HomeMy WebLinkAboutHousing & Redevelopment Authority Packet 11-25-1980AGENDA
PLYMOUTH HOUSING AND REDEVELOPMENT AUTHORITY
Wembev 2S, 1980
7:00 pm
I.: Roll Cali
Ii. Approval of Minutes for September 22, 1980
III. Public Hearing for Year VII CDBG Program
IV. AppoiotMent of Dick .tree to the Housing Rehabilitation Committee
V. Report on the Section 8 Program
V1. Adjournment
CITY OF PLYMOUTH
34.00 PLYMOUTH BLVD., PLYMOUTH, MINNESOTA 55441
TELEPHONE (012) 559-2800
OATS; November 20, 1980
MEMO
TO: HRA Commissioners
FROM: Milt Dale
SUBJECT: Report on Section 8 Program
Staff was directed by the Commissioners to respond to a letter from HUD and the
financial audit by Moen and Pentilla requesting that the Plymouth HRA settle it's
accounts for the fiscal year ending June 30, 1979. This has been done as the HUD
Area Office received our check for $15,923.33 during mid-October. Attached is
the letter responding to Mr. Feeney's letter of September 2, 1980.
Recently HUD sent me a letter calling for my attendance at a Section 8 Housing
Quality Standards training session. This 3 -day session would cost $270:00.
Computing in my hourly rate as an associate planner for the three days I would
be gone, the total cost to the taxpayer would be close to $500.00. The objective
of the training session would be to train administrators in how to use a new
federal housing inspection form. The attachments give more information on this
matter. Incidentally, the only response we have received from the HUD Area. Office
are two telephone calls --one from a Shawn Huckleby regarding the fact that the
training session was mandated from the Chicago Regional Office and one from
Nancy Bratrud regarding whether I would be in attendance. I said no.
Last month a matter came to my attention which I want to pass on as a point of
information. In October, I found out that one of our Section 8 tenants had not
been living in her apartment from sometime in early June to late October, a period
of about five months. During this time, the Plymouth HRA paid $905 of federal tax
money for a vacant apartment. After investigating the matter, I found that c?ie
tenant had been in St. Louis, Missouri for the five months. She then came up to
Plymouth briefly, vacated her apartment (her lease had terminated) and moved down
to St. Louis. Since she gave the apartment management a late notice, we were also
obligated to pay another month's rent! Our recourse? None! In talking to the
HUD Area Office's legal staff, I was told there would be no legal recourse in the
matter as we would be "restricting a person's mobility" by requiring them to maintain
residence in the apartment for which federal tax dollars are being spent.
Fortunately, such incidents have happened only rarely in Plymouth.
Attachments:
1. L tter to Nancy Bratrud HUD), 10/15/80
2. Letter to Thomas Feeney HUD), 11/10/80
3. Memo from Blair Tremere to James Willis, 11/7/80
4. Letter to Thomas Feeney HUD), 11/5/80
S. Brochure on Training Session
MD/ba
October 15, 1980
CITY OF
Nancy Bratrud PLYMOU R
Assisted Housing Management Branch
HUD Area Office
6400 France Avenue South
Edina, MN 55435
Dear Nancy:
In response to Mr. Feeney's letter of September 2, 1980 I am enclosing a check
for $15,923.33. This complies with Finding No. 6 of the recent Plymouth HRA
audit. Also enclosed is a listing of account code numbers to indicate that the
City of Plymouth can provide the required accounting services. This complies
with Finding No. 3.
As you also know, I have submitted certain required items requested by your
March Management Review and I will continue to do so in as speedy a fashion as
is possible. However, the Housing Authority staff in Plymouth consists of only
one (1) moulting middle-aged city planner --we are not in the same league as the
Minneapolis, St. Paul, Metro or Dakota County HRA's with their specialists in
every field. In June of this year, a reduction in City revenues forced the
termination of one secretarial support person. (You see, the City of Plymouth
and the HRA favors the rather strange fiscal policy of not spending any more
money than it takes in!)
Our Housing Authority has made it a primary goal to maintain qualified Section 8
tenants on the Program in Plymouth as indicated by our full utilization of the
Program. This in itself takes time. As well, we are committed to operating a
productive housing rehabilitation program. This takes time, especially in view
of the fact HUD and Hennepin County continually escalate the reporting require-
ments. The truth of the matter is we are delivering the services. However, we
have not always provided your office w11W all the various documents attesting to
this fact. As well, there have been certain computation errors made by myself
that must be corrected. I assume full responsibility for any such errors. It is
my sincere intention to make corrections and resolve all differences.
May I state for the record that it is very unfortunate that programs like Section
8 and now the housing rehabilitation programs are becoming mired in red tape and
bureaucracy. These programs have been reasonably helpful to a wide range of lower
and moderate income persons. However, now the growing cost of administering these
programs, due to the inordinate amount of required supporting documents is fast
making these programs prohibitive in a community like Plymouth. As is often the
case, the loser will be the person the program was designed to help. Your
positive efforts in supporting less documentation would really be a help in
keeping programs like this operating in communities like Plymouth.
Sincerely,
Milt Dale Attachments: Check
Plymouth HRA List of Code Numbers
3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA 55441, TELEPHONE (612) 559.2800
CITY OF PLYMOUTH
3025 HARBOR LANE, PLYMOUTH, MINNESOTA 5.5441
TELEPHONE (812) 559.2800
DATE: October 20, 1900
MEMO . .
TO: HRA Commissioners
FROM: Wilt Dale, City staff
SUBJECT: HRA meeting and Public Hearing for Year VII CDBG Program
The City Manager and Planning Uirector have suggested that hereafter the Public
Hearing for the CDBG Program be held before the Housing Authority rather than the
Planning Commission due to the emphasis on housing matters in Plymouth's CDBG vrogr&n.
This requires that there be a public hearing sometime in November to satisfy tederal
requirements. City staff is suggesting that this public hearing be held on Tuesday,
flovember 25 at 7:00 p.m. .This would permit more time for public discussion than if
the meeting were held on a Monday night prior to a Council meeting. Tuesday, Novem-
ber 18 would also be a live option, however Council/Commissioners have a meeting on
both the 17th and 19th of that week. This meeting would be held in place of the
regularly scheduled HRA meeting for November.
Staff will have to know of the ComiM ssioners' wishes in this matter prior to Friday,
October 31 in order to meeting publishing deadlines.
Early next month a memo will be mailed to Commissioners outlining the type of CDBG
activities the federal government allows a community to use its CDBG funds for.
Attachment: November calendar for City meetings
AGENDA FOR CDBG PUBLIC HEARING
November 25, 1980
1. Purpose of Meeting
To provide the public an opportunity to hear a presentation of the proposed use
of Community Development Block Grant (CDBG) monies anticipated for receipt by the
City in 1981-82 (Year VII). Citizens will have an opportunity to address the HRA
concerning questions regarding the proposed use of these funds.
The City for several years has participated in the Community Development Block
Grant Program which, in Hennepin County, involves a joint powers agreement with
Hennepin County. Under the arrangement, the County, as an "urban county"
applies for Community Development Block Grant Funds which are then appnrtioned
among the communities which participate.
As part of that arrangement, Plymouth has two citizen representatives who meet
periodically with other community representatives to decide what projects would
best meet individual community needs. This committee, called the Planning Area
Citizens Advisory Committee, will be meeting during the next few months to advise
the various City Councils in Hennepin County how they believe the CDBG money
aiwu id ba spent.
2, The Meeting was Carefully and Thoroughly Announced as Follows:
a. Notices were published in the New Hope -Plymouth POST, the official City
newspaper.
3. Review of CDBG Receipts and Proposed Use.
James G. Willis. Executive Director
4. CCBG Anticipated 1931-82 Allocation
98,000 - Land Write Down Assistance
40,000 •- Rehab
5. The Procedure for the Hearing Will Be as Follows:
a. Write name, address and agenda number on blue card.
b. Pass card to person collecting them, who will give them to the Chairman.
C. When your name is called, come up to the microphone.
d. Please speak clearly into the microphone so that all may benefit from your
remarks.
3. No one may speak twice until all others who wish to speak have done so.
Please gi%e your name and address each time you speak.
6. Closing Public Hearing
7. HRA Action
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September 4, 1980
Mr. James G. Millis
City Manager
City of. Plymouth
3400 Plymouth Blvd.
Plymouth, MN 55441
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Thank you for your letter inviting my participation in a
meeting with staff of our local HUD office on Monday,
September S. I regret that I will not be in town that
day but have asked my Field Director, Iris Saunderson,
to join you at that time. Iris does nothandle my
legislation. in the housing area, but I know: that she
will try to be as helpful as possible.
BP:pce
Yours very truly,
Bill Frenzel
Member of Congress
nus 9TATIONCRY PanNTIo oK OAMR MA49. WITH RMYCLED Pl=RS
CITY OF PLYMOUTH
302.5 .HARBOR. LANE,, PLYMOUTH. MINNESOTA 55441
TELEPHONE (612) 559.2800
DATE: VmOrj I•FEMO
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YI.NNSAPOLIS, NINNCSOTA 99425
40121 940-3200
September 30. 1930
Plymouth H. R.A.
Attn: Mr. jim Willis
3025 Harbor Lane
Plymouth, MN 55441
PROPSSSIO.NAL SILRVIC89 RCNOSRSO:
Audit authority andCity records
prepare report 6/1/77 through
6/30/79; Research. HUD audit
questions and recommencbtion
and record to HUD Federal
AuditStandards $
2.107.00
BALANCE DUE $2.107.00
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October 2, 1980
Mr. Milt Dale
HRA Director
City of Plymouth
3400 Plymouth Boulevard
Plymouth, MN 55441
Dear Mr. Date:
As someone who works in the area of housing and/or community develop-
ment, I thought you would be interested in the enclosed summary of the
Housing and Community Development Act of 1980. The summary briefly
describes the bill's key points, but does not address all of the provisions
In the legislation.
The bill amends and extends all: of the major Federal programs in the areas
of housing and community development. Included in the bill are the new
mortgage limit requirements for FHA insured homes, as well as a 5 -year
implementation of the Home Mortgage Disclosure Act. Several. changes in
the HMDA are also included.
Both the House and the Senate adopted the Conference Committee version
of the bill on. Monday evening. It is expected that the President. will sign
it into law sometime this week.
If you have any specific questions or comments on this, or other matters,
please let me know.
BF: jb
Enclosure
Yours very truly,
Bill Frenzel
Member of Congress
TNIS STATIONERY PRINTED ON PAPER MADE WITm. RECYCLED PIBERS
Congressman 81'r i . gze1' October. 1980
Summary of Major Points: Conference Report on the-Housing and Community Development Act
I. COMMUNITY DEVELOPMENT
n tw eve 5—mer1t'Block Grants
the CDBG program is granted authorization for the next 3 years, beginning. with3.81 billion for F.Y. 1981
Eligible activities under the CDBG program are expanded:, especially in the area of--
energy conservation
A new provision is added that allows the inclusion of certain independent cities
in determining CDBG amounts for urban counties
B. Urban Development Action Grants '
The UDAG program is authorized for the next 3 years at a level of $675 million por'%y tr
Several changes are made to eliminate delays that have been encountered by communities
using a•UDAG in correlation with a historic preservation project
Several amendments are made to provide greater flexibillty for Indian tribes who wfsW.-'
to utilize the WAS program
C. Section 31, 'Rehabilitation Loan Program
Maxiimm Apaq,,amount for residential ;property is increased from $27,000 to $33,504 "
The definition of the hypes of buildings that can he rehabilitated under the„programIsexpanded
Authorization levels are increased, set at $144 million for F.Y. 1981 and not to ex-
ceed $12.9 million for F.Y. 1982
II, HOUSING ASSISTANCE PROGRAMS
A. Public Housing _. rehensive Improvement Assistar ce Program
Purpose of the program as defined in the bill is:
JI) to improve the physical condition of existing public housing projects and21to!upgrade tht management and operation -of such projects, in order to assure that
such projects continue be available to serve low-income families
Limits are established for the amount of assistance that is available to public housingprojectsforassistance, and application conditions are established
B. Sec,,,; sti_ on_8 . .
The Section 8 existing, new and substantially.rehabilitated programs are extended
under current guidelines
For moderate rehabilitation units the Secretary of HUD may -establish i.maximum'monthly
rent wnircn exceeds the Fair Market Rent by not more than 305 if such unfits are locatedinanareawheretheSecretaryfindscostlevelssorequire
For new and Substantiall rehabilitated units, the maximum monthly rent may notexceedymorethan101theF.R.R. esublished for an area
it. B. Sec ion 8 -grogram, cont.
III.
Financial assistance for the benefit of any non-immigrant student alien is prohibited
Income mix for elderly projects: Projects.(Section 8) that.are spoWically designedorelderlyamesareeexemptfrailtherequirementthattenantselection -criteria
be destgred to assure that projects include families with a broad range of incomes.
C. Section 235: S1nale.Family Homeownership Initiative
The bill"establishes a one year Section 235 Mousing stimulus program, to allow
higher eligibility incomes and higher mortgage limits than currently allowed undertheSection235program
Eligibility intone would be 1.30% of median intone for the area
Kor489e limits would be up to 82% of the new FHA mortgage limits for the area
Q. New Proft_sa_ls dropped in Conference:
A. House proposal to establish a subsidized
and a Senate proposal to establish minimum
tion were dropped from the bill.
middle income multi -family housing-progrem
Federal standards for Candominium rggula-
New FHA limits, Other Program Amendments and Extensions
A. Extension of FNA Mortgage Insurance Program
Authority of the Secretary is extended for one year to insure mortgages and loans
under programs contained in the National Housing Act
Norte limits, FHA insured:
The current ceilings of $679500 for a single-family; $76,000 for a two family; $92,000forsthreefamilyand $1.07,000 for a four family home would remain in effect. However,
In high cost areas as determined by HUD,. the Secretary could increase the maximum mort- gage limit up to $90,000, but in no event could the maximum exceed 95% of me4ian home
sales price for the area.
The same limits would apply to the Section 220(d)(3) rehabilitation and neighborhood
conservation and Section 222 servicemen's programs, except that the Sec. 222 program
is restricted to one family homes or condominium units.
FNA Interest Rate
The bill includes a provtsion for a der-ionstration program that would purmit the FHAinterestratetobenegotiatedfreelybetweenthebuyerandlender, with respect to10% of the FHA Sec. 203 volume of business, or 50,000 mortgages, whichever is greater. A 30 day commitment period, during which the lender would be bound by the negotiatedinterestrate, as well as the negotiated number of points, would be requtred. HUD
regulations will determine the administration and allocation of the program.
ggrte, rly review of FNA rate by HUD
The HUD Secretary is called on to review thoroughly the relationship between the FHAinterestrateandtheyieldsonconventionalmortgagesfrequently, in order to mini-
mize discount points, uncertainty, and speculation in transaction in insured mortgage. The Secretary is expected to make this review at least quarterly
f
Oil VbFrenzel, p. 3 October 1980
I1I. 6. Emergency HomPurchase Assistance Act Amendments
The bill revises and updates the "Brooke -Cranston" program, and extends the
Secretary's authority under the Act for one year. The bill. Increases the
mortgage limits and the purchase price limits for the program.
No funding for the grogram is included in the bill appropriating funds for
housing and community development
C. Temporary Nortgage Assistance Program
New program designed as an alternative to acquisition under the existing
assignment program. Authorizes the Secretary, in order to avoid foreclosure,
to make all or part of the monthly payments on behalf of a borrower who has
defaulted on mortgage payments where the default was beyond the borrower's
control..
D. Building Energy Performance Standard's.
Under the bill, the BEPS are delayed until 1983. DOE is called upon to con-
duct a demonstration project in two different climatic regions and submit a
report -to Congress on its findings
E. 5 gear Rome Mortgage Disclosure Act
The original Conference.Report contained a provision that would have made the
H.MeD.A. permanent. A resolution was passed by both the House and the Senate,
however, which sunsets the Act after 5 years. Changes made 1n the Act include:
SMSA's would be defined by the Commerce Department instead of OMB
Census tract reporting would be required in any county within a SMSA or
with a population of 30,000 or more
Reporting would be on a calendar year basis
the Examination Council would be required to compile data for each SMSA
and HUD would be required to comply with FLMDA for loans they make which
are net otherwise reported
IY. elannift'Mststance
Amends the Section 701 program to redirect it toKard encouraging states, local
government, and area -wide planning organizations to develop comprehensive plans
V. Rural housing
Amends and extends Farmer's Hone Administration authority for one year
vv... ...... ....... . . .
77.
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U. DEPARTAENT OF HOUSING AND URSA'*- DEVELOPMENT
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MOEN AND PENTTILA, LTD:
CCRTI/IED PUBLIC ACCOUNTANTS
SUITE 203 VALLEY SOUTH GUILDING
1160666 or
Y1I[IIICIIN INSTITNTi OF CRIITI)IEO PUIPLIC ACCOUNTANTS
City of PIymouth
Plymouth, Minnesota
Attn: LloydRicker, Finance Director
Dear Mr. Ricker,
0900 WAT2ATA SOULEVARO 16121 016.3208
MINNEAPOLIS. MINNESOTA 55420
October IS.. 1980
In response to your request of October 9, 1980, concerning
the amounts due to or due from the Housing and Redevelopment Authority
Of the City of Plymouth by the City of Plymouth, as of June 30, 1979
we submit the following summary:
I. Accounts receivable -City of Plymouth
General Fund $5,201.00
HRA (Agency) Fund 702 . 7,797.00
T $1299800
The $5,201.00 due from the General Fund as of June 30, 1979, has been
paid as of this writing. This represents one-half of the collectible in 1979
taxes of $10,402.00. The procedure for handling the HRA tax levies, as
you are aware, to for the General Fund to transfer annually to the HRAtheentiretaxlevyascertifiedforcollection. The General Fund then
retains all collections made for this levy and accounts for all receivables..
On March 11, 1980, a wire transfer of $10,466.36 was made to the HRA
Authority) f om the City's general checking account. Of this transfer,
10,402.00 was in payment of the collectible in 1979 taxes.. The $7.797.00
owing from the HRA (Agency) Fund 702 is still outstanding (see item #2below).
2. Accounts payable -City of Plymouth
HRA (Agency) Fund 702 $ 7,932.96
This payable to the HRA (Agency) Fund as of June 30, 1979, can be
offset by the receivable of $7.797.00 as stated in item #1 above which
Will resultin a net liability to the City Agency Fund 702 as follows:
Receivable from Fund 702. $7,797.00
Payable to Fund 702 7.932.96
Net Payable to Fund. 702 W
3. Note payable -City of Plymouth
Investment Trust Fund 701 $15.000.00
This note is evidtnced by a signed demand note dated December 1, 1978, due to the Investment Trust Fund. The note as of this writing has notbeenrepaid.
October 15. 1980
Page 2
The above information is submitted so as to expedite your work
in setting up a separate set of books for the Housing and Redevelopment
Authority completely independent of the City's accounting. system. We.
recommendthat, within the MRA accounting system separate funds be main-
tained for the Section 8 and Home Improvement programs.
Should you. wish to discuss any of the above information or have
any other questions relating to our report dated July 22, 1980, please
fsel fee to contact us.
Respectfully,
A Ct - -eavv`yhw--
MOEN t PENTTILA. LTD. .
16 •
October 15.- 1980
Nancy Bratrud
t
Gr? OF
PLYMOUTH
Assisted Housing Management Branch
HUD Area Office
6400 France Avenue South
Edina, MN 55435
Dear Nancy:
In response to Mr. Feeney's letter of September 2, 1980 I am enclosing a check
for $15,923.33. This complies with Finding No. 6 of the recent Plymouth HRA
audit. Also enclosed is a listing of account code numbers to indicate that the
City of Plymouth can provide the required accounting. services. This complies
with Finding No. 3.
As you also know, I have submitted certain required items requested by your
parch Management Review and I will continue to do so in as speedy a fashion as
is possible. However, the Housing Authority staff in Plymouth consists of only
one (1) rtoulti.ng.middle-aged city planner --we are not in the same league as the
Minneapolis, St. Paul,. Metro or Dakota County MRA's with their specialists in
every field. In June of this year, a reduction in City revenues forced the
termination of one secretarial support person. (You see, the City of Plymouth
and the HRA favors the rather strange fiscal policy of not spending any more
money than it takes in!)
Our Housing Authority has made it a primary goal to maintain qualified Section 8
tenants on the Program in Plymouth as indicated by our full utilization of the
Program. This in itself takes time.. As well, we are committed to operating a.
productive housing rehabilitation program. This takes time, especially in view
of the fact HUD and Hennepin County continually escalate the reporting require-
ments. The truth of the matter is we are delivering the services. However, we
have not always provided your office w tai all the various documents attesting to
this fact. As well, there have been certain computation errors made by myself
that must be corrected. I assume full responsibility for any such errors. It is
my sincere intention to make corrections and resolve all differences.
May I state for the record that it is very unfortunate that programs like Section
8 and now the housing rehabilitation programs are becoming mired in red tape and
bureaucracy. These programs have been reasonably helpful to a wide range of lower
and moderate income persons. However, now the growing cost of administering these
programs, due to the inordinate amount of required supporting documents is fast
making these programs prohibitive in a community like Plymouth. As is often the
case, the loser will be the person the program was designed to help. Vour
positive efforts in supporting less documentation would really be a help in
keeping programs like this operating in communities like Plymouth.
Sincerely,.
Milt Dale
Plymouth NRA
Attachments: Check
List of Code Numbers
3000 PLYMOUTH BOULEVARD; PLYMOUTH, MINNESOTA 55441, TELEPHONE (812) 559-26W
kra[• c/o Nancy Bratrud
HUD Area, Office
6400 i rance Ave. South
tdina, K104 55435
CITY HALL *KYMOuTH, MINNESOTA 5S441
TK FOLLOI.WiG ARE CMAFGES TO YOUR 131i'v"AT
Oct.1S
Oct_ 15, 1980 .
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wt _19--_
L 1. t;TRlJ., TAt CCPV
ml r
yrs `• - .-' •,.. { •
i - •
1/10 FOR VAYMkNr
002 128
14OUSING* ADEVELOPMEN r. AUTHORITY 0 J 10U- f" 0012.281
lfwh-w N - Me 1=0 I NW.MWAY 53•
17, JqLVlM0UTPLMUM%HA:MW t,' "4t - 910
PAY IMCTLY
10/16/ .41580P2.2h 923.33Ji
7ia3i
4 0 0
o HUD Ai6ix bffice
Attention:; Mah- B 4'rcy. ratrud
6400.Francc,.AVenue South
Edina, Wnnesoti'SS435'
W
St
400 EXEC ME DIRECTOR
T
0
yrs `• - .-' •,.. { •
i - •
1/10 FOR VAYMkNr
002 128
14OUSING* ADEVELOPMEN r. AUTHORITY 0 J 10U- f" 0012.281
lfwh-w N - Me 1=0 I NW.MWAY 53•
17, JqLVlM0UTPLMUM%HA:MW t,' "4t - 910
PAY IMCTLY
10/16/ .41580P2.2h 923.33Ji
7ia3i
4 0 0
o HUD Ai6ix bffice
Attention:; Mah- B 4'rcy. ratrud
6400.Francc,.AVenue South
Edina, Wnnesoti'SS435'
W
St
400 EXEC ME DIRECTOR
T
0
a . DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
MINNEAPOLI"T. PAUL APIA OFFICE
SW FRANCS AVENUE SOUTH
MINNEAPOLIS.. MINNESOTA 5035
REGO* v
Mr. Hilt Dale, AssoCiate Planner
Housing and 0 1 Authority
of Plymouth
U0.0 Plymouth Boulevard.
Plymouth, Hirmsota 55441
Dear We Dale:
Subject: Sdxdosign of Secti n'$ Year End Finmwiai Statements
M46 -E170-002
lel REPLY RIVIR TO:
HMA:DC
The year end financial statements listed below for the Sections 8 Program have
not been received by our office and we overdue for fiscal year ending Jule 30,
1980.
HUD 52681 - lbudW, for PaymWt of Annual Cnntrfbuti ss
Original - Regianal A000unt3ng Division
Dopy - Area Office
HUD 52682 - Operating Statement, housing Assistance Payments Program
Original - Office of Finance and Accounting
Copies - Regional Accounting Division and Area Office
HUD 52595 - ealancae Sheet - Lew Income Rousing Program
original - Office of Finance and Aeeosnting
Copies - Regieasal, Accounting Division an' Area office
The reports are to be submitted not later than 20 days after the end of the fiscal
year. If Line 23 an the HUD 52681 indicates that an. is due HUD, the
overpayment is to be submitted with. the 52681 to the Regional A000unting Division.
Supporting cloc m—itation must be attached to the 52681 if column 2 figures exceed
column 1 figures before the overrun can be approved by our -office. Refer to the
Rowing Assistance Payments Program Addountfng HHancmook 7420.6 dated February 9,
1978 and Findbook 7420.3, REV -2, CH 6-2 dated Novecber 9, 1979 for additional
3n61orasa1 regarding the submission of these fornix.
Please submit the reports to our office immedfatrely.
These reports must be received by our office before we can. approve payment of the
next requisition for the quarter ending March 311 1981 (due in our office by
Deomber 5, 1980) . Please inform us why the statements were not st bmlitted at the
required time. The forms are enclosed for your =ndenienee.
rely. I I
AU S 0 i&
Thomas T. Pee W
ft
Area Massager
0.
U. S. 96PARTMENTOF MOUSING A -ND URBAN DIVEIOPM04T
NOTICE E:9
Ageru.iea and Owners - Section R tbufi;-tg ASSistance Payments program
includi:m Existing dousing, Moderate P-ehdbilitation, New Construction,
To.: slubc,tanti. babilitation, State Agencies, Far.wwrs Hama A4kninistration,
motion 2C2, tr*A Pmperty Disposition -i d Loon ManaqOmmt Set -Abide
Programs
SUBJECT: interim Rule ):.Sgardi ng Changes in Colnwputation of Gross
Fatly Contra bUtAon
Attachment A to tiihs notice is a c -xv of an interim ride and supp'c„nritMY
nformatior regarding computation of dross family contributicn piib isbed in
the Federal Register, Volune 45, "Unbez 176, Tue-sday, SeptedW 9, 980.
jjj,e3 intzerim rule changes the oampu tion :f gross faint ly ta nrx ik r i•7• for
fainiiies whose gross family c ontrihution MV bp 15% of monthly gross ince:
rather than 25% of monthly irneme after a11cFw&.~ s.
Attachment D ins a dhart, developed by the Area Cf iO), which may be Of assistan"
t,o you in clarifying the ctw4ca made by this # nt er. r rule.
19A) is roqu45ting cxtrmwa.ts3 On this interim rule, parti.ew-'ar-ly in regard :o any
rwquit:ies you fw%l may runiult From imp,QnWjta#ior' or suggestiorw for reducirrl
any hart abips. This office plata -to Wtv t= cufmymts anw3 we strongly urge you
to :submit your axmmmt.s as we11 to the Ru,.es [krket Clerk, Of Fide of General
Coun.Sel, Roam 5218, tx1mrt:m>ont of Housing and Briar, Developnent, 41-11 Seventh
Street Southwumt, Washingtort, D.C., 20410. Convents are due in Washington by
bvadber 10, 1980.
4.ea Marm. or
At, taclIMMt s
9v
HUD -2101:1117-P HUD-ftsh-. D. C, 6-F7
Federal Regloterr / Vol. 45, No. 178 / Tuesday. September 9, 2080 / Rules and Regulations 58309
rent crodlt 40 i ss the ranula to
thalr present wttts'!bs 1 epartnaeat has
determlasi , for consistency. that there
should be a point in time when this
aspect of I% program Is mmpletaly
eliminated. and public Housing
Agencies (PHM) are no longer bold
accountable for thls roce l»te,. At the
same tfaw vre feel to credit should be
phased oatggrradually rather than so at
onm Therefore, the final eine states that
thereat credit wW be eliminated from
the prooraft within three years. since
lasses for a nUs under the program
rrsuant to Seaton 882.!07 "... shoo
for not lesii than one year not more
an Weir yeah..
Six of the 59 co;n.nreats opposed
eliminating tits Rent Credit tam the
Existing Housing Phigram regulations.
nne comment. Indicated that. Ifthis
Incentive wars removed there would be
no motivation for tenants to select units
with rents below exhting FM?s. In
considerintg these comments, the
Department observed that one basis for
CAD's recommendation for eliminating
the Rent Credit was that It appeared to
ha -,-e a usgllole effect on the number of
families aelactlol cheaper housing. This
is because half ai the families receiving
the Rent Credit did not move from the
unit they lived in before applying to the
pmgram. Alm are discussed in the
Proposed rola current studies and other
evidence suggests that assisted families
had a negligible role In negotiating the
terms of the Section a lepse, Including
the amount ofrent.
Three comments suggested that
eliminating the Rent Credit from the
program would be detrimental to
elderly, handicapped, and working
f.mmJies as those families would more
likely sutler rent increases as s result. to
response to these comments, tbt
Department fasts that the Increased
etnounts that any family would have to
pay uivn the elimination of the Rent
Credit would be minimal and. at any
rate. the family would pay no more than
between is afro. 2s percent of thelr
income for lwuaing as required under
Program regulations.
As web noted in the proposed rule, the
Senate Appropriations Committee
Report on the 1978 HUD Appropriations
1),11 directed tiro Department to elimNc rets
the Rent Credit far families who do not
r"0038 to move. However, many of the
Comments which favored the elimination
til the Rent Credit expressed the concern
that if it Is to be eliminated for
applicants who tepee sn place, it must be
ehrn;nated for all In order to prevent on
unf Ar situation. We agree with thio
Position since there are no compelling
r^asc!rs, given the nature of the Rent
C:t-:411, to euminste it for certain families
w011e continuing It for others.
Given the complexity of the current
formula for real reduction. and iSe
recommendations of the Senate
Appropriations Committee, GAO and
others, the Department believe$ that tl-o
present teat reduction credit sbo..dd be
phased out. This does not preclude
fuhure consideration of other methods of
cost cental mens.
NEPA.
A Fin&,& of roopplicahility with
respect to environmental impact has
been prepared In accordance with HIUD
procedures. A copy of this finding of
inepplicobility will be available for
public Irspectin during regular
buslnees hours at the Office of Rules
D.vket Clerk, Office of General CounsrL
Roost 5218, Department of HOU$°ng and
Urban Development. 451 fth Street.
S.W. Washington. D.C. 2NIM
This rule it not hated in the
Department's semiannual agenda of
significant rules. published pursuant to
Executive Order 12221.
Accordingly, 24 CFR Fart 882 Is
amended as follows:
1. Amend i Burns by adding a 601111?
paragraph (d) to read:
88tt is Rent reduetlon tneantive.
d) As of (insert effeciive date of these
regulatfonL no family entering the
pnogrsnn may receive a Rent Credit For
any family currently trecel ft a
reduction In its Cross Family
Contribution because the unit selected
by the family has a Cross Rent less than
the Fair Market Rent or bigner rent
approved by HUD under; 8$2.106(a)(3),
the rent reduction will be eliminated. at
the end of the stated lease term or when
the faintly moves to another unit,
whlchave-• is earlier.
Section 7(d). Department of Housing and
Urban Development Act, 42 U.S.C.3s3s(d))
Issued at Washington, OZ. Oeptember 4,
loom
Lawrom 8. Buns=*,
Aselstatml8@cretory jorH#wi4y—Fedewl
10118108 CommisotOner.
Ira Coe. senses Mild sena 90 so
911461" coos 4e1M1411 .
a.
24 CFR. Part 869
IDodret too. 04044311
Seetlon 8 Mousing Assistance
Payments Program --Computation
Gross Fondly Contribution
Aaa 4m. Office of the Assistant
Secretary for Housing•-.>rederal. Housing
Commissioner. HUD.
AC OM interimtn tuts.
sUMNAM HUD is issuing this Interim
rule to revise Its regulations for
datermiNng how much of Its Income a
Family pays towards rent under the
Section 8 Housing Assistance Psyments
Program This Interim revision reflects
recent statuttaffne e
PAI* -
980}
Comments due: Comments should be
filed on or before November 1o.1980
AODWAS: File comments with the Rules
Docket Clerk. Office of Ceneral Counsel,
Room 52.18: Department of Ho"84V and
Urban Development. 462 Seventh 51teet.
S.W.. Werhlaliton. D.C. 204:0.
row FURT fur tNFOAtaAT1oN co1RAcr.
Emiward Whipple, Chief, Public Housing
Rental and Occupancy Branch (2112) 765-
1,942, jaures Tehash. Director.
Meld amilP am Phan Division
202)428-8730 Stephanle Gtddinge.
Existing Housing Division (202) 70-
8598. Department of Housing and Urban
Development, 451 Seventh Street. S.W..
Washington. D.C. 20ti0 None of the
above telephone numbers is to!1--free.
3NPftAMaMARY 111/OONAT101% Section
202(b) of the Hou§inrtgg and Communis
Development Amsndments of 1979 (PL
93-153) amends Section 0(c) (3) of the
United States Housing Act of 1937 by
establishing new rules for computing the
Cross Family Contributions required of
some Eligible Families. RpeciRcally, the
Amendments raise the Cross Family
Contribution required of Vol Large
Lower-income Families (Without
Exceptional Medical or Other Expenses)
from 25 to 20 perceal of family income,
and raise the minimum Cross Fancily
Contribution limits applicable to certain
other Lower -Income Families from 13 to
20 percent of family Income. These
amendments also permit the Departmant
to raise the maximum from 25 to 30
percent of family Income. Section 202(c)
a id st the ntthorzebySection202(b) ee not to
be applied to "families whose
occupancy of housing units assisted
under the United States Hoeing Act of
1037 commenced prior to (January 1.
1980) ... so long as such occupancy is
continuous thereafter."
In order to Implement the statutory
requirements as expeditiously as
possible, and to facilitate the orderly
tronsillon to Ehe new requirements for
program administrators. the Department
flas decided to make the fewest possible
changes at tds time, consistent with the
statute. In addition. the Department has
d ermined to minimize the financial
hardship to certain families. consistent
with the statute. Accordingly. allhoagh
the required change in the minimum
f 5016 Federal Register / VOL 41k Na 276 / Tuesday. September 9, 1980 Mr .Rules and Reputations
family contribution fiea#e tom pea^eeat
Of fad Income for an" Is
te
Increm the maxlmwa conlributlnn for
eetrtalm other families fran.2s to 80
percent of fam ilr incomes
To avoid the hardshipwhidrwould
result if affected families were rc-etfroil
to make retroactive payments be& to
January I. low (theaffeLeve"ot the
azmwmenbi HUD co=M= it
necessary to lima theimmediats affect
of the statutory chamtgsatahmilitewho-
brgin occupancy eo dgre atlas
publication of this cola.
HUD has daterminedthat a
retroactivepsyment;requle+sm mt, would,
impose umrdua administrative burdens os,
Public Housing Agenda CH>!tG) and
Section 6 owners and wouldlmpose
tinandsi burdens on,manyotiha .
affected Families. Altering.do teases of
such Families to reflect Intodas<
increases is Gross Family Canhibutiaas
for ibis reason could also be
incoo-ostent with, soma Stats Iowa
relating to tettanpa tigbW thereby
potentially axposing owners and HUD to
litigation.
Section 8t!s.100 it being revised to
indicate that ths,Grow Familp-
Contribution required of certain Very
Large LoweFandlies (Without
Exceptional Medical orOthwExpenses}
and otherlawar &icoms Families not
covered to otherc3tegorlesfadependent
upon the time at whf& the Family
establishes occupency in a PHA's
Existing Housing program or in the same
Section 8 assisted project. Under the
revised regulation, a Family will be
subject;* the now Gross Fondly
Contribution requirements if it eases a
Sections unit on or after the effective
dote of this interim nils. but will not be
affected by the cdt commenced
occupancy prior :.r Januaryl.200and
9mtei..w occupancy in the rare PHNs,
Eaclsting Housi ag Programa or In the same
Section 8 ass+ated project on a
cc,--inuou! :tests. A ea.milywhfch
initially leased a unit is a program or
prolectonor afterlamwary 1.1984 but
phot to the affective date of this interim
rule. win notbe affe..ed by thaehanges
until its current lease expires oruntli its
next income reexamination (asyrovided
in the lease) whichever occeaex VOL
In as Interee. of implementing
promptly the amendments o[SectlmrM
which were tc• havetmmediately
affected famf!ies entering thepmagram
on or after January 2.1984t Rae
determined that good cause exists for
making these revised regulations
effective on an interim besis. Althougb
the Department beano definitive
knowledge at this time of the effects of
the statutory changes (Ley the absolute
or relative payment level of various
families in telattoa to iarooma. eines and
other factorst HUD halsAolennfned to
implement that --MM"- L eonsistant witir
the statute ias, mmtanues which would
cause the leastamountaf discretion of
cement practices, The Departmeul W
hewer interestedin receiving, and
invites commentsragardit sar
peeeeived inequities and suggestionit for
redw ft any hardships. Suit comments
will be given full consideration before
the Final Ruta is adopted.
This regulation implements the
mandatory peovisiuns cf the 1s79
amendments onlyfor.the Secti'on,&
Housing Assistance Payments Program
Including Edst[ctgHousing„Moderate
Rehabilitation. Now Cortstruetiom
Substantial Rebabditatfoma State
Farmer`s Hoare
Administration. Section 20L and
Ptu" Disposition and Lona
Management Set -Aside Programs)
In addition; the Department expects to
publish an AdveneeNotice of Ptoposed
Rule solici . public comment& on other
dumps to achieve the maximum
consistency In astabiishimy tenant maw
between *,i Section 8 and thepublia
ho la.na prcm,,e•ams.
Nl?.1}A
The Department has determined that
these regulation do not constitute a
mejorFederal action significantly
affecting the quality of the human
environmeft Arvardingly. a Finding of
no Significant impact under the National
Environmental Policy Act of 1989has
been made and is available. for public
resection durlrtgregular business hours,
in a OEilce of thhe Butes Deicer Clerk
at the address specified above.
This is not listed in HUD's semiannual
agenda of significant-.tles, published
pe-ivant to Executive Order IMM
Accordingly. 24 CFR Part888 is
amended by revising: J 889105 to read.
as follows:
I 889.105 Computation of Wass, MOW
rear! wtion on • 1 M MY fess%.
If a hunily qualifiedfor more then one
category, select the category resulting in
the inwest monthly gross family
contribution.
a) Very Low -Income Family. The
monthly grass family contribution abaft
be 25 percent of the family's monthly
Income after allowances but In no event
less than 25 percent of the family's
Montt. income.
b) La:ear Very Low•lncoma Family or
Any Lower -Income Family with
Exception' 'Medical or Other Expenses.
Its mouthti gross fe pily con dbutton
shall be 15 percent of the family's
monthly income.
c) Very flange Lower4ocome Family.
The menthly, plops family contribution
shall be Mpercent of tha faWs
monthly incomewmpt that:
1) For a family who began occupancy
of an assisted unit prior to JannaryI-
2980 and whavontinuer to participate Im
the game Section a Existing program or
who continues to live Is, tho same
Section s assisted project the montblr
gross family contribution anall be 25
percent of the family's monthly income
and
2) For a family whose occupancy
commencedon or after lanumyri.IWO
but prior to the effective date of this,
rule. the monthly gross family
contributioasW be computed Is
accordance wtthparagrapb (cl(Q until
the tine of the family's next lease
expiration, (as provided in the lease) or
Income reexominattan6 whichever is
sooner.. At that time t:•a family will be,
required to begin paying 20 percent of
the family's montaty income.
d) Other Lower -Income Fanzi)y(witb
incomeabovebOpercent of median.bnt
not exeeeding80pe mie The monthly
gross family contributioo shall be 23,
percent of the family's monthly income
after allowances. but Irmo event tees
than ao percent of the family's monfty-
income except thea
1) For a family whose participation In
the some Section 8 Existing program or
whose residency in the same Sectiun 6
assisted project commenced prior to
January L 3980. the monthly gross
family contribution shall be 25 percent
of the family's monthly income after
allowances. but in .no event less then iS
percent of the family's mor thly income.
and
2) For a Family whose c:cupancy
commenced oa or after January 1. IM
but prior to the effective dateof this
rote. the monthly gross family
contribution etalkbe computed In,
accordancewith parogroph(d)(i) until•
the time. of the family's next least
expiration (as provided In the lease) or
Income reexamination. whichever comes
Gret. At that time. the family will be
required topey25 percent of the
family's monthly tncom after
allowaa n. t Jas 7{+'s, not
ac7(s, I. ' JM Act (42 U,S C
a ss(dl)l
issued at Washington. D.C. July, 23.ISM
Lawrence 9. Simons.
slant SecrMiy forhoushW—Federal
mousing cammissioner.
IMaspnamePTMAs 44FLOW.1
Mauro Coos ueoaacr
C OMMIM OP GROSS PRWX C!FOR SUMCN 8 Pi S - Effective Nw3ber 10r 1980
1. VERY IN DMM MaLM (Ulxier 50% of median inoon e) :
a* with kno' mediml eVense in exw3s of 25% of
anneal * *Yme . . . . . . . . . . . . . . . . . . . . . . 158 of monthLy inocme (gross) ID
b. with six or more minors . . . .. .. .. . 6 . . . . . . . . . 15% of monthly iw me (gross)..
c. with five or fewer minors . . . . . . . . .. . . . . . . . 251 of monthly income after allowances, but not
less than 15% of monthly income (gross).
2. tOM 003CM PAMZM (Xh=n a above 508 but not emeeding 80%):
a.. with medical ewe in excess of 259$ of
annual incgme . . , . . . . . . .. . . . . . . . . . . . in of monthly !nacre, (gross)..
b. with eight- or more minors:
if leased on or after 11-10-80. . . .. . . . . . . . . . . 20% of monthly income (gross).
if leased prior to 1-1-80 and continues to lease
in same Section 8}-E pr+ogran or assisted project . . . . 15% of monthly income (gross).
if leased an or after 1-1-80, but prior to 11-10-80. 20W of monthly income (gross)- not effective
until next lease eviration or reexamination,
wrrichever comes first.
c.. all other loner inomie families:
if leased on or after 11 -10 -Po . . . . . . . . . . . . . . 25% of mthly income after allowances, but not
less than 2.08 of monthly irname (gross).
if leasE d prior to 1-1-80 and continues to lease
in same. Section 8 E program or assisted project 25% of monthly income after allowances, but not
less than 158 of monthly income (gross).
if leased an or aftez 1-1-80, but prior to 11-10-80 . . . 25% of monthly income after allowances but not
less than 20% of monthly income (gross). -
not effectix: until next lease expiration or
ninaticn, whichever OCMS first.
ND F : If a famulyy qualifies for yore than one category, select the category resultirq ir the low-st monthlygrossfardlycontribuLion.
November 5, 1980
Mr. Thomas Feeney
HUD Area Office
6400 France. Ave. So.
Edina, NN
Dear Nr. Feeney:
CITYOF
PIYMOUTfF
This letter is a request that the HUD Area Office not require. that Plymouth: send a
representative to the upcoming Section 8 Existing Housing Quality Standards TrainingsessiontobeheldDecember3-5, 1980 for the following reasons:
1. Over 99Z of the rental housing stock in Plymouth is under 15 years old.
2. Staff assigned to make inspections has had class work in inspections and
rehabilitation of housing within the last three years. (Previous to this, this
staff person had built his own house piece by piece.)
3. Removing the sole. administrative person from his. day-to-day responsibilities
for threee days is a heavy administrative burden to impose on a small housing author-
ity. (We have one part-timee staff person.)
4. The cost for the session, $270.00, is.a high price for a housing authority
of our size to absorb.
S. Previously, in August of 1979= HUD had its own inspector check out several
rental units in Plymouth and he discovered the following significant(V) deficiencies:
a. Living room screens needing repair,
b. Broken glass In a rear common door,
c. Large crack in a sidewalk,
d. A crack in a window and no screen,
e. Collapsed garage that needed rebuilding.
When I see the public shame of "housing" (if it can be called that) for raigratory
workers in other parts of our country with nothing really being done, I -do believe
HUD is failing grievously in using its resources and personnel effectively. It is
a!Y opinion that seminars of this nature may well be necessary --but only in those
areas where true f)ross disregard of housing quality standards exist.. This is not
the case in Plyw,.—h.
Unless wise discretion is used in the expenditure of public monies --soon there may
be very little public monies for even essential needs. This type of "training"
is a case in point. It points up the folly of a "cookie -cutter" approach to solving
what may be a problem in one part of the country and forcing everyone everywhere to
adoptthe exactsame policies. (In this regard, I would like to quote Abraham Lincoln
who said,"I never had a policy. that I could always apply. I've simply attempted to
do what made the greatest amount of sense at the moment.")
i cerely
le
Plymouth HRA
3400 PLYMOUTH BOULEVARD, PLYMOUTH. MINNESOTA 55447, TELEPHONE (612) 559.2800
sIF %%1(7
November 10, 1980 .
CITY OF
PLYMOUTR
Mr. Thomas Feeney
HUD Area Office
6400 France Avenue South
Edina. M
Dear Mr., Feeney:
I note with some concern that you are requiring all local PHA's operating in
the Section 8 existing housing program to send one staff person to a seminar
scheduled for December 3-S.
It seems to me that your office should a"t Ahe responsibility of providing
such training as may be required for local housing officials in order that
they can comply with Section 8 requirements. Instead, it appears that you
are suggesting that this function be delegated to private consultants with
the local officials having to pay the costs.
I would appreciate hearing from you personally as to the basis of the require-
ments set forth in the Housing Quality Standards Seminar brochure requiring
local. attendance. In addition, it would be helpful to know why the local HUD
office is unable to provide the required training in order to meet its own
requirements.
Yours truly,
aures G. Millis
ity Manager
J(N: jm
3100 PLYMOUTH BOULEVARD,. PLYMOUTH, MINNESOTA 55047, TELEPHONE (812) SNOW
221]17-P
U. S. DEPARTMENT Of HOUSING AND ORGAN DEYELOPUNT NpY Q
NOTICE 81-2 - a_
TO: All PMs Administering the Section 8 Using Assistal Program
aoeAeT. Year Ind Settlement Fawn M 52681
The Vwc her far Payment of Annnal Contributions ilcusing Assistance Payments
Progxamn, i aD 52661, detOmdnes the year-emd settlemnt of an urlderpapent due
a. PmA or an. Overpayment clue. HIS. If in arriving at the mmut of the settle -
Mont your request for funds inaoluma two (2) emeeds the apWoved amaount of
any figure in ooltmM one. (1) budgeter' amount, you ave required bo 8%*'Lt docu-
mei tation showing hoer the various amounts were caYmulated. You may include. any
dlpl,anaticns that will assisc you in justifying the overr m. "t* AcSministrative
Fee re.*mted is to be a=mmmted on a monthly basis whether or Mot there is an
ova as follows:
Units Allowable Total
Mnth UnOW Lease X r_i X PWmt "fie
1ltis procedure foes not infer that. Budgets no longer need to be revised When
an overrun is anticipated . It is intended far those inslanoes where t3:ere is
insufficient time to process a revised budget.
If you have arW questions, please contact. Your- Fimncial Analyst in the
Assisted Bolusing 163nagement Branch..
A44w""
ea =armW
llv mmb-. a G HUD -216
W