the "Corporation"), in accordance with Section 65.344 of the Oregon Revised Statutes.

The special meeting shall take place on August 2, 2010, at 8:00 a.m. PST, in Conference Room 322 of the Oregon Housing and Community Services Department at 725 Summer Street NE, Suite B, Salem, Oregon 97301-1266.

Related Documents: Notice of Special Meeting.

I have also posted the Articles of Incorporation sent to me HERE. 

To my knowledge there was no opportunity for the public to see or comment on  the Articles of Incorporation and Bylaws prior to expected "closing" of the HH plan with the US Treasury some time next week.

I have posted on many occasions about the need for the public to understand the jurisdictional scope, the organization, and the ongoing openness of the operations of this new non profit. It is disappointing to me that OHCS moved backwards from their prior transparency and did not provide the public an opportunity to offer their views on

• What the leadership structure of this new non profit will look like
• What the formal relationship to OHCS will look like,
• What the allowable activities should be limited to,
• The extent to which non profit meetings and records will be open to the public.

New Non Profit Has BROAD Jurisdiction, Clearly NOT Limited to Hardest Hit Activities. 
My reading of the Articles of Incorporation indicate that the potential scope of this new non profit is VERY broad, and much more than necessary to carry out activities of the Hardest Hit program. 

From the Articles of Incorporation:

The specific purposes of this Corporation are to (i) administer grants, loans, and other forms of financial resources targeted to help prevent or mitigate the impact of foreclosures on low and moderate income persons, and to help stabilize housing markets in the State of Oregon (the "State"), (ii) develop and implement housing assistance programs targeted to help prevent and mitigate the impact of foreclosures on
low and moderate income persons, and to help stabilize housing markets within the State, (iii) provide funds or other financial support or benefits to promote, preserve or stabilize affordable housing markets located in the State, (iv) provide subsidies or other benefits targeted to low and moderate income persons within the State necessary or appropriate to stabilize housing markets located in the State, (v) finance affordable or subsidized housing in the State, (vi) accept and make grants for affordable or subsidized housing in the State, (vii) develop and administer programs related to housing permitted under the Emergency Economic Stabilization Act of 2008, as amended ("EESA"), and to act as an institution eligible to receive Troubled Asset Relief Program funds under EESA, (viii) finance and refinance housing loans, provide credit and other financial support for housing loans and otherwise provide financial support for affordable housing within the State, (ix) develop and implement educational programs, instruction, research, assistance and other programs to help prevent foreclosures of housing and stabilize housing markets within the State, (x) lessen the burdens of government by assisting the Housing and Community Services Department of the State of Oregon ("OHCS") prevent or mitigate the impact of foreclosures on low and moderate income persons, and to help stabilize housing markets within the State, and (xi) conduct or perform any ancillary or related activity in furtherance of the foregoing. For purposes of these articles, the determination of what constitutes affordable housing and who is a low and moderate income person shall be determined by the Board of Directors of this Corporation. Subject to Article VILB of these Articles of Incorporation, this Corporation shall be permitted to conduct other lawful activities permitted under the Oregon Nonprofit Corporation Act

If the future the effort is made to move current or future housing programs within the umbrella of this new non profit I have major concerns, and I expect others may have similar concerns. 


Originally created and posted on the Oregon Housing Blog.

New GAO Testimony on Need for TARP Transparency.

GAO testimony before Senate Finance Committee is HERE. Within testimony, discussion of TARP housing programs begins on PDF page 11; interesting table on PDF page 18 showing change in various market interest rates and loan volumes. Appendix in report starting on PDF page 20 shows all prior GAO reports on TARP.

Related June 2010 GAO report on HAMP, Further Actions Needed to Fully and Equitably Implement Foreclosure Mitigation Programs, is HERE.

Originally created and posted on the Oregon Housing Blog.

SeeClickFix: Using Social Media to Increase Government Responsiveness.

Interesting concept to attempt to use social media to empower citizens to identify problems, refer to government, and track progress towards resolution. (Slick way to identify problems, but resources to investigate,fix, prioritize on fixer end may be an issue?).

Available for virtually any area of world; Portland problems reported are shown HERE.

Multiple views of same data possible--the view HERE is apparently of watchers [government agencies and civic groups] who track problems reported.

Originally created and posted on the Oregon Housing Blog.

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:


Arizona
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.

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

Florida
Receiving $418 Million
Material for April 5th Public Hearing
Agenda
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

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

Nevada
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

HUD's New Open Government Plan.

Just issued, it's HERE. (HUD's plan is part of government wide effort; White House page HERE has links to ALL plans).

Editorial comment: Good stuff!

AFTER reading the HUD plan, you can provide your feedback (or read other comments) in the HUD provided on line forum HERE.

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.

New Open Government Directives from OMB.

Courtesy of BeSpacific

From OMB Director's Blog on the Directive:

"The directive, sent to the head of every federal department and agency today, instructs the agencies to take specific actions to open their operations to the public. The three principles of transparency, participation, and collaboration are at the heart of this directive. Transparency promotes accountability. Participation allows members of the public to contribute ideas and expertise to government initiatives. Collaboration improves the effectiveness of government by encouraging partnerships and cooperation within the federal government, across levels of government, and between the government and private institutions."

The Open Government Progress Report to the American People

The Open Government Directive

Local Spotlight from Sunlight Foundation Highlights Our Excel Recovery Jobs Database.

File under "shameless promotion".

Sunlight foundation Local Spotlight blog post is HERE.

Originally created and posted on the Oregon Housing Blog.

Cross Post: Oregon Disclaims ORS Copyright.

From my Oregon Open Government News Blog HERE.

Cross Post: Sunlight Foundation Picks Up on My Prior Post Highlighting House YouTube Hearing Upload.

From my Open Oregon Government Blog HERE.

Cross Post: State Asserts Copyright Over Oregon Revised Statutes.

From my Open Government News and Issues, Oregon Blog HERE.

Dumb Government Revisited: Gov Contractors Escape Paying Health Insurance.

Story in WSJ yesterday reminded me of an earlier post HERE where I called the federal government "dumb" because of its failure to collect back taxes from 30,000 federal Medicare providers.

Story yesterday in WSJ HERE, recounts that:

1. Federal government is missing opportunity to require federal contractors to provide health insurance (or dollar equivalent in fringe benefits) to employees by exempting industries from requirement where health insurance is "not typical".
2. Feds also have no system for collecting information on how many of the estimated 5.4 million federal contract employees have employer provided health insurance(or pay dollar equivalents in fringe benefits).
3. $3.16 per hour is currently provided as the fringe benefit equivalent to health insurance. (This seems to me to woefully inadequate to provide anything other than very limited individual [not family] insurance coverage).

With all the commotion about expanding health insurance it strikes me as plain "dumb" to NOT mandate that all government contractors must provide health insurance, or to require a realistic fringe benefit payment sufficient for the employee to pay for privately provided individual insurance, and to track and report health insurance coverage by each government contractor. (It would be equally 'dumb" to allow employees to collect the fringe benefit equivalent, spend it on something other than health insurance, and then enroll [at government expense] in Medicaid).

One way to expand coverage would be to allow private contractors to enroll federal contract employees in the Federal Employee Health Plan, with employees who enroll required to pay a share of the insurance premiums and co-pays just like federal employees, and with employers paying the majority of the insurance premium.

Cross Post: Slate's Delegate Calculator Shows Daunting Clinton Task Ahead.

Cross post on subject from my Open Oregon Government blog HERE.

Oregon Housing Organizations Get New Search Tool.

Please DO send this along to others....

Have you ever wanted to restrict a housing related search in Google just to key housing related organizations in Oregon?

Well, now you can with a newly constructed search tool I have put together called ORHOUSE. (ORHOUSE is an acronym for Oregon Housing Organizations User Search Engine).

With ORHOUSE I believe Oregon will be the FIRST state nationwide to have an information tool that searches multiple websites of key housing organizations within a state.

ORHOUSE was developed using Google’s custom search capability. ORHOUSE search results will be restricted to just those returned from the websites of the nearly 40 housing related organizations in Oregon I have initially chosen for the search. (I will provide a complete listing of those websites once the software moves out of its current BETA stage and I finalize the list. For now suffice it to say that includes most local HUD entitlement community development agencies, several larger housing authorities, HUD, three agencies of the State of Oregon, and non profits from around the state).

HOW TO USE ORHOUSE: The tool can be accessed by going to my Oregon Housing Blog at www.oregonhousing.blogspot.com and search using the ORHOUSE box provided near the top right hand corner of the blog. (PLEASE subscribe to the blog via email [it’s free] to get this and other updates automatically delivered to your email).

Important search tip: Unlike the regular Google search function we are familiar with, if you are searching for a PHRASE, put quote marks around it. I.E. “Affordable Housing” NOT Affordable Housing.

FUTURE DEVELOPMENT: ORHOUSE is in a BETA stage of development.

I will be working with others who may be interested in being listed as a ORHOUSE affiliate AND then if they choose, permission from me to add this search tool to their own home pages. I will also be soliciting user feedback on ways to improve the scope and precisions of searches and wil also be providing FAQ’s at a later date.

ORHOUSE isn't intended to replace typical global Google type searches. It is a supplement to those searches when you want to focus more on what is going on within Oregon.While ORHOUSE is in a BETA stage of development it is already a powerful way of finding out what others in Oregon are doing and saying about a wide variety of housing news, issues, and policies of importance throughout the state.

Give ORHOUSE a try and let me know what you think by adding a comment at the bottom of this post.(If you want to send a non public comment to me, please email me at housepdx@gmail.com).

Thanks, Tom Cusack
http://www.oregonhousing.blogspot.com

Site Provides Details on Privately Paid Congressional Travel Expenses (And More)

Click to See Cross post from my Oregon Open Government Blog

Year to Date HAP 2007 Board Agendas and Minutes Combined into one Single Searchable Document; Innovative HAP Dashboard Report Also Noted

The Housing Authority of Portland (HAP) probably does the best job in Oregon of any HUD grantee of posting for download their individual monthly Board meeting agendas and minutes on their web site HERE. (HAP also posts a regular monthly “Dashboard” of key metrics that is a unique and innovative snapshot of Housing Authority operations. The current dashboard on their website can be found HERE).

HAP is HUD’s largest grantee in Oregon. Kudos to the staff and Board at HAP for their leadership in making Board information readily available in advance of Board meetings and for their continuing improvements in improving the scope and quality of information made available to the public.

To build on HAP’s good work on monthly board reports:
1. I have downloaded the individual monthly year to date Board packets and combined them into a single document HERE. The current PDF file, covering meetings from Jan-July of 2007, is a 4.6 MB download with 497 pages, and may require free Acrobat Reader 7 to view.

2. Within the PDF file I have added a bookmark panel to the left so that you can continue to navigate directly to board packets for an individual month.

3. With this new combined 2007 HAP Board Meetings PDF file, it is possible to do ONE search by keyword within the file and see the results from ALL of the HAP agendas and minutes for 2007. (So for example, one now can find all 88 references to the keyword “New Columbia” from all meetings from Jan-July 2007).

(Note: The combined Board packet link http://www.housepdx.com/pdfs/housing/07hapytdboardpackets.pdf from above will be a permanent link to the most recent combined HAP Board 07 package that I have prepared. You may want to add this URL to your browser “favorites” or “bookmarks” so that you can get easily to the latest combined HAP board packets in the future.)

From HAP's website it appears that their next Board meeting will be in September, so look for the next update of this combined PDF file in mid September.