Multifamily /Asset Management and Compliance. NEAHMA RI Agency Meeting

Transcription

1 Multifamily /Asset Management and Compliance NEAHMA RI Agency Meeting

2 Department Updates Asset Management and Compliance assigned to Development Division Better coordination with loan officers and design & construction staff Working closely with loan officers at underwriting to ensure that proposed income and expense projections are reasonable Compliance staff visiting new projects during construction

3 Priorities for 2017 Create a new LIHTC Compliance Manual Automate LIHTC file reviews Create and publish concise Asset Management guidelines Share detailed portfolio operating expense data with owners and managers Escrow Analysis Additional Trainings

4 RI Housing Program Bulletin Bulletin_ _IOS_12.20.pdf Amends policy related to submission of financial reports Now required quarterly (was monthly) Effective with quarter ending March 31, 2017

5 Interim Operating Statements (IOS) Form HF150 Change to Quarterly vs. Monthly will reduce the volume of required submissions by property managers and also will reduce both paper and preparation time receipt is preferred, however if not an option, paper will be accepted If site financial staff is not aware of change to quarterly, please inform the correct staff of this change packages to:

6 RI Housing Program Bulletin ulletin_ _escrow_analysis.pdf Establishes policy related to minimum required funding levels in escrow accounts and procedure for issuing refunds / collecting shortages For new transactions (new construction and refinance), analysis of escrow accounts will begin in the second year of operations Analysis is currently in process and will be completed annually going forward

7 RI Housing Program Bulletin (cont.) For new transactions (new construction and refinance), analysis of escrow accounts will begin in the second year of operations Analysis is currently in process and will be completed annually going forward

8 Asset Management Rhode Island Housing s Asset Management Department is looking closer at Development operations. HUD is doing the same. HUD requires quarterly updates regarding operating performance of Developments insured by HUD s Risk Share Program. Rhode Island Housing must advise HUD on what steps are being taken to manage the challenges. We may request updates from property manager if there are large fluctuations in key areas of asset management on a quarterly basis which may need to be communicated to HUD.

9 Fair Housing and VAWA It s the Law! The VAWA Reauthorization Act was signed into law on March 7, Applies to ALL housing programs Rhode Island Housing requires that owner/agents incorporate these protections into lease forms, tenant selection plans, and resident policies relating to unit transfers and changes to family composition. HOME

10 Fair Housing and VAWA (cont.) Rhode Island Housing updating written agreements and lease addendum Rhode Island Housing required to provide the following documents: - HOME Emergency Transfer Plan - Notice of Occupancy Rights - Certification of Victim form - Emergency Transfer Request form

11 De-coupling file reviews and physical inspections Rev. Proc modifies the 20% rule Lesser of: 20% of LIHTC units in the project, OR number provided in unit sample size reference chart in revenue procedure.

12 De-coupling file reviews and physical inspections (cont.) Selected units for inspections may differ from files to be reviewed Units must be selected separately and randomly No advance notice of which units May conduct physical inspections and file reviews at different times

13 De-coupling file reviews and physical inspections (cont.)

14 REAC Inspections Three Rhode Island Housing staff currently certified as REAC inspectors and two staff in process of certification. Will inspect to HUD protocol HUD tightening oversight/more QA visits Ensure vacant units are ready Provide proper notification to tenants.

15 REAC Inspection = LIHTC Inspection Rev. Proc permits the inspections conducted under REAC protocol to satisfy the physical inspection requirements of Section 42 If HUD makes the REAC inspection report available to RI Housing, we will treat the REAC inspection as the LIHTC inspection

16 IRS Form 8823 RI Housing has increased the issuance of Form 8823 (Report of Noncompliance) At the direction of the Internal Revenue Service Majority are issued as a corrected deficiency Typically only issued for exigent health and safety violations and noncompliance related to resident eligibility

17 Industry Standard Repairs Standards are applicable to all properties that are subject to UPCS physical inspections. Inferior repairs - not acceptable All repairs must be made in a good and workmanlike manner with materials that are suitable for the purpose and free from defects

18 Industry Standard Repairs (cont.) Examples of inspectable items that are often incorrectly repaired: Cracks in Brick Wall. Tuck-pointed using mortar is the correct means of repair; caulking is not appropriate. Drywall Repair. Sheetrock with mud and/or tape is the correct means of repair. Simply covering hole or damaged drywall with plywood or laminate is not correct. Wooden Door Repair. Wood or wood veneer is the correct material for repair. Sheetrock mud or plywood is not correct. Downspouts. Same materials, shape and design are correct. Plastic or PVC piping is not correct.

19 Asset Management/Compliance Contacts Assistant Director of Asset Management/Compliance - Michael DiChiaro, mdichiaro@rihousing.com Multifamily Compliance Supervisor Kathleen Millerick, kmillerick@rihousing.com LIHTC Program Multifamily Compliance Specialists: Glen Turner, gturner@riousing.com Jill Rioles, jrioles@rihousing.com Craig Scorpio, cscorpio@rihousing.com Lenore Coughlin, lcoughlin@rihousing.com HOME Program Compliance Specialist: Brittany Toomey, btoomey@rhodeislandhousing.org

20 Asset Management/Compliance Contacts Multifamily Loan Workout Specialist and Quality Control Manager - Susan Halloran, shalloran@rihousing.com Financial Accountant, Asset Management and Compliance - Kate Mashburn, kmashburn@rihousing.com Asset Management Compliance Specialist - Jamie Wolcott, jwolcott@rihousing.com

21 Questions? Thank you!