The Housing Authority of the County of Contra Costa. Subsidy Layering Review Checklist for Low-Income Housing Tax Credit Projects
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1 The Housing Authority of the County of Contra Costa Subsidy Layering Review Checklist for Low-Income Housing Tax Credit Projects Projection Name: Location: Narrative description of project including: Sources of funds: Uses of funds: total number of units type of unit by bedroom distribution portion and type of units receiving assistance Each source listed separately with details principle interest rate, amortization term accrual, deferral, balloon or forgiveness provisions reserve or escrow requirements receipt of portion of net cash flow Detailed Breakdown of Project Costs, including hard and soft cost items. acquisition costs broken into appraisal, survey, title and recording, and related legal fees builder s profit and overhead listed as separate items Commitment letters from all sources disclosing significant terms Tax Credit Allocation Commitment Letter from State Housing Finance Agency Amount of Credits Reserved, or IRS Form 8609 Historic Tax Credits (as applicable) Amount of Credit
2 Equity Investment Commitment Letter Amount of Investment Equity Contribution Schedule showing amount and timing Bridge Loan Details (as applicable) Appraisal Report establishing the as is value of the property before construction or rehabilitation, and without consideration of any financial implications of tax credits or project-based rental certificate assistance. Operating Proformas: projected rental commercial and miscellaneous income vacancy loss operating expenses debt service reserve contributions cash flow PHA Notification of Approved Rent to Owner PHA Approval of PBA Voucher Assistance for Project Standard Disclosure and Perjury Statement, Identity of Interest Statement Form HUD-2880 (Ensure you list all the names and titles of Corporate Officers use separate sheet(s) if you require more space) Initial Contract Rents
3 Housing Authority letter confirming gross contract rents with applicable tenant utility allowances
4 Attachment A OFFICE OF PUBLIC AND INDIAN HOUSING COMBINING LOW-INCOME HOUSING TAX CREDITS WITH PROJECT-BASED RENTAL VOUCHERS DOCUMENTS TO BE SUBMITTED BY THE PHA TO THE HUD FIELD OFFICE AND FORWARDED TO HEADQUARTERS FOR TAX CREDIT/SUBSIDY LAYERING REVIEW 1. Narrative description of the project. This should include the total number of units, including bedroom distribution. If only a portion of the units will receive project-based rental certificate assistance, this information is needed for both the project as a whole, and for the assisted portion. 2. Sources and Uses of Funds Statements. Sources: List each source separately, indicate whether loan, grant, syndication proceeds, contributed equity, etc. Sources should generally include only permanent financing. If interim financing or a construction loan will be utilized, details should be included in a narrative (item 3. Below). Uses: Should be detailed. Do not use broad categories such as soft costs. Acquisition costs should distinguish the purchase price from related costs such as appraisal, survey, title and recording, and related legal fees. Construction and rehabilitation should include builder s profit and overhead as separate items. 3. Narrative describing details of each funding source. For loans, details should include principle, interest rate, amortization term, and any accrual, deferral, balloon or forgiveness provisions. If a lender, grantor, or syndicator is imposing and reserve or escrow requirements, details should be included in the narrative. If a lender will receive a portion of the net cash flow, either as additional debt service or in addition to debt service, this should be disclosed in the narrative. 4. Commitment Letters from lenders or other funding sources evidencing their commitment to provide funding to the project and disclosing significant terms. Loan agreements and grant agreements will suffice. 5. Appraisal Report. The appraisal should establish the as is value of the property, before construction or rehabilitation, and without consideration of any financial implications of tax credits or project-based rental certificate assistance. An as-build or after-rehab appraisal is not acceptable unless it also includes an as is valuation. 6. Stabilized Operating Proforms: Should include projected rental, commercial and
5 miscellaneous income, vacancy loss, operating expenses, debt service, reserve contributions and cash flow. Headquarters analysis will project these costs over the 15 year tax credit compliance period. Income and expenses will be trended at three percent. 7. Tax Credit Allocation Letter: Issued by the State tax credit allocation agency, this letter advised the developer of the amount of the low-income housing tax credits reserved for the project. If available, IRS form 8609 will suffice. If the project is in a designated difficult to develop area, it may be receiving additional credits above those to which it would normally be eligible. When applicable, this should be pointed out in the submission. It may not always be reflected in the allocation letter. 8. Historic Tax Credits: Some projects in designated historical districts may receive an additional one-time historic tax credit. When applicable, the amount of the historic credit should be disclosed. 9. Equity Contribution Schedule: If contributed equity will be paid in installments over time, a schedule should be provided showing the amount and timing of planned contributions. 10. Bridge Loans are often used when equity contributions are planned over an extended period, so that proceeds will be available to the project up front. If the financing plan includes a bridge loan, appropriate details should be provided.
6 THE FOLLOWING ITEMS SHOULD BE PROVIDED BY THE HUD FIELD OFFICE. 1. Initial Contract Rents: Copy of letter from HUD Field Office to PHA approving initial contract rents, if issued. Otherwise, transmittal memo should explain field office position of initial contract rents. PLEASE NOTE: Exception Rents must be approved by HUD on project-based rental certificates. PHAs must request HUD approval of exception rents and cannot approve exception rents themselves. 2. The field office Architectural, Engineering and Cost Branch should review proposed construction/rehabilitation costs to determine if they are reasonable. 3. The field office Architectural, Engineering and Cost Branch or Valuation Branch should review projected operating expenses to ensure that they are reasonable for a project of the size, type, age and location of the proposed project. PLEASE NOTE: FIELD OFFICES SHOULD NOT SEND DUPLICATE DOCUMENTS. ONLY ONE COPY OF A SCHEDULE, LETTER, OR MEMORANDUM IS NEEDED.
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