Accountant. the MHA Project. August 1, 2013

Transcription

1 Accountant Presentation Training Title z Date NFMC and the MHA Project August 1, 2013

2

3 Introductions Ruth Hutchins NFMC & MHA Project Program Manager Nick Boettcher EHLP Program Manager & Monitoring Kevin Knase Monitoring

4 Agenda Budgeting and Funds Tracking Requirements incl. OMB Circulars The NFMC Program Grant Funds Reporting The MHA Project Grant Funds Reporting Monitoring and Audits

5 Program Fund Names NFMC Counseling Program-Related Support (PRS) MHA Project Document Preparation and Submission (DPS) Outreach

6 NFMC and MHA Project Budgeting & Funds Tracking Requirements No invoicing needed Track programs separate from each other and separate from other funds Example: NFMC Counseling NFMC Program-Related Support Record keeping Interest earnings Unexpended Counseling and DPS

7 NFMC and MHA Project Ineligible Fund Uses Discharge of mortgage balance or other debt reduction Clients that have already been billed to HUD Fees cannot be charged to clients in exchange for foreclosure mitigation counseling services.

8 NFMC and MHA Project OMB Circulars Review your grant agreement for a complete list of requirements! Administrative Requirements Cost Principles Non-Profits A-110 A-122 State, Local and Tribal Governments A-102 A-87 The OMB Circulars can be found at:

9 NFMC and MHA Project OMB A If over $500,000 in federal funds expended The single audit required to be completed within 6 months of fiscal year end The single audit must also be submitted to the Federal Audit Clearinghouse within 9 months of fiscal year end

10 NFMC and MHA Project OMB A If expenditures do not trigger the single audit requirement Contact Minnesota Housing in writing that the audit was not required and provide audited financial statements to Minnesota Housing instead If revenues are less than $300,000 annually and agency receives less than $25,000 in NFMC funding, agency may submit to Minnesota Housing a Review Statement or Compilation Statement in lieu of independent audited financial statements

11 NFMC and MHA Project CFDA # s Program Round CFDA # NFMC PL113-6X1350 NFMC PL112-55:95X1350 NFMC PL X1350 MHA Project N/A No CFDA #

12 The NFMC Program The National Foreclosure Mitigation Counseling Program (the NFMC Program) Goal and purpose of the NFMC Program 35% and 3 rd place NFMC Round 7 Allocation for MN Housing: Serve over 3,000 households 22 sub-grantees participating Total allocation of $980,694

13 NFMC Program Successes July 2008 Start of NFMC $15,601, Total NFMC Grant Award including Rounds ,562 Number of households served through NFMC since Round 1

14 NFMC Grant Summary Counseling Funds Level 1 - $150 Level 2 - $300 Level 4a - $300 Level 4b - $150 Program-Related Support (PRS) 10% of the counseling allocation

15 NFMC Counseling Funds Eligible Uses A few examples include: Salaries Benefits Credit reports for clients Facility rent

16 NFMC PRS Eligible Uses Outreach to delinquent clients Implementing the Minnesota Homeownership Center s Triage System Group orientation and education sessions Outreach and communication on preventing rescue or loan modification scams Infrastructure development and communication

17 NFMC PRS Eligible Uses continued Improving capacity and infrastructure for tracking and reporting data Hiring, training and orienting new counseling agency staff members

18 NFMC Program Disbursement Schedule TOTAL Initial Draw (Contract Execution) Draw 2 (25% of allocation billed) Draw 3 (60% of allocation billed) Draw 4 (100 % of allocation billed) Final Draw Counseling $10,000 $3,500 (35% of Counseling allocation disbursed) $3,000 (30% of Counseling allocation disbursed) $3,000 (30% of Counseling allocation disbursed) $250 (2.5% of Counseling allocation disbursed) $250 (2.5% of Counseling allocation disbursed) PRS $1,000 $700 (70% of PRS allocation disbursed) $150 (15% of PRS allocation disbursed) $150 (15% of PRS allocation disbursed) See Exhibit A of the grant agreement for further details. N/A N/A

19 NFMC Program Reporting Quarterly Report Review Submission requirements Box.com Do not submit to All Files and Folders Label as Agency Name_NFMC Quarterly Report

20 NFMC Program Reporting (Continued) Quarterly Report Due Dates See MN Housing s website October 15, 2013.* Reporting period July 1, 2013 September 30, January 15, Reporting period October 1, 2013 December 31, * In addition to reporting quarterly expenditures for the period July 1, 2013 through September 30, 2013, this report must also detail expenses incurred during the period beginning with each Counseling Agency s Round 7 start date through June 30, Final Report Due Date ed near end of the Round February 14, 2013

21 The MHA Project Making Home Affordable Outreach and Intake Project (aka The MHA Project). Goal of MHA Project Purpose of funds Allocation for Minnesota Housing Serve 315 households Outreach efforts are estimated to reach 80,000 in Minnesota through the efforts of 21 sub-agencies and the Minnesota Home Ownership Center with an allocation of $54, Total allocation of $206,190 incl. Supplemental Outreach Nationwide Update

22 MHA Project Grant Summary Document Preparation and Submission (DPS) Fees $450 Outreach Funds 12.5% of DPS allocation

23 MHA Project DPS Fees Eligible Uses A few examples include: Salaries Benefits Credit reports for clients Facility rent

24 MHA Project Outreach Funds Eligible Uses Listed below are some examples of allowable MHA Outreach and Intake Project outreach activities: Purchasing local advertising, including print and radio ads Distributing brochures, posters, fact sheets, flyers, and other collateral Mailing postcards Engaging local media outlets, including newspapers, radio stations, and television stations

25 MHA Project Outreach Funds Eligible Uses (continued) Listed below are some examples of allowable MHA Outreach and Intake Project outreach activities: Translating or otherwise adapting materials in culturally appropriate ways Implementing social media campaigns Engaging local partners, including faith based organizations, lenders, neighborhood groups, local government, and social service organizations Hosting or participating in community events and producing related signage and/or exhibits Calling, , texting, or otherwise directly soliciting potentially eligible homeowners

26 MHA Project Outreach Funds Eligible & Ineligible Uses Eligible Uses These funds are to be used by the counseling agency only for outreach activities designed to reach homeowners in need of mortgage assistance. The counseling agency must remain consistent with the outreach activities and budget submitted in the Letter of Intention. Billing staff time or administrative expenses directly associated with performing outreach activities is acceptable. Ineligible Uses Outreach Funds should not be used to support outreach efforts of the counseling agencies credit counseling, homebuyer education, or post purchase counseling. If the funds are spent other than in accordance with the outreach plan submitted, the funds will be subject to recapture. MHA Outreach Funds cannot be used for general overhead. Billing general overhead that is not tied to the MHAfunded activity is not allowable. The counseling agency will not be entitled to receive funds under the MHA Outreach and Intake Project for any costs or services (or portion thereof) which are funded from any other source.

27 MHA Project Disbursement Schedule

28 MHA Project Reporting Outreach Funds Expenditure Report and Disbursement Request Review ed Quarterly Report Review ed Final Report will be ed as end date of program draws near

29 MHA Project Reporting (Continued) Submission Requirements Box.com Do not submit to All Files and Folders Label as Agency Name_MHA Project Quarterly Report All reports for the MHA Project must also be signed and submitted by mail with the original signature.

30 Report MHA Project Reporting Due Dates Reporting Period Due Date to Minnesota Housing Outreach Funds Expenditure Report and Disbursement Request To be completed as soon as sub-agency has spent the first 50% of outreach fund allocation. Quarterly Report and Hope LoanPort Report* *A report from Hope LoanPort that identifies the client name and submission status for all MHA Project clients during the reporting period identified. Reporting period will cover activity between receipt of initial disbursement and June 30, July 31, 2013 Report will cover activity between July 1, 2013 September 30, November 1, 2013 Report will cover activity between October 1, 2013 December 31, February 3, 2014 Final Report February 14, 2014

31 Differences between NFMC & MHA NFMC Program Counseling Advanced a set amount when disbursement thresholds are met. Use against allocation is determined by uploads to the Data Collection System. Usually 5 disbursements total for each NFMC round. Distinction between Level 1, Level 2, Level 4a, Level 4b MHA Project Document Preparation & Submission (DPS) Reimbursed a set amount for accepted* Initial Packages in HLP *Payments are disbursed after the Initial Package has been accepted by servicer, not when servicer makes determination regarding options for the homeowner. Disbursements occur on a monthly basis. No level distinction. Only DPS.

32 Differences between NFMC & MHA (continued) NFMC Program Program Related Support Broader parameters for use including expenses for staff time when completing reports. You can create your own materials for foreclosure counseling specific outreach. Disbursed funds can be used throughout the entire performance period. Three disbursements which are made at certain thresholds. There is no requirement to request funds when previous disbursements are fully expended. MHA Project Outreach Narrow parameters for use where any costs must be directly associated with outreach. Must use Treasury approved materials or obtain pre-approval to make changes. No disbursements after September 30, All funds must be used, obligated, encumbered or otherwise expended by October 31, Two disbursements: The first half is at grant agreement execution and the second half must be requested once the first is fully expended. Unspent funds need to be returned to Treasury.

33 Differences between NFMC & MHA (continued) NFMC Program Re-allocations In our experience, reallocation of funds by NeighborWorks has not been a standard practice within any given NFMC round. However, MN Housing reallocates funds as necessary to ensure the grant is spent down within the performance period. MHA Project Re-allocations Re-allocations will occur at some point during this Project. The timeline for when this will occur or how that will be determined is uncertain at this point in time.

34 Differences between NFMC & MHA (continued) NFMC Program Performance Period The day after agency reached it s Round 6 allocation through December 31, Spend Down Timeline All funds (Counseling and PRS) with the exception of the 5% of Counseling funds not disbursed until after the end of the performance period must be expended by December 31, MHA Project Performance Period May 1, 2013 December 31, 2013 Spend Down Timeline Outreach - No disbursements after September 30, All funds must be used, obligated, encumbered or otherwise expended by October 31, DPS Must be expended by December 31, 2013.

35 NFMC and MHA Project Monitoring and Audits Evaluation period NFMC December 31, 2015 MHA Project June 30, 2015 Monitoring by MN Housing Audits by NeighborWorks (Mayer Hoffman McCann) Oversight by Treasury (MHA Project only)

36 NFMC and MHA Project Audit Readiness NFMC see NFMC Members Site Web Ex titled NFMC Quality Control & Compliance Web Ex Sub-grantee Checklist from March 14, 2013 MHA Project see Compliance Policy posted on MN Housing s website (pgs. 7-16)

37 NFMC and MHA Project Audit Readiness (continued) Any or all of the following may be requested of your agency in an audit. This list is subject to change: Mode of Counseling Client Management System Audits Financials Records Retention Policy Disposition of client s personal information Translation Services Counselor Certifications

38 NFMC and MHA Project Audit Readiness (continued) Any or all of the following may be requested of your agency in an audit. This list is subject to change: Accessibility ADA Contracted Services Counselor Payroll Receipts Authorization to do Business No Exclusivity Contracts Free Services HUD s Housing Counseling Approval

39 MHA Project Audit Readiness In addition to what was previously stated, the following were identified in the Making Home Affordable Outreach and Intake Project Compliance Policy specific to the MHA Project: Allowable Outreach Activities Oversight Conducted Anti-Discrimination Policy Continued Services Protecting the homeowner s personal and financial information

40 For More Information Contact: Ruth Hutchins