Patrick Sheridan
Assistant Deputy Administrator,
Multi-Family Housing,
Rural Housing Service, USDA
Washington, D.C.
Addressing CARH:
On Tax Credit monitoring, we said we would touch base with NCSHA
(National Council for State Housing Agencies) and do some checking around to
find what the average Tax Credit Monitoring Fees were and how the different
states were administering it. What we did find out is they are not very
consistent in how they are assessed. Now I think what we did find out is
that
the average fees tended to be about the same, but how they assess it against
the owners of the project vary quite a bit. Given that it doesn’t appear it
is an astronomical charge like it used to be a few years ago, we are moving
toward allowing that as a project expense; we haven’t gotten anything out
official about that yet. We are working on an AN to do that and we will make
sure the handbooks reflect that when the handbooks come out. It is not an
issue for the actual regulation itself since that is a little broader brush.
It would be covered under the regulation the way it is written right now as
a
proposed rule, but we are in a position where we can put it in a handbook.
The other issue is Lease-up fees. It is an area we are looking into. We
mentioned it in a teleconference with our States that as long as Lease-up
Fees were reasonable, it would be something that could be covered. If I
remember right, we were told CARH would provide some proposed language to
look at and maybe include in the handbook.
On educational fees and membership dues, Colleen Fisher and I have had a
number of discussions about that over the past month or two. We will be
putting out an AN clarifying what our position is with that. We are looking,
again, for a little bit of guidance there, to work with you on the
allowability of educational fees versus membership dues in organizations. I
think we are in the position that once we have sort of worked out a position
that works well between your organization and the other organizations we
work
with and ourselves as program staff, we will also be able to run that by the
Office of Inspector General to get their views on the concepts so we’re all
on the same page, at least to start on that. We will be doing an AN on that
in the near future. Along with Tax Credit monitoring, the educational fees
and membership dues — our goal on that as far as issuing an Administrative
Notice is to try to do it before we have our August Policy Meeting so we can
address it with field staff so they are up to speed on that.