FOR YOUR INFORMATION
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.
I have the following comments on the program:
DRAFT 3560. I remain concerned that when it is published for comment,
its provisions will adversely affect the interests of the Agency, Owners
and
Tenants. Stay tuned.
RA COST. Given the concerns over the cost of RA, there must be ways
either to reduce the cost, or maximize the benefits, such as moving RA to
projects which need it from projects which don’t. Perhaps a Task Force is in
order.
REHAB FUNDS. Without rehab money, the program will implode.
COMPARABLE RENTS FOR COMPARABLE UNITS. The Agency continues to seem to
believe such a policy should be applied to existing projects in truly rural
areas.
MANAGEMENT FEES. I have won appeals of Management Fees where the State
Office had put out an AN in an attempt to set fees. Call me to discuss
doing
the same for you.
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.