I consult with owners and managers on the full range of 515 issues:
appeals related to OIG audits; Workout Plans; appeals of adverse RHS
decisions; issues with the Agency; and, prepayments and equity loans.
RENT INCREASES. Be sure to request rent increases to cover maintenance
costs, capital improvements, and cure any physical deficiencies.
PROJECT CLASSIFICATION. Do whatever it takes to get any project out of
a
“D” Classification; a Workout Plan may be needed.
PENDING LEGISLATION. H.R. 1776 includes additional criminal provisions
for fraud, waste and abuse; no hearings have been held; it may criminalize
incompetence and stupidity.
MANAGEMENT AGREEMENTS. Revise Agreements and Plans to describe in full
detail all services and how costs are allocated.
3560. Watch for Mark-to-Market provisions for rent increases, rehab
loans
and transfers in the proposed rule and handbook.
THIRD PARTY EQUITY LOANS AS PREPAYMENT INCENTIVES. The Agency now
permits
an equity loan to be funded by a conventional lender. Thus, it may not be
necessary to wait for an equity loan. With the Agency outlook on RA and
enforcement, however, it may be best to consider prepaying.
OIG AUDIT. Equity Skimming and Identity of Interest are hot buttons in
the program. Look for increased OIG Audits, Investigations and indictments.
And, look for increased Agency concerns.
I have worked with and advised owners, developers and managers on 515 program issues and problems since 1988. If you have an issue with RHS or on your projects, or don’t have the expertise on your staff, please contact me.