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R&C Housing Notices

270th Edition: 2/24/2020-2/28/2020

News of Note

HUD Defines "Small Rural PHA," Rolling Back Environmental Review Requirements for Small PHAs and Small-Scale Redevelopment Projects
On February 27th, HUD issued a notice outlining small PHA designations and small-scale redevelopment project exemptions under Section 209 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. HUD's notice exempts small rural PHAs from environmental reviews for development and modernization projects less than $100,000 and reduces Section 8(o) voucher unit inspection requirements for small rural PHAs.
HUD Updates Administrative Guidelines and Requirements for PBV Subsidy Layering Reviews
On Friday, February 28th, HUD issued updated administrative guidelines for Project-Based Voucher and Mixed-Finance public housing Subsidy Layering Reviews (SLRs). The guidelines update SLR requirements for HOTMA, clarify the process for requesting SLRs and provide transparency on HUD's expectations and methodology. The administrative guidelines are effective as of their publication.
Reno & Cavanaugh Submits Comments with CLPHA on HUD's Project Based Voucher (PBV) Online Form
In response to HUD's proposed information collection for PHAs administering PBVs, R&C and CLPHA submitted public comments on February 24th. HUD's initial notice, published in late December 2019, proposed collection of project-level data to evaluate the PBV program. Among other provisions, CLPHA and R&C cited HUD's unfunded request for information, a preponderance of which HUD presently collects from PHAs and owners.
Supreme Court Stays Illinois State Public Charge Injunction
Following the Supreme Court's nationwide injunction of the Department of Homeland Security's controversial "Public Charge" rule, the Supreme Court granted a stay to the only remaining challenge to the rule in the State of Illinois. The Court's decision came ahead of the rule's nationwide implementation Monday, February 26th.

Upcoming Events

R&C Attorneys to Speak at the RAD Collaborative Southwest Regional Convening
February 29, 2020

R&C Members Steve Holmquist and Julie McGovern, and Associate Cody Bannon will speak alongside HUD officials and affordable housing professionals at the RAD Collaborative Southwest Regional Convening, To RAD & Beyond! in Austin Texas. On March 5th, Julie McGovern will discuss PHA roles in RAD and means of assuring the PHA Mission and Steve Holmquist will moderate a session on "National and Regional Experiences-Portfolio, Development, Subsidy & Financing Options." Cody Bannon will participate on a panel discussing practice strategies and solutions to portfolio repositioning and redevelopment on March 6th . Interested individuals may register for the conference here.

Felicia Hulit to Speak at Eastern Lenders Association Annual Conference
March 11-13, 2020

R&C Member Felicia Hulit will speak on "Chapter 9 Environmental Updates" at the 2020 Eastern Lenders Association (ELA) Annual Conference in Baltimore, MD. Register for the conference here.

R&C Attorneys will present on Year 15 and Year 30 LIHTC Strategies
March 18, 2020

R&C Member Matthew Greeson and Of Counsel Vonda Orders will present "Soup-to-Nuts: Year 15 and Year 30 Preservation Strategies, Structures, and Financing" at the Maryland Department of Housing and Community Development in Lanham, MD. As a part of the Housing Association of Nonprofit Developers' "Training & Capacity Building Series," this presentation will cover disposition, negotiating exit, and disposition strategies. Interested individuals may register for the series here.

Lisa Tunick to Speak on HUD Contracting Pitfalls at LeadingAge Event
March 24, 2020

R&C Member Lisa Tunick will present on "HUD Contracts and Pitfalls for Owners/Managers" at LeadingAge Georgia and South Carolina's 2020 Joint Annual Conference on Aging & Trade Show in Greenville, SC on March 24. Access more information on the conference here.

Federal Register Notices

HUD Seeks to Revise Budget Worksheet for Reasonableness of Rent Increases

60-Day Notice of Proposed Information Collection

February 25, 2020
85 FR 10710

HUD solicits comment on its proposed revisions to HUD 92457-a, a worksheet used by HUD Field staff to collect owner budgetary information and determine the reasonableness of requests for Budget-Based rent increases. Comments are due April 27, 2020.
PDF | Text

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