Additional updates include:
- Davis-Bacon wages do not apply to work done prior to the execution of the HAP contract. The 18-month window is clarified to be following contract execution.
- PHAs will be able to use existing income certifications and will not need to re-certify tenants upon the date of conversion.
- Guidance clarifies requirements for post-closing requests for transfers of assistance.
- Guidance provides standards for PHAs seeking a waiver of the PBV $0 subsidy problem – which prohibits a PHA from renting to a new, otherwise income-qualified tenant if the tenant’s income exceeds the RAD rent.
- An alternative restrictive covenant can facilitate removal of the Declarations of Trust (DOTs) in transfer of assistance projects.
- Projects seeking 9% LIHTCs will not have their CHAPs revoked and can reapply for LIHTCs if they do not receive awards in their initial attempt.
- The 10-year exclusion on conversion of HOPE VI projects is eliminated.
- Applications no longer require financing letters of intent.
- PHAs and Project Owners must have a concept call before submitting a Financing Plan.
- The practice of re-setting rents every two years has been made official policy.
- Guidance implemented in PIH 2018-04 – allowing the 75% RAD – 25% Section 18 blend – and in Notice H-2018-05 / PIH-2018-11 is incorporated – expanded rent bundling, PBV tenant-paid utility savings, developer fee boosts for homeless assistance, and streamlined processing for PHAs with less than 50 units.