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:
3560. The long awaited 3560 proposed regulations have been commented on by CARH and other groups. The Agency seems to think that Final Regulations could be out in much less than a year.
3560 HANDBOOKS. The Agency approach is to put the policies in the 3560 regulation and the implementation in the 1,000+ pages of Handbooks.
3560 POLICY: CONVENTIONAL RENTS FOR COMPARABLE UNITS. (Or is it Comparable Rents for Conventional Units?) This confusing proposed CRCU policy (in search of a word pronunciation such as CRUCial) could result in basic rents below what is needed for project operations.
FRANCONIA ASSOCIATES TRIAL. The June trial for damages seems to have been very successful; watch www.faegre.com for updates, possibly including a transcript.
MANAGEMENT PLANS. Now is a good time to review project management plans to make sure they fully describe duties, responsibilities, and expenses charged to projects.
RHS INSIDE BASEBALL:
With continuing retirements, changes in senior staff in Washington, D.C., and the prospect of 3560, the Agency is going to be in dire need of direction and major training.
Some Agency offices will try to implement 3560 before it is official and before they have received adequate training.
It is anybody’s guess when and if Agency 3560 training will take place.