Tuesday, September 8, 2009

ANNUAL REPORT Update: Don’t Forget Certification Forms

Annual report certification forms are crucial, and no annual report is complete without them. There are two certification forms, and both may be downloaded from the ‘References’ tab, the rightmost tab on the web annual report. Since the certification forms must be signed by your chief elected official, you must mail them to Florida Housing to supplement your web-based annual reports.

The first certification form is very straight forward. It certifies the accuracy of the annual report. The second certification form addresses the implementation of regulatory reform activities. This form is one main method that Florida Housing uses to document a jurisdiction’s compliance with the requirement to implement a minimum of two “incentive strategies”.

Section 67-37.019 (5) of the SHIP Rule outlines the incentive strategy requirements for all SHIP jurisdictions:
The local government staff or entity with administrative authority for a local housing assistance plan shall provide documented evidence to the Corporation or its designated monitoring agent, that:
(a) Permits, as defined in Sections 163.3164(7) and (8), F.S., for affordable housing projects are expedited to a greater degree than other projects; and
(b) There is an ongoing process for review of local policies, ordinances, regulations, and plan provisions that increase the cost of housing prior to their adoption.

These two incentive strategies are often referred to as (a) Expedited Permitting and (b) Ongoing Review. Sections 1 and 2 of the regulatory reform certification are statements to evidence that the jurisdiction has implemented these two incentive strategies.

Section 3 asks for details resulting from your jurisdiction’s ongoing review process. You must report the estimated per unit cost increases for housing construction that have resulted from the creation of any new policies, ordinances, regulations, fees or plans during the most recently completed state fiscal year. In order to complete this form with accurate information, talk with the group or individual in your jurisdiction that performs the “Ongoing Review” responsibility. Ask them about their review process during the 12 months of this last fiscal year. If there have been no new policies to increase costs, enter $0.

Section 4 is very similar to Section 3. Provide the per unit estimated cost increases for rehabilitation activities that have resulted from new local policies, ordinances, regulations and more that were considered during the state fiscal year.

How should your jurisdiction go about estimating how much a particular policy will increase the cost of housing? The SHIP Statute and Rule provide no guidance or method by which a local jurisdiction must determine the cost increase. Such estimates are a local determination, and the jurisdiction should retain back up material to justify the dollar amounts reported on this certification form.


THE DEADLINE IS APPROACHING
Every jurisdiction must submit their reports by next Tuesday, September 15th. The Coalition is available to help you ‘cross the finish line’ and submit your annual reports. This year, the Coalition is available on Tuesdays and Thursdays to provide this assistance through its technical assistance line: 800 677-4548. In addition, a full and updated collection of frequently asked questions about annual reports is available at http://faqannualreports.blogspot.com/.

Wednesday, September 2, 2009

ANNUAL REPORT Update: Recent Change Affects Form 4

Check the ‘Review’ tab of each of your three annual reports. Do they show an error involving ‘Expended Funds’ reported on Form 4? If so, this may be the result of an update Florida Housing has made to the web annual report.

For each SHIP distribution, you must report details about all program funds that have been expended, including the name and address of each assisted household. The strategy that was used to provide assistance is listed alongside the name of each recipient. Florida Housing has now programmed the web system to total up the expended funds for each strategy. Now, a “Summary by Strategy” total appears at the end of the list of expended funds you have added to Form 4.

There’s a good reason for the change; it allows Florida Housing to review the amount expended per strategy and compare this with what is reported on each strategy line of Form 1. If the expended fund figures do not match, this new improvement may make it easier to identify specifically where the error occurs. For example, consider a jurisdiction that has expended funds on three strategies. The ‘Summary by Strategy’ totals show that the funds expended on Strategies A and B exactly match the figures on the top of Form 1. The total expended for Strategy C, conversely, does not match Form 1, so it is the source of the error. Correcting this report will go quickly since one is able to focus attention on only a portion of the data provided.

A Related Question:
On Form 4, I added an amount of expended funds per strategy that exactly matches the figures reported on Form 1. Yet the Review Tab still shows an error. Specifically, it indicates:
“There are no "Expended Funds" records for the "Homebuyer Assistance" strategy listed under the Distributed Funds' "Home Ownership" section on Form 1.”
Please provide guidance.

Answer:
The error in this case is caused by the fact that this jurisdiction labeled a strategy “Homebuyer Assistance” on Form 1, but called it “Purchase Assistance” next to the name of each buyer listed on Form 4. In order for Florida Housing’s new programming to work properly, the name of each strategy must be identical on Forms 1 and 4. Pay attention to capitalization, since this also makes a difference. In this case, the jurisdiction decided to change the strategy name on Form 1 to “Purchase Assistance” and the error message disappeared.



THE DEADLINE IS APPROACHING
Every jurisdiction must submit their reports by September 15th. The Coalition is available to help you ‘cross the finish line’ and submit your annual reports. This year, the Coalition is available on Tuesdays and Thursdays to provide this assistance through its technical assistance line: 800 677-4548. In addition, a full and updated collection of frequently asked questions about annual reports is available at http://faqannualreports.blogspot.com/.