Duplication of Benefits DRAFT Submitted to HUD: July 3, 2013

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1 Duplication of Benefits DRAFT Submitted to HUD: July 3, 2013 Introduction This duplication of benefit plan explains methods and procedures to prevent the duplication of benefits, as required by the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) [at 42 U.S.C. 5155(a)], the Disaster Relief Appropriations Act, 2013, the Small Business Act, and other authorities. Although the potential for duplication of benefits arises most frequently under homeowner rehabilitation programs, it is not limited solely to that program type. Therefore, this Plan seeks to provide general, cross cutting policy that can apply to any program. The Luzerne County is creating several disaster recovery programs and must consider whether one program will duplicate assistance provided by another program, even when the secondary program is funded entirely with non federal funds. The following Plan provides structure for departments or other organizations implementing disaster recovery programs in determining the amount of Community Development Block Grant (CDBG) disaster recovery assistance that will not duplicate assistance from other resources. For purposes of this plan, the term County refers to the Luzerne County and its agencies responsible for delivering CDBG Disaster Recovery assistance. A. Assessment of need prior to assistance. B. Total assistance available to the person or entity C. Non duplicative assistance excluded from final benefit calculation. 1. Funds for a different purpose 2. Funds for same purpose, different eligible use. 3. Funds not available to the applicant. 4. Private loans. 5. Other assets or lines of credit. D. Unmet need. E. Calculate CDBG disaster recovery award. F. Use of CDBG Disaster Recovery Funds 1. Use of funds for explicit and eligible purposes. 2. Treatment of SBA Loans. 3. Duplication of Benefit Subrogation G. Collecting a duplication of Benefit H. Administrative Procedures for Identifying the Duplication of Benefits I. Applicable Law and HUD Guidance J. Processes Specific to Residential Property Owner Assistance A. Assessment of need prior to assistance. The County will first determine the applicant s total post disaster need in the absence of any duplicative benefits or program caps. Following the identification of total need, duplicative assistance can later be subtracted and program caps applied to arrive at a final award. A rebuilding project s cost estimate is often able to serve as the best demonstration of need.

2 Some recovery programs not involved with physical rebuilding, such as economic development or revitalization to provide an affected business with working capital, may not necessarily base awards on construction cost estimates. In such scenarios, the potential award may be determined by the program and be guided by standard underwriting principles; however, it must still be determined to be cost reasonable. B. Total assistance available to the person or entity. Assistance includes all benefits available to the person or entity including donations or gifts of cash and other resources such as insurance proceeds, grants, and SBA loans. Private loans not guaranteed by SBA are excepted. (See paragraph C.) The County will identify all assistance received by each person, business concern, or other entity, via insurance, FEMA, SBA, other local, state, or federal programs, and private or nonprofit charity organizations, either directly from the sources or through a required Applicant signed certification. See, FEMA Disaster Assistance Policy , Duplication of Benefits Non Government Funds. The County will also identify reasonably anticipated assistance, such as future insurance claims payments or approved SBA loan proceeds, either directly from the sources or through a required Applicant signed certification. Reasonably anticipated funds include assistance that has been awarded, but has not yet been received. For example, assume a business was approved to receive an SBA loan for $30,000, but had only received $20,000 when it applied for CDBG disaster recovery assistance for the same purpose. The County would identify the full amount of assistance for which the applicant was approved ($30,000). Funds are not reasonably anticipated when the source and/or amount is indefinite, or the applicant is unaware that he/she may be eligible to receive additional funds at a later date. To address any potential duplication, beneficiaries must enter a signed agreement to repay any assistance later received for the same purpose as the CDBG disaster recovery funds. Please note that if additional need is established, use of subsequent funds for additional need would not be considered duplication. See paragraph E, Unmet Need, for more information on this issue. C. Non duplicative assistance excluded from final benefit calculation. Once the County has determined the potential award and the total assistance received or to be received, it may exclude for duplication of benefit purposes, assistance that was: (1) provided for a different purpose than for the program from which the Applicant seeks assistance; (2) used for a different, eligible purpose within the same program; (3) not available to the applicant; (4) a private loan not guaranteed by SBA; or (5) any other asset or line of credit available to the applicant. Below, each of these categories is explained in greater detail. 1. Funds for a different purpose. Any funds provided for a different purpose, or a general, non specific purpose (e.g., disaster relief/recovery ), may be excluded from the final award calculation if they were not used by the applicant for the same purpose. Funds provided to a property owner typically fall under one of the following categories: replacement housing, rehabilitation assistance, or interim (i.e., temporary) housing. Funds provided for replacement housing are generally easy to identify they assist an individual or household to secure a replacement

3 home in the event their disaster affected home cannot be rehabilitated. This includes, but is not limited to, downpayment assistance, interim mortgage assistance, and acquisition of the damaged property. While these types of funds may be delivered through separate programs, they all have a uniform purpose to equip an individual or household with the funds necessary to gain replacement housing. Rehabilitation includes repair and reconstruction. If a property owner receives rehabilitation funds from CDBG disaster recovery, all other assistance provided to address that home s rehabilitation must be included. If award amounts are related to a property s value or estimated cost of repair/replacement, then HUD will consider them to be for the purpose of rehabilitation or reconstruction of housing. Funds provided for interim housing, that would be provided if a household is temporarily unable to reside in its permanent residence, are considered to have a different purpose than rehabilitation or replacement housing. For example, if FEMA funds were eligibly used for interim housing, and CDBG funds were provided for home rehabilitation, there is no duplication regarding those the use of funds because the funds were provided for different purposes. However, any FEMA funds eligibly used for housing replacement or rehabilitation must be considered for that purpose. Economic development programs may address many unique purposes. Thus, for a more effective administration of these programs, each should be carefully designed from the beginning with clear, identified purposes for the use of the funds. Finally, when providing funds for the repair, replacement, rehabilitation, or new construction of public facilities or improvements, the County must address whether other sources of funds are available for that same purpose and for that specific project because funds used directly by the County or other government entities for public facilities or other purposes are also subject to the duplication of benefits prohibitions under the Stafford Act. 2. Funds for same purpose, different eligible use. Funds used for a different eligible purpose may be excluded from the final award calculation. In some instances, funds provided for the same general purpose as the CDBG disaster recovery funds will have been used by the applicant for a different specific eligible purpose. In these circumstances, if the applicant can document that the funds received were used for a different, eligible purpose, then the funds are not duplicative. In general, acceptable documentation may include, but is not limited to, receipts as well as sworn statements and certifications that can be verified or substantiated. FEMA requires individuals to keep receipts or bills for three years to demonstrate how all FEMA funded assistance was used in meeting an eligible, disaster related need. (Note that for CDBG disaster recovery assistance, HUD requires recipients and subrecipients that are governmental entities to retain records for four years (24 CFR (a)(16)).) The County will notify applicants of this requirement when submitting an application for CDBG assistance that supplements FEMA assistance already received. Whether the funds are used for an eligible purpose is dependent upon the program that provided the funds. For example, assume the County is administering a property owner rehabilitation program and an applicant to the program previously received housing assistance from FEMA. If the applicant can document that the FEMA funds were used for eligible interim housing costs (such as rent, in accordance with FEMA program eligibility), and not housing replacement or rehabilitation (which may also be an eligible use of the funds), then his or her CDBG award for permanent housing should not be reduced by the amount of FEMA assistance used for interim housing. Because FEMA may allow its recovery funds to be used for multiple purposes, CDBG disaster recovery funds may not duplicate the ultimate use of the FEMA funds.

4 3. Funds not available to the applicant. Funds that are not available to an applicant may also be excluded from the final award calculation. A benefit is available if a person or entity: (1) would receive it by acting in a commercially reasonable manner, or (2) has received it, and has legal control over it. Commercially reasonable efforts refer to efforts that use a standard of reasonableness defined by what a similar person would do as judged by the standards of the applicable community. Commercially reasonable efforts should be consistent with good faith business judgments. For example, it may be commercially reasonable for a person to elect to receive a lump sum insurance settlement based on estimated cost of repairs to avoid transaction costs associated with the alternative of receiving reimbursement based on actual replacement cost; any additional benefits that theoretically might have been received under another settlement option do not reduce eligibility for assistance. Funds are not available to the person or entity if the person does not have legal control of the funds when they are received and are used for a non duplicative purpose. For example, if a property owner s mortgage requires any insurance proceeds to be applied to reduce the lien balance, then the bank/mortgage holder (not the property owner) has legal control over those funds. Therefore, the property owner is legally obligated to use insurance proceeds for that purpose and does not have a choice in using them for any other purpose, such as to rehabilitate the house. Under these circumstances, insurance proceeds do not reduce assistance eligibility. Alternatively, if a disasteraffected property owner chooses to apply insurance proceeds to reduce an existing mortgage, or requests that the lender demand payment, insurance proceeds reduce the amount of disaster assistance eligibility. In addition, if a mortgage requires insurance proceeds to be used for rehabilitation of the property, those proceeds must be considered as assistance for that purpose. A property owner does not need to possess cash assistance to be considered as being in legal control over receiving benefits for a particular purpose. For example, it is common for property owners to choose to apply to local or state administered housing repair or reconstruction programs where the program administrator acts directly to complete the repairs for the property owner. In this case, the person asks/applies for $10,000 worth of repairs (for example) and the benefit they receive is $10,000 in repair work to the home. The person does not need to have personally possessed the $10,000 in order to be in legal control over receiving that benefit for that specific purpose. 4. Private loans. Similarly, for duplication of benefits purposes, private loans may be excluded from the final award calculation. Unlike SBA loans (or any other subsidized loan or federal loan guarantee program that provides assistance after a major disaster or emergency), private loans not guaranteed by SBA need not be considered duplicative assistance. Congress provided for SBA loans (both direct and guaranteed) as part of the overall statutory scheme for disaster recovery. As such, SBA loans are made pursuant to a government program. Since private loans are not provided under a government program, they do not need to be considered as potentially duplicative assistance. However, when making final award determinations, necessary and reasonable cost principles such as OMB Circular A 87 (2 CFR part 225) apply. While private loans need not be considered for duplication of benefit purposes, the County is not prohibited from considering loans for other purposes, such as underwriting. The loan must meet the private loan definition. Private loans are defined as non federal loans (neither direct nor guaranteed) that are made in a commercial lending transaction for fair market rates with a willing borrower and willing lender, under standard commercial lending terms in which the borrower must repay the full amount of the loan (plus

5 interest, if applicable). This includes private loans for construction and bridge financing, but not forgivable loans. This policy applies regardless of whether the borrower is a business or an individual. 5. Other assets or lines of credit. Other assets or lines of credit available to a property owner or a business owner need not be included in the award calculation. This includes, but is not limited to: checking or savings accounts, stocks, bonds, mutual funds, pension or retirement benefits, credit cards, mortgages or lines of credit, and life insurance. Please note that these items may be held in the name of an individual, or in the name of a business. D. Unmet need. Long term recovery is a process. However, disaster recovery needs are calculated at points in time. As a result, a subsequent change in circumstances can affect need. If, after needs are initially calculated and/or a CDBG award has been made, an applicant for CDBG disaster recovery assistance can demonstrate a change in circumstances, such as vandalism, contractor fraud, an increase in the cost of materials and/or labor, a change in local zoning law or building code, or subsequent damage to a home or business that was partially repaired, the County may subsequently reevaluate the calculation of the award by taking into account the increased need. However, any reevaluation must be done before the initial need for which the assistance was granted has been fully met (e.g., before the damaged house is fully repaired). In effect, once the house is fully repaired, the need resulting from the disaster impact will have been fully met; but actual costs to the point of completion are eligible. Oftentimes, unmet need does not become apparent until after CDBG disaster recovery assistance has been provided. For example, a subsequent storm or disaster may affect the unrepaired house or business of an individual or entity that was previously assisted by CDBG disaster recovery for a prior disaster. Therefore, additional CDBG disaster recovery assistance can be provided to meet the outstanding need to the extent that an original disaster recovery need (e.g., rehabilitation of a home) was not fully met, but was exacerbated by other factors beyond the government s and individual s control (e.g., lack of contractor availability or vandalism). The County has discretion to determine the best way to determine and verify additional or unmet need. Physical inspection will be conducted by County approved professionals, including but not limited to County personnel, licensed architects, engineers, and general contractors. If a subsequent appraisal demonstrates that the CDBG award is in excess of need, the County should evaluate whether a duplication of benefits has occurred or whether the applicant s award should be reduced based upon program eligibility criteria. E. Calculate CDBG disaster recovery award. The calculation may look as follows: (1) Identify total post disaster need prior to any assistance; (2) Identify potentially duplicative assistance; (3) Subtract all assistance found to be duplicative, resulting in the maximum potential award amount, or unmet need.

6 F. Use of CDBG Funds 1. Use of funds for explicit and eligible purposes. CDBG disaster recovery funds must be used for eligible purposes of the program or activity for which they have been provided. That is, CDBG funds provided for the sole purpose of repairing a home should be used strictly for the repair of that home. They should not be used for any other purpose. Similarly, funds provided to a business for equipment replacement, or structural repair, should be used only for those purposes. While some business assistance programs may provide for profit entities with working capital, this purpose should be clearly identified from the outset of the program so as not to duplicate other programs or working capital assistance. 2. Treatment of SBA Loans. CDBG disaster recovery funds may not be used to pay down an SBA home or business loan. In cases where initial SBA loan amounts approved based on estimated costs are later determined to be inadequate relative to the actual costs to complete home repairs or reconstruction, the SBA will consider re evaluating an applicant s maximum eligibility to explore if additional assistance may be provided. This also applies to recipients of SBA business loans (including loans for working capital). If need remains after all SBA eligibility has been exhausted, supplemental disaster recovery CDBG funds may be used to address that need. SBA loans are among the Federal government s primary and standard forms of disaster assistance. As disaster recovery CDBG funds are provided by Congress through supplemental appropriations only in extraordinary circumstances, these funds are intended to supplement rather than supplant ongoing disaster recovery programs from the FEMA, USDA, and SBA. 3. Duplication of Benefit Subrogation All applicable claims (including insurance payments, unpaid claims, lawsuits, and settlements) paid to applicants not included in the original benefit determination calculation and/or after their closing appointment, must be subrogated to the County to prevent a duplication of benefits. Only claims designated for the same purpose are required to be subrogated to the County. The Subrogation Agreement is signed at Initial Closing and forwarded to the insurance company. In the event that a claim is settled after Initial Closing, the County will determine if it is subject to subrogation. The County will verify the claim with the insurance company to ensure that only funds for the same purpose of assistance are subrogated. The County will perform a calculation to determine the amount necessary to be subrogated. The required subrogation amount will be any claims received up to the applicant's amount of assistance. G. Collecting Duplication. If a potential duplication is discovered after CDBG disaster recovery assistance has been provided, the County may reassess need at that time. If additional need is not demonstrated, disaster recovery funds could be recaptured to the extent they are in excess of the need and duplicate other assistance received by the beneficiary for the same purpose. However, it may depend on what funds were provided last.

7 Under the Stafford Act, a federal agency that provides duplicative funds must collect those funds. FEMA regulations at 44 CFR set forth a hierarchy of delivery that determines the order in which beneficiaries should receive federal assistance. This hierarchy is based on which agency has the primary responsibility for providing assistance following a disaster, not which agency actually delivers the assistance first. As an example, in most situations, FEMA and SBA assistance is provided to individuals before supplemental disaster recovery CDBG assistance is able to be delivered. However, there may be cases in which, prior to receiving FEMA or SBA assistance, an applicant receives CDBG assistance for a purpose for which they are FEMA/SBA eligible. In this latter case, subject to the agreement that the County would have in place with the applicant, the applicant would reimburse the County in an amount equal to all duplicative FEMA or SBA funds subsequently received for purposes which CDBG funds were initially used. The regulations at 44 CFR (d) explain that a duplication of benefits occurs when an agency provides assistance which was the primary responsibility of another agency, and the agency with primary responsibility later provides assistance. When the delivery sequence has been disrupted, the disrupting agency is responsible for rectifying the duplication. Since CDBG disaster recovery provides long term recovery assistance via supplemental congressional appropriations, and falls lower in the hierarchy of delivery than FEMA, USDA or SBA assistance, it is intended to supplement rather than supplant these sources of assistance. If CDBG disaster recovery funds or non federal funds were provided last and unknowingly create a duplication, the method of recapturing the CDBG funds, and the timeframe, are consistent with OMB Circular A 87 (2 CFR part 225), HUD Office of the Inspector General, and the Stafford Act, in accordance with chapter 37 of title 31, relating to debt collection. H. Administrative Procedures for Identifying the Duplication of Benefits 1. For each CDBG disaster recovery funded program, the County will identify potential assistance from insurance, federal and state government, County agencies, and private or nonprofit charity organizations (covered assistance) that it reasonably expects to be in a project or to otherwise be received by a beneficiary of CDBG disaster recovery assistance. 2. All applicants for assistance from the County s CDBG disaster recovery allocation will be required to identify their other sources and amounts of covered assistance (sources and uses), and to certify that the CDBG disaster recovery assistance requested does not duplicate other covered assistance that has been received or is reasonably expected to be received. 3. In any application for CDBG disaster recovery assistance, the County will require beneficiaries to agree to repay any assistance later received for the same purpose as the CDBG disaster recovery funds. 4. In conjunction with its actions to prevent fraud, waste, and abuse, the County will employ data systems and data sharing and data matching to identify duplication of benefits. The County will enter into data sharing agreements with relevant federal and state agencies, and other entities, as appropriate. 5. The County will include duplication of benefits among its review criteria in monitoring for compliance with applicable laws, regulations, and other authorities.

8 I. Applicable Law and HUD Guidance Public Law 113 2: Disaster Relief Appropriations Act, 2013(at HR152 34) Signed January 28, 2013 Section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5155), as amended Section 18 of the Small Business Act, as amended (14A U.S.C. 647) 44 CFR Duplication of Benefit HUD Federal Register Notice at 76 FR published November 16, 2011 HUD Federal Register Notice at 77 FR published April 16, 2012 HUD Federal Register Notice at 78 FR published March 5, 2013 HUD Federal Register Notice at 78 FR published April 19, 2013 HUD Federal Register Notice at 78 FR published May 29, 2013 J. Processes Specific to Housing Programs Duplication of benefit includes payments made to the applicant by identified parties representing disaster assistance for the same purpose for which the Housing Programs are providing assistance. Each applicant for CDBG disaster recovery funds will complete a duplication of benefits analysis specific to such application, which includes a signed attestation by the applicant that all required information has been disclosed and further agrees to provide to the County on a timely basis any new pertinent information such as receipted of additional funds, not known at time of signing the application. If such analysis discloses any duplication of benefits, the proposed expenditure will be reduced by such amount. During the period of draw down of funds, if the County discovers or the applicant discloses additional funds' receipt that is determined to be a Duplication of Benefits, then the County shall reduce remaining drawdown availability by the amount of new funds received from other sources. If the drawdown balance equals less than the duplication amount, then in addition to withholding any further payments, the County will commence action to recover the funds. After expenditure, if the applicant voluntarily provides information to the County about additional funds from other sources having been received that may fall within Duplication of Benefits, then the County will make a determination as to whether, a) The funds are from a source that falls within Duplication of Benefits guidelines and b) Covers a cost within the unmet need amount upon which the release of CDBG funds was based. If there is an affirmative finding to both a) and b), then the County will offer the applicant a repayment plan of the amount of the Duplication over a reasonable period of time not to exceed (insert time period)

9 After expenditure, if the County discovers that the recipient has received a duplicate benefit, the following actions will be taken: (1) The recipient will be notified and offered the opportunity to provide written evidence that either the source of funds does not fall under Duplication of Benefits restrictions or that the additional funds were used to cover an eligible cost that was above the unmet need used as the determination for the award of the CDBG funds. (2) If such information is provided by the applicant in a timely manner of 30 days or less, then the County will reassess to determine whether additional need has been demonstrated that would qualify the applicant for additional benefits. To the extent that such additional need is demonstrated, the amount of duplication may be reduced or eliminated. If there is no response or insufficient response from the applicant, then the County will commence action to recover the funds based on: (1) Each owner of an assisted property will be required to sign an enforcement note and mortgage before receiving funds for repairs related to storm damage. The enforcement note and mortgage will require the owner to inform the County of, and to repay, any duplicate benefits. Failure to repay will be grounds for a foreclosure action to recoup the duplicate benefit which will be commenced by the County's Law Department upon being notified. (2) Each recipient will be required to sign an agreement before receiving interim payment assistance benefits. The agreement will require the recipient to inform the County of, and to repay, any duplicate benefits. If a recipient fails to repay duplicate benefits, the matter will be referred to the County's Law Department, which will commence litigation or utilize a collection agency to seek recovery of the duplicate benefit. Inputs Necessary to Calculate Assistance for Housing Rehabilitation or Reconstruction Construction Bid Award The bid amount is based upon the Home Evaluation work write up estimate conducted by County approved construction professionals, including but not limited to County personnel, licensed architects, engineers, and general contractors. The amount of the bid is the basis for the award calculation. Duplication of Benefits The following are some sources of funding assistance that may be available for structural damage and loss that are considered a duplication of benefits (DOB) in addition to CDBG Disaster Recovery: private insurance, FEMA Individual Assistance (IA), FEMA National Flood Insurance Program (NFIP), NFIP Increased Cost of Compliance (ICC), Small Business Administration (SBA) Disaster Loan programs, and other sources. Under federal law, DOB must be deducted from the amount of assistance in a rehabilitation assistance agreement. Any additional duplication of benefits received by the applicant after assistance is awarded must reduce the award amount. Funds received from any source, including flood insurance, FEMA, and hazard insurance, that were used to cover repair to the applicant s home do not reduce the amount of disaster assistance if the evidence of expenditures at least equals the amount of assistance and those expenditures are not included in unmet need request of assistance. Documentation must be provided demonstrating the cost and type of repair conducted. The County will conduct a work write up that will inspect, confirm and estimate value of repairs based upon applicant s statement of repair work already completed and verify that it is consistent with most current required building code provisions. Documentation for determining duplication of benefits for various funding sources is discussed below:

10 FEMA Individual Assistance (FEMA IA) FEMA IA will be determined and verified by the County through the FEMA database. If the County is unable to verify the FEMA IA amount through the FEMA database, it will use the payment amount provided by the applicant at the time of application. If an applicant is able to provide written, demonstrating that the FEMA IA amount provided by the FEMA database includes amounts not paid to cover structural loss, the County will use that documentation to adjust the FEMA IA payout amount used to calculate the housing rehabilitation or reconstruction assistance it provides. The documentation provided by the applicant must come from FEMA for the IA amount, and the documentation demonstrating all or part of IA was not used to cover structural loss must be in form and detail acceptable to the program. FEMA National Flood Insurance Program (NFIP) Insurance Any payments for loss to the dwellings under NFIP insurance claims are deducted from the amount the applicant is eligible to receive. Payments for contents or other expenses are not deducted from the applicant s award. The County will identify and confirm payment to applicants under NFIP policies using the NFIP database. If the County is unable to verify the NFIP insurance proceeds through the NFIP database, the County will use documentation supplied by the applicant. If an applicant is able to provide documentation demonstrating that the insurance proceeds amount provided by the NFIP database includes items not covered in the home evaluation or not paid to cover structural loss, the County will use the documentation provided by the applicant to adjust the insurance payout used to calculate the housing rehabilitation or reconstruction assistance it provides. The documentation provided by the applicant must come from the insurance company which issued the payments and be verifiable by the insurance company. Increased Cost of Compliance (ICC) under NFIP Increased Cost of Compliance (ICC) coverage is one of several resources for flood insurance policyholders who need additional help rebuilding after a flood. It provides up to $30,000 to help cover the cost of mitigation measures that will reduce flood risk. ICC coverage is a part of most standard flood insurance policies available under the National Flood Insurance Program (NFIP). The County will determine duplication of benefits regarding ICC funds provided by NFIP. The County will identify and confirm payments to applicants under ICC policies through the NFIP database. If the County is unable to verify the NFIP ICC amount through the NFIP database, the County will use documentation supplied by the applicant. The documentation must be in sufficient detail to be independently verifiable. If an applicant is able to provide documentation demonstrating that the ICC amount provided by the NFIP database includes items not covered in the home evaluation or not paid to cover structural loss, the County will use the documentation provided by the applicant to adjust the ICC payout used in its calculations. The documentation provided by the applicant must come from the insurance company that issued the payments. The documentation showing use of ICC proceeds for specific expenses must clearly show services, materials, products, or any other tangible deliverable that is outside the scope of structural loss and the basis for the home evaluation. Private Insurance Generally, all private insurance settlement amounts for loss to dwellings are deducted from the applicant s award. However, private insurance payments for contents or other expenses such as fences, storage sheds, etc., are not deducted from the applicant s award providing such expenses are not related or eligible for funding from the program for which the applicant is seeking funds.

11 Insurance proceeds are identified and confirmed by the County through the applicant s insurance settlement. If an applicant can provide documentation demonstrating that the amount of proceeds provided by the insurance company includes items not covered in the home evaluation or not paid to cover structural loss, the County may use that documentation to adjust the private insurance DOB calculation. The documentation provided by the applicant must come from the insurance company that issued the payments. The documentation must clearly show the use of proceeds for specific expenses, e.g., services, materials, products, or any other tangible deliverable, outside the scope of structural loss and the home evaluation. The Small Business Administration (SBA) Approved amounts for repair to the dwellings under SBA Disaster Loan programs are deducted from the amount the applicant is eligible to receive. Approved amounts for contents or other expenses are not deducted from the applicant s award. The County will identify and confirm amounts approved for applicants under SBA Disaster Loan programs through the SBA data matching. If the County is unable to verify the SBA approved amount through the SBA database, the County will use documentation supplied by the applicant. If an applicant is able to provide documentation demonstrating that the approved amount provided by the SBA database includes items not covered in the home evaluation or not for structural loss, or in the case of addressing structural loss is insufficient to cover all costs needed to correct the structural loss, the County will use the documentation to adjust the SBA approved amount used in its calculation. The documentation provided by the applicant must come from SBA on SBA letterhead, and clearly show use of loan funds for specific expenses, e.g., services, materials, products, or any other tangible deliverable that is outside the scope of structural loss and the home evaluation. The documentation to show insufficient loan proceeds to cover all costs tied to structural loss must be itemized and on the letterhead and signed by a licensed professional acceptable to the County (such as architect, engineer, or general contractor). Other Sources Other funds from any source that is specifically provided for the purpose of repair, reconstruction, or other improvements to the dwelling are deducted from the amount the applicant is eligible to receive. Private Loans that are structured as forgivable loans are considered a duplication, as well cash gifts, donations and other funds, if specifically provided for the purpose of repair, reconstruction or other improvements to the dwelling. The documentation provided by the applicant must come from the source that issued the payments. Notable exceptions of other sources are described in above sections Private Loans and Other Assets or lines of Credit. Adjustments and Offset to the Amount of Assistance Applicant must provide evidence of funds spent for repairs and rehabilitation that would be subject to duplication of benefit. No receipts provided: If the applicant is unable to provide receipts as required in this policy to demonstrate other, unrelated uses of funds already received, the full amount of housing repair and/or replacement assistance previously received must be deducted from the amount of funding for which the applicant would otherwise be eligible.

12 Partial receipts provided: If partial receipts are provided by the applicant documenting that only a portion of the housing repair and/or replacement assistance previously received was used as intended, the amount received not supported by receipts must be deducted from the amount of funding for which the applicant would otherwise be eligible. All receipts provided: If receipts are provided by the applicant documenting that the full amount of housing repair and/or replacement assistance previously received was used as intended, and as required in this policy to demonstrate other, unrelated uses of funds already received no deduction is made from the award amount for which applicant is eligible. In instances where no receipts or only partial receipts were provided by the property owner, the County may consider self certifications when calculating the amount of assistance that can be provided. In these instances, the following requirements apply: The property owner must provide a signed self certified statement prepared and provided by the County based on information provided by the applicant that documents in detail all labor and or repairs made to the damaged property following the hurricane; and A Certified Inspector must determine with verifiable assurances (i.e. permit dates, utility restart dates, etc.) that the repairs were made after the date of the hurricane and that the repairs are consistent with damage resulting from the hurricane; and The County will document, through photographs, the repairs that were made. A Certified Inspector(s) is a person or persons hired by the County, qualified to inspect for labor and or repairs made to the damaged home in the absence of receipts. Self certified statements of the property owner must be reviewed in detail by a Certified Inspector to determine: Whether repairs were made to the home; Whether the repairs could be reasonably determined as occurring after Hurricane Sandy; and A reasonable value of the cost of repairs to the home (including labor). Allowed Activities: Applicants must provide documentation for allowable activities to off set potential Duplication of Benefit. Temporary Housing: Allowable activities are temporary housing such as rent, hotel stays and applicable utilities that occurred because of temporary displacement from their primary residence because of Hurricane Sandy. Eligible temporary displacement is from the time of the storm until the date of the verification letter. Evacuation costs are not eligible for Duplication of Benefits offset. Although Rental Assistance is not considered to be a source of duplication of benefits under this program, temporary housing expenses can offset the potential duplication of benefits amount. To offset the total amount, the following applies:

13 The offsetting amount would be the amount of documented expenses that exceed the amount received for Rental Assistance. Contractor Fraud: If an applicant was a victim of contractor fraud, the amount paid to the contractor may not be counted as a duplication of benefits. The applicant would have had to file a formal complaint with a government authority, e.g., consumer protection or police department, setting forth in detail the cause and amount of fraud in sufficient form to be verifiable and affirmed through enforcement follow up. Mortgage Force Payment: If an applicant s mortgage company placed a force payment on insurance proceeds, the insurance amount paid to satisfy a force payment is not a duplication of benefits. The applicant would have to provide the document proving that that the mortgage company did not release the insurance proceeds. Legal Fees: Legal fees that were paid in successfully obtaining insurance proceeds will be credited to the applicant and will not be deducted as part of their duplication of benefits. Applicants will need to provide evidence of payment and self certify in accordance with County policy in order to be credited. Tax Filing: Tax filings related to losses to the home do not affect funding assistance awards and are not considered duplication of benefits. Applicants should consult their personal tax advisor about any tax related matters. Inputs Necessary to Calculate Housing Interim Payment Assistance Rental Contract or Mortgage Statement The current rental agreement or mortgage statement will serve as the basis of calculating assistance. Duplication of Benefits FEMA Individual Assistance (FEMA IA) The County will identify and confirm FEMA IA awards through the FEMA database. If the County is unable to verify the FEMA IA amount through the FEMA database, it will use the payment amount provided by the applicant at the time of application. If an applicant is able to provide written documentation demonstrating that the FEMA IA amount provided by the FEMA database includes amounts paid to cover costs other than interim housing assistance, the County will use the documentation provided by the applicant to adjust the FEMA IA payout amount used in its duplication of benefits calculation. The documentation provided by the applicant must come from FEMA for the IA amount. The documentation demonstrating all or part of IA was not used to cover temporary housing assistance must be in form and detail acceptable to the program. County, State or Federal Housing Subsidy All government housing subsidy payments are considered in duplication of benefits calculations, including but not limited to rental assistance, mortgage assistance, homeowner insurance and flood insurance assistance, utility payment assistance

14 If an applicant is able to provide documentation demonstrating that the housing subsidy amount includes items not for the same purpose as the benefit from the Interim Payment Assistance Program, the County may use the documentation provided by the applicant to adjust the housing subsidy duplication of benefits calculation. The documentation provided by the applicant must come from the subsidy provider which issued the payments. The documentation showing use of subsidy for specific expenses must clearly show actual items purchased or services provided that are not rental housing or mortgage payments. Other Sources Other funds from any source that is specifically provided for the purpose of rent or mortgage assistance are deducted from the amount the applicant is eligible to receive. Private Loans that are structured as forgivable loans are considered duplication, as well cash gifts, donation and other funds, if specifically provided for the purpose of rent or mortgage assistance. The documentation provided by the applicant must come from the source which issued the payments.

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