Managing and Monitoring NSP Programs for Results

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Hubert Carr
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1 U.S. Department of Housing and Urban Development Managing and Monitoring NSP Programs for Results Neighborhood Stabilization Program Neighborhood Stabilization Program

2 Workshop Purpose Highlight performance and compliance issues typically arising as NSP programs start up Identify actions and tools to address those issues Covered in other workshops or one-on-ones: NSP eligible uses and special requirements 25% set-aside for very low income beneficiaries Acquiring REO properties DRGR U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 2

eligible uses and special requirements 25% set-aside for very low income beneficiaries Acquiring REO

3 Importance of Topic Grantees are ultimately responsible for all program activities, expenditures and noncompliance HUD will review and audit programs Some problems difficult to resolve retroactively, such as failing to provide URA assistance, meet 25% set-aside U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 3

difficult to resolve retroactively, such as failing to provide URA assistance, meet

4 Typical NSP Performance Issues Roll-out experience indicates some program components are not working well redesign needed Agreements with developers not in correct form Program policies & procedures not clear Problems acquiring suitable, complying properties Sub-recipients & developers with serious capacity gaps Grantees and sub-grantees don t have enough staff Various compliance issues: URA, environmental, etc. U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 4

properties Sub-recipients & developers with serious capacity gaps Grantees and sub-grantees don t have enough staff Various

5 Crucial Grantee Management Tasks Provide policies/procedures manual and forms Assure that good reporting and check-off systems are in place Assess internal and out-sourced programs identify glitches and capacity gaps Periodic, even frequent site visits are advisable Determine what s working, and what isn t Amend or de-obligate agreements if necessary Amend the Substantial Amendment if necessary U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 5

frequent site visits are advisable Determine what s working, and what isn t Amend or de-obligate agreements if necessary

6 Program Policies/Procedures Missing or spotty in some NSP programs Or not shared with sub-recipients and developers Makes compliance and monitoring very difficult Advisable to have different manuals for different program types E.G. acquisition rehab, land banking, etc. With accompanying forms, spreadsheets etc. HUD TA providers are creating Toolkits ; many sample documents are already available (word search toolkit ) at U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 6

acquisition rehab, land banking, etc. With accompanying forms, spreadsheets etc.

7 Written Agreements Written agreements MUST be executed Types of agreements Subrecipient, contractor, and developer agreements CDBG flow-through provisions apply to NSP Look for agreement templates in NSP Toolkits U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 7

8 Legal entity to which sub-award is made Subrecipient States not required to use local govts as in CDBG Can be designated; can t earn developer fees Can keep and reuse program income, or not Subject to uniform administrative requirements U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 8

9 The developer form of agreement is proving to be appropriate and flexible for NSP Used with for-profit and nonprofit developers Becoming more defined through NSP Can be designated Rather than procured saves time Can earn developer fees Can keep and reuse program income, or not Not subject to uniform admin requirements Developer U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 9

time Can earn developer fees Can keep and reuse program income, or not Not subject to uniform admin

10 Contractors provide grantees with goods or services over limited duration of time for specific price, such as Appraisers, title companies, consultants Demolition companies Must be competitively procured Can t keep program income, but typically not an issue Contractor U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 10

Must be competitively procured Can t keep program income, but typically not an issue

11 Required contents Basic to All Agreements Statement of work and budget with eligible use lines Payment criteria and procedures Qualifying beneficiaries and target areas Record-keeping and reports Management/accounting of program income Federal flow-through requirements Enforcement provisions - suspension and termination Duration of agreement Simpler if a program manual can be referenced U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 11

income Federal flow-through requirements Enforcement provisions - suspension and termination Duration of agreement

12 Subrecipients Agreements: Special Provisions Uniform administrative requirements Conditions for religious organizations Reversion of assets e.g. equipment purchased Developers Developer fee amounts and how paid What can be charged as direct costs vs. in fee Terms of financing for multifamily rental projects All (potentially): bonding and insurance U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 12

13 Finding foreclosed properties Develop relationships with REO holders Acquisition Challenges Research public records to get a jump on competition Subscribe to proprietary data services Focusing on salable locations Sometimes requires acquiring/rehabbing or demolishing vacant properties in the vicinity Avoiding compliance issues with foreclosed definition, URA and tenant protections U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 13

acquiring/rehabbing or demolishing vacant properties in the vicinity Avoiding compliance issues with foreclosed

14 Tracking and Approving Activities Effective reporting tracking tools essential Examples will be available in NSP Toolkits Includes property status and expenditures by NSP property types and commitment to VLI occupants Consider what actions grantee should approve E.G, acquisitions, beneficiary income qualifications, form of recapture/resale documents, relocation plans, multi-family proformas U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 14

15 Monitoring for Capacity Gaps Staff and sub-grantees with low production and compliance problems need urgent attention TA can be provided with NSP grant or national funds Providing a step-by-step program manual and forms may solve many problems samples in NSP Tookits New hiring and outsourcing may be needed Obligation/expenditure deadlines should be set Other warnings/directives should be given in writing De-obligation is a last resort U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 15

Tookits New hiring and outsourcing may be needed Obligation/expenditure deadlines should be set Other warnings/directives should be

16 Methods of Monitoring & Support Desk reviews of activity reports and supporting documents E.G. proof of purchases, foreclosed status, work completion, buyer incomes Gather additional information, as needed Site visits with sub-grantees U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 16

proof of purchases, foreclosed status, work completion, buyer incomes Gather

17 Includes 3-step process Monitoring Visit Preparation including timed agenda of meetings and property inspections Conducting monitoring Follow up Determine strategy and tactics for monitoring and support to sub-grantees A generalist can be in charge, but specialists in construction and finance might make their rounds Tailor frequency of visits to performance or lack thereof U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 17

generalist can be in charge, but specialists in construction and finance might make their rounds Tailor frequency

18 What Documentation to Review? Program policies, procedures, manuals etc. Written agreements and budgets Forms, checklists, recapture and resale docs Subrecipients and other entities information Property and client files Marketing plan for home sales Payment requests/vouchers Past monitoring files Split up review among specialists on grantee staff U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 18

information Property and client files Marketing plan for home sales Payment requests/vouchers Past

19 Other Monitoring Tasks Assess capacity of sub-grantees, particularly those that are lagging: Including any developers working under them Ask for staff roster and percent of time spent on NSP Determine organization and staff experience particularly with real estate development and sales Make sure marketing plans are sound Must tie to counseling and subsidies Review process steps with clients U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 19

particularly with real estate development and sales Make sure marketing plans are sound Must tie to counseling and

20 Other Monitoring Tasks Inspect properties acquired in pipeline for purchase Determine if they are at saleable locations Inspect properties under construction Determine quality and completeness vs. construction standards (including green standards) Usually a job for grantee s construction specialist Review number and status of prospective buyers Advisable to meet with pre-purchase counseling staff or outside agency to get a first-hand report on progress U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 20

construction standards (including green standards) Usually a job for grantee s construction specialist Review number and status of

21 Other Monitoring Tasks Meet with financial specialists on staff Ask about connections with lenders and products being offered to NSP buyers (typically FHA loans at this time) Sometimes a job for grantee s finance specialist U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 21

22 If You Have Challenges You are not alone many NSP programs are facing issues with performance and compliance Encourage open and candid discussion Aimed at correcting problems, not gotcha At the same time, set standards and deadlines for correcting them De-obligation, partial de-obligation and amending program components should be on the table U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 22

23 Tools to Use Look for tracking and monitoring tools in NSP s online Resource Exchange More being added continually See Contact or visit NSP grantees that are farther along with a particular NSP program activity Borrow useful forms, policies/procedures, tracking tools, etc. U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 23

24 Other Tools on HUD Website NSP generally follows CDBG rules In the CPD Monitoring Handbook CDBG is Chapter 3 and applies generally to NSP Other CDBG toolkits A basic NSP monitoring manual is forthcoming from HUD U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 24

25 What we covered: Recap of Session Performance and compliance issues in start-up of NSP programs Actions and tools to address those issues Sources for monitoring tools Urgent monitoring and issues: Obligation of funds, capacity to deliver and compliance Possible need to amend programs and budgets Now, final questions and discussion U.S. Department of Housing and Urban Development Neighborhood Stabilization Program 25

Guidance on NSP-Eligible Acquisition & Rehabilitation Activities

Guidance on NSP-Eligible Acquisition & Rehabilitation Activities This NSP Policy Guidance describes how to determine whether or not a property is eligible for acquisition and or rehabilitation with NSP