HomeMy WebLinkAboutAGENDA REPORT 1997 0219 CC REG ITEM 09ATO:
FROM:
DATE:
CITY OF MOORPARK
CITY COUNCIL AGENDA REPORT
The Honorable City Council
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Donald P. Reynolds Jr., Administrative Services Manager
February 13, 1997
SUBJECT: Consider Acceptance of the Terms and Conditions of the HUD HOME Grant
Program
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City and County staff have been finalizing the language for use of the proposed HOME grant
monies with the Redevelopment Agency's housing rehabilitation program, and staff is
presenting several potentially problematic issues related to the incorporation of HOME
regulations into the current program. These regulations range from additional administrative
duties to a potential loss of the City's matching portion of the funds. However, the problems
can be mitigated, if assistance is provided to very low income home owners, for homes within
the required value range. This is significantly less flexible than originally perceived. Overall,
staff is confident that the program can be administered efficiently and increase the availability
of assistance to Moorpark residents
Background
The current Housing Rehabilitation program provides a combination of $5,000 grants and
$10,000 loans for households within the project area, and only loans not to exceed $15,000 for
those outside the project area. A separate report to the Agency is requesting that only loans
be provided. The assistance for those outside the project area is currently funded by $160,000
of local, non -MRA affordable housing funds. One household has been assisted and
approximately nine other applications are being considered.
The City was awarded the $50,000 HOME grant from the County last April primarily to expand
the assistance to those outside of the project area. If there are no applications being
considered for this use, it may also be used for the loan portion of assistance to homes within
the project area. In either of the two applications, the HOME monies can only be used as
loans.
The HOME grant requires a 25 percent match, or in this case, a local contribution not to
exceed $12,500. This would allow four loans split between local matching funds of $3,750,
and $11,250 of HOME monies, assuming $15,000 was considered. This leaves $2,500 of
HOME monies available for a fifth project, but no required match would apply. Out of ten
projects, the loan amounts have ranged between $10,000 and $13,000, which indicates that
the total of $62,500 available could be used to assist as many as six households. When loans
are made to very low income households, payments can be deferred until the title changes
hands. Loans made to low and moderate income households initiate payments shortly after
the project is completed for a ten year term. All but one home assisted thus far is at or below
the very low income status.
Discussion
Like CDBG, the County contract passes the HUD /HOME regulations, which were finalized by
HUD in September 1996, to the City. Unlike CDBG, the HOME program is specifically
designed to increase the availability of low income housing in the community (where CDBG
can be used for much more broad approach to assisting low income residents). Some of the
regulations imposed by HUD are aimed at assuring that affordable housing resources
increase, and this difference could potentially cause some complications to the current
administration. Regulations such as the federal bid requirements and Davis Bacon /prevailing
wage provisions are the same for CDBG as they are for HOME. These two requirements
however, do not apply to the Rehabilitation program unless the City is using HOME for a multi-
family complex, (because Davis Bacon applies only to rehabilitation of eight units or more), or
using more than $100,000 for any one project, (which triggers federal bid requirements).
There are however, three unique HOME requirements that do require the City's attention.
The first concern is the mandated repayment of the City's matching portion of $12,500. Within
the HOME regulations is the stipulation that each grantee (in this case is the County, with the
City acting as a sub- recipient), create a HOME Investment Trust Fund. HOME monies and the
local match portion when loaned by grantees, are required to be returned the HOME Trust
fund when repaid. These monies would then be considered for new projects within the
grantee's jurisdiction. In this case, the "grantee's" jurisdiction includes the County
unicorporated area, and the cities of Moorpark, Santa Paula, Fillmore, Ojai and Port Hueneme.
At issue therefore, is the disposition of the City's local match, when the HOME Trust Fund is
programmed by the County for a new project
As a member of the "Grantee's jurisdiction," the City is able to reapply to the County and
compete for use of the HOME Trust Fund and/or new HOME monies in subsequent years.
The Grantee will consolidate both the Trust Fund monies and the new HOME Grant monies
each year, and present the availability of the sum each January. Therefore, it should be
recognized that the matching requirement will apply to any future successful HOME grant
application. These applications do not have to focus on housing rehabilitation, and could be
proposed to the County for use in any affordable housing application. Staff may be presenting
new HOME grant application concepts or expansion of the currently proposed program to
Council in December, 1997
If the City used the HOME Funds to target only the very low income households, which equals
nine out of ten applicants thus far, then the repayment of the City's match could be prolonged
until the title changes hands. Assuming that various loans will be repaid at various times, most
for more than ten years, the value of the City's match will be returned in small increments, (no
more than $3,750 per repayment), and the first repayment may not be made until ten or more
years after the assistance has been provided. During that time frame, the City's $12,500 will
have decreased significantly in value, or in actual buying power, as a result of inflation. So
what appears to be a potential for the City to place at risk $12,500, may by the time it is repaid
to the County, be equal to substantially less when the loan is actually repaid, if provided to a
very low income household
The second most significant concern is a requirement to maintain the "affordability of the
home" over a five year period. The five year period is determined by HUD, based upon the
amount of money used for each project. Those loans of $15,000 or less, require a five year
"affordability" assurance. There is no provision currently in the program to assure the
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affordability. HUD provides two options to determine whether or not a home meets the
affordability criteria; 1) use of a County -wide average provided by HUD, or; 2) use of a local
survey of home resale values. The home has to be at 80% or below the average resale value
to be eligible for the program. The HUD provided County -wide assessment places this value
currently at $195,000, and the HUD data is updated annually. It is perceived that although a
deed restriction will be required to assure that the home remains available to other low income
persons if re -sold during the five year period or if the value increases to above the 80 percent
threshold, if the houses subject to these regulations begin at a low enough value, this factor
will not be applicable.
HOME monies, with the deed restriction assuring affordability for a five year period, can
present a slightly greater risk for use by the homeowner than accepting a loan which is
currently available using local resources. To assure expedient use of the HOME monies, as
required by HUD, the administration of the program will have to follow a flexible approach of
looking at applicants both within and outside of the project area. HOME monies for eligible
homes, will therefore, be the first consideration for use whenever possible less attention made
to the project area boundary and geographic location
The third concern is the requirement for annual income verification. Although HUD requires
the annual income verification of each recipient, there is no penalty or loan pay -off triggered in
the event that a person or family rises above the low income standards. HUD has combined
the income verifications with the affordability of the home (as mentioned above), and elected to
enforce the occurrence of a home becoming too costly to be deemed affordable, as its
mechanism of enforcement, rather than a household no longer being "low income." Just the
same, the contract requires documentation of each, and income verifications for the initial
applicants are already in place. Annual income status could be resolved by regular mailings,
for the same period as the "affordability" criteria, or five years. Considering the fact that only
five homes would be assisted, and that the income status would only need to be maintained
for this same period, this task would not be prohibitive
Summary
If the City applies the use of HOME with consideration of these regulations, the apparent
differences between the current program and the HUD program can be mitigated. Because
the City can fall back to home owners within the project area, when no "eligible" applicants can
be accommodated outside the project area, the HUD contribution can be used to expand the
current program. The HOME recipient targets therefore, would be first the very low income
persons residing outside the project area with homes valued at less than $195,000, and then
turn to homeowners inside the project area who meet the same two criterion. The key is to
assist those most in need, who reside in homes with the least value. This concept is different
than originally intended by staff, which was hoping for a broader target area consisting
primarily of homes outside the project area. However, the program can still assist the City in
the rehabilitation endeavor, and still be a valuable tool for residents to improve their quality of
life.
Recommendation
Authorize staff to accept the grant and authorize the City Manager to execute the contract
initiating the program.
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