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R&C Publishes COVID-19 Resources Page
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R&C compiled relevant COVID-19 resources for owners and operators of multifamily housing developments in a single webpage covering a host of issues including Fair Housing Act considerations. Recent HUD developments include: (1) 30-day extension of the deadline for March and April AFS submissions; (2) OGC's issuance of Contingency Plans for Closing HUD Multifamily and Commercial Loans; and (3) HUD released PBCAs from the obligation to perform MORs and is evaluating options to monitor property operations without the need to access occupied units. R&C has learned that 80-90% of the HUD workforce is working remotely and utilizing electronic communications and processing to minimize personal contacts.
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CLPHA and R&C Submit Joint Comments on AFFH Proposed Rule
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Under HUD's proposed Affirmatively Furthering Fair Housing (AFFH) rule, HUD would create a metrics system to evaluate and rank jurisdictions based on their AFFH performance and, based on such performance, reward high performing jurisdictions and require remedial or punitive measures of low performing jurisdictions. The Council of Large Public Housing Authorities (CLPHA) and R&C submitted joint comments urging HUD to withdraw the proposed rule on March 16, citing, among other critiques, that "Creating a system of winners and losers, where PHAs across the country will base their efforts to affirmatively further fair housing on how to score high on yet-to-be-determined metrics to avoid yet-to-be-identified punitive measures does not affirmatively further fair housing."
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HUD Updates Procedures for PRAC CNAs and Budget Based Rent Adjustments
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Multifamily Housing updated its approach to PRAC CNA reviews and BBRI calculations via a memorandum issued on March 12. HUD will now prioritize core operating costs (i.e. utility charges, maintenance, taxes, critical repairs) and future repair needs of major building system components when making budget-based adjustments. The memorandum also addresses the RAD for PRAC program and owners' need to leverage financing to address capital needs without large, short-term increases to replacement reserves.
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