FOR YOUR INFORMATION
I consult with owners and managers on the full range of 515 issues: appraisal 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. REGULATION and HANDBOOKS: As always, soon.
3560 POLICY: CONVENTIONAL RENTS FOR COMPARABLE UNITS. (Or is it Comparable Rents for Conventional Units?) This confusing proposed CRCU policy could result in basic rents below what is needed for project operations; it may apply only to new projects.
FRANCONIA ASSOCIATES: Stay tuned.
TENANT CERTIFICATIONS: OIG is in hot pursuit of tenant income being under-reported; wage matching (done by whom?) could result in more income being reported and less RA being used.
RENTAL ASSISTANCE: The GAO has found major problems with Agency administration of RA. The Agency disagrees.
RHS INSIDE BASEBALL: The RHS Administrator was appointed in mid-July: Russell T. Harris. He comes from Treasury; in Bush 1, was at HUD. He seems to have substantial experience in finance and in affordable housing.
The 515 inspection report and portfolio study may be monumental for the program; stay tuned.