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HomeMy WebLinkAboutHousing & Redevelopment Authority Packet 04-16-1992MEETING OF APRIL 16, 1992 AGE.N0A PLYMOUTH HOUSING AND REDEVELOPMENT AUTHORITY April 16, 1992 at 6:30 p.m. 1. Call to Order 2. Approval of Minutes for March 19, 1992 Meeting 3. Section 8 Program - Final Report on June 1991 Management Findings 4. Senior Housing Project - Attorney's Review of Preferences 5 Scattered Site Homeownership Program - Review of Plans 2 and 3 6. Section 8 Operating Reserve 7. Information: a. Response to Plymouth's First Time Homebuyer Program b. Section 8 Summary Statistics Report, 4/1/92 c. Section 8 Financial Report for Period 7/1/91 - 2/29/92 (Balance Sheet and Operating Statement) 8. Other Business 9. Adjournment hra/agenda.4-16) MIR 0 2S• MEND CITY OF PLYMOUTH . 3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA 55447 DATE: April 7, 1992 For Housing and Redevelopment Authority Meeting of April 16, 1992 TO: Charles E. Dillerud, Executive Director Fall: Housing Specialist Milt Dale SUBJECT: SECTION 8 PROGRAM - FINAL REPORT ON JUNE, 1991 MANAGEMENT FINDINGS ACTION REQUESTED: Information item.. Two HUD personnel will be attending the meeting. They are Patti Hannay and Kaye Pistilli both Housing Program Administrators with the Minneapolis -St. Paul HUD Office. On June 26 and 27th of 1991, the Minneapolis -St. Paul HUD Office had HUD employees Patti Hannay and Kaye Pistilli do a Section 8 Management Review to cover the period from its last review in 1987. After the review, Ms. Hannay and Ms. Pistilli discussed in general terms, their review findings. In early September, a letter came from Mr. Thomas Feeney, Manager of theMinneapolis -St. Paul HUD Officeoutlining the findings and expected action to be taken by the Plymouth Housing Authority to comply with the findings. On September 23; 1991 we provided a letter to Mr. Feeney outlining the actions we were taking to comply with the findings. On October 7, 1991, we sent a second letter to Mr. Fenney following up onhisletterofSeptember4, 1991 relative to four specific findings. On October 18, 1991 we provided more detailed information to Mr. Fenney astothefilereviewsectionofthetheirfindings. On November 14, 1991, a letter from Mr. Fenney cleared several of thefindings. Later in November, as a result of a follow-up review conducted by Ms. Hannay and Ms. Pistilli, a letter came to us from the HUD Office on January 29, 1992. This letter requested an additional response from us. On February 12, 1992 and again on April 4, 1992 we responded to the HUD letter of January 29, 1992. PRIMARY ISSUES AND ANALYSIS: The HUD Office has found our responses to their management findings acceptable. While some of the issues were serious, they felt the corrective action taken was adequate to comply with their directives. One of HUD's primary concerns was allowing over 206 of our Section 8 allocation going over Fair Market Rent. We have corrected that deficiency and at the present time have granted no approvals over Fair Market Rent. This situation has been helped considerably -by the significant increase in Fair Markets Rents on October 1, 1991. We are, with our computer program, monitoring Fair Market Rents closely. Another important issue related to maintaining the waiting list current and updated. We updated the waiting last fall and are continuing to maintain the waiting list in an orderly fashion. On April 8, 9, and 10, 1992, Denise Hutt and myself are attending a HUD sponsored workshop for Section 8 program administrators.. We also have maintaimd close contact with our HUD staff liaison Patti Hannay. As well, 1 have been attending the Section 8 portability meetings held in St. Paul on a quarterly basis. CONCLUSIONS AND Sinct. this is basically an information memo. I feel that Commissioners should avail themselves of the opportunity to discuss program particulars with the staff or the two HUD personnel at the meeting on April 16, 1992. At this stage, it is my understanding that all findings have been cleared. 1. Letter from Thomas Feeney, 9-4-91 2. Letter from James Willis, 9-23-91 3. Letter from James Willis, 10-7-91 4. Letter from James Willis, 10-18-91 S. Letter from Thomas Feeney, 1144-91 6. Letter from Thomas Feeney, 1-29-92 7. Letter from Milt Dale, 2-12-92 B. Letter from Milt Dale, 4-3-92 hra/md/4-16.0) SEP 41991 C. Gerald wells, Chairperson 80:6329 and Redevelopment Authority of Plymouth 3890 Orleans Lane Plymouth, Minnesota 55441 Dealt Mr. mallet as o w100d w wa+e w VOM asrdW.nN soGmM Mplea v lusmid Shaft SEP 9 M CITY OF PLYMOUTH COWANTM I ma".. SUBJECT; Department of Rousing and urban Development Management Review of the Section 8 B:isti2g Program BnclOaed is a copy of the Management Review Report covering the subject program. The field audit wes•conducted by no. Patti Bannay and Ms. Saye Pistilli of the Assisted Rousing Management Branch staff on June 26 and 27. 1991. The attached report contains ten findings with required corrective action. Due to the seriousness of the Federal Rsgulation and. Handbook violations contained In this report, our office will schedule a follow-up review upon receiving your response. We believe it would be beneficial to both parties to arrange a meeting between the Board of Commissioners and members of our staff to discuss the serious issues raised In this report. Please respond to all findings, required corrective actions and recommendations within forty-five days of the date of this report. is your response, advise as of the actions which have been taken to date and if the actions will necessarily exceed 45 days, provide us with a eobedule for their completion. 2 If you have any -questions or need assistance, please contact Ms. Patti Ramsay at (612) 370-3212. Ne wish to thank Mr. Milton Dale for his cooperation duriagourv!sit. ve si c p yours, Thomas S. Feeney, Manager I—. MANAGEMENT REVIEW Public Sousing Agemcys Plymouth Rousing and Redevelopment Authority Project Embers P946-8170 Number of Unites 87 Period covered by this review July, 1987 through June, 1991 DEBCRIPTIOW OF REVIEW A Management Review of the Plymouth section. a Certificate Program was conducted by Patti Rannay and says P16till: of the Assisted sousing Management staff, Minneapolis/Bt. Paul Office, Is accordance with instructions contained in Randbooa 74.20.3, Chapter S. The review consisted of an inspection of tenant Man. A review of management and financial records. A comparison of the operating policies and practiceu, and a discussion of program operations with the Authority staff. sTATUs OF PRRVIODs REVIEW AnD OCCUPANCY AUDIT The findings from the previous review were closed based on your agencies response. Presently, there are two employees that administer the Section 8 program. Between the two there is 700 of a position. It is avident by our review that sufficient time is not spent in the administration of your program. This is due to either staff time charged to the program but not actually worked, or the need for additional training. The time allocated to the program is sufficient to administer the 87 Certificates currently nudes the ACC if it is properly utilised and the staff is knowledgeable of the program. Our staff is available to provide training for new or current employees. LEASING Status The following summarises the PRA's leasing status at the time of our reviews IBR XMM 3sR Total units Authorised 17 67 3 units Leased 17 66 3 Certificate Outstanding 0 1 0 Waiting List Unable to Determine Detailed findings, Corrective Actions and sea caneadatieas It is obvious that pour authority is aware of the high rents within the city of Plymouth since exception cents were applied for in 1980, 1982 and 1984. Our office has not received or approved a request since 1184. federal regulations prohibit placing units under contract for which the gross rest (contract rest plus utilities) exceeds the fair market rent. (Reference 24 CPR 882.106) An agency may: (a) exceed the fair market rest by 100 for up to 200 of the units authorised under the Annual Contribut_oss Contract (ACC) (b) request authority from BOD to exceed the fair market rent up to 200 for a specific participant due to a hardship, (e) request authority from BOD to exceed the fair market rents up to 200 for all or a portion of the units under the'ACC. (Reference 24 CPR 882.106) Under no circumstance can a housing authority or BOD approve a gross rant over 200 of the applicable fair market rent. Corrective Action Reeuired To clear this finding the following steps most be takens 1. Compare the initial gross rent (contract rent plus utilities) for all participants on-tbe program with the fair market rent in effect at the beginning'of the contract period. 2. List nay units where the gross rout (contract rent plus utilities) exceeded the fair market rout and the percentage by which it is exceeded. 1. going the current fair :arket rents (effective October 1, 19901 eliminate any gait from the list where the torrent gross rant no longer exceeds the October 1, 1990 fair market rents. The above information must be submitted to our.office. Members of our staff will do a follow-up review and at that time determine the extent of penalty that will be charged to your authority's administrative foe. At this time your Authority is prohibited from exceeding the fair market rents on any new contracts until the number of exceptions are within the allowable level under federal regulations. 3 Flmdime 42 orence 24 CPR 092.209) Our review noted the following cameos 1) One applicant was placed in the •high priority file• but was not income eligible. 21 There were at least two applicants in the •bl9b priority• file that did not have a preference. 3) A tenant paying 75% of their income in sent received priority over one paying 509. An applicant must qualify as a family and fell within the applicable income limits in order to be placed on a waiting list. Applicants must be given a questionnaire to determine if they qualify for a preference. Regulations require housing autbor=ties to give preference to applicants who are displaced by government action or disaster, applicants living in substandard booming, or applicants paying in excess of 500 of their annual 99069 income for rent. These preferences must be in your Authority's Administrative Policy. Applications that weigh equal In preferences should be placed on the waiting list according to the date and time received. All applications upon receipt must be stamped with the date and time. Under no circumstances should an applicant without a preference be issued a certificate before one with a preference. Correetive Aetiem Beeaired Your agency must establish sit waiting lists, one for each bedroom also with a preference and one for each bedroom also without a preference. To comply with the above the following most be dose: 11 A determination of family eligibility and income eligibility most be made for all applicants currently on file. 2.) if any applicantis determined ineligible, a letter must be sent to the applicant stating the reason and informing them of their right to an informal hearing. A sample ineligible and eligible letter are included in the Board Chairman's copy (Attacbments 1 and 2) 3) Send a letter to all current eligible applicants on band to determine continued interest, you most include a federal preference questionnaire to determine whether any applicants qualify for a federal preference. A sample questionnaire is 3neluded with the Board Chairman's copy. (Attachment 3) 41 when a response is received from the interested applicants, families most be placed on the waiting list according to federal preference and date and time from the receipt of the original application. A sample waiting list is included with the Board Chairman's copy. (Attachment 4) The above procedure will be verified by our staff on a follow-up review. Please submit the completed two bedroom waiting list for our review. Pisdisa 83 Best Rrasosabiesess data is not adhered to. Your agency is not using Beat Reasonableness date to assure that rents for units assisted under the Section 8 program are reasonably related to rents charged in your jurisdiction for comparably equipped units. [(Reference Randbook 7420.7 and 24 CPR 062.106(b)) Cho faatiWe Action Reauired For each unit which a lease has been approved, your agency most certify and document that the contract rest is (1) reasonable in relation to rents currently being charged for comparable units is the private unassisted market, and (2) not in crews of rents currently being charged by the owner for comparable unassisted units. Corrective Acties Reauirod To determine the above, a survey scat be done of the rental market and should include each information ass unit location, unit type, unit mise, quality, bandieap accessibility, amenities, maintenance and gross rents. Information can also be obtained from the city or local real estate agents. Beat reasonableness must also be conducted aid documented when as owner increases the contract rent over tke amount previously charged. 4o clear this finding, please submit rent reasonableness documentation and certification for the Bert three new units placed under a lease. (Reference Bandbook 7420.7 Ch. 6) Fludi s •4 Quality Centro! inspections are not conducted. CFR 24 882.211 states, 'The FRA will inspect or cause to beinspectedeachdwellingonleasedtoaFamilyatleastanaually and at such other times as may be necessary to assure that the owner is meeting the obligation to maintain the unit in decent, safe and sanitary conditions and to provide the agreed upon utilities and other services.• (Repeat finding from 1987 Management Review) Corrective Action Reaaireel A procedure most be established for reviewing a sample of completed isspectioas. Reinspection by a supervisor of a random sample of five percent is required. (Reference 7420.7 Ch. 5) To clear this finding please submit copies of two recently completed quality control inspections. Finding •S Reasest for cease approval process is not Consistently followed, when a family finds a suitable unit it most submit a RDD 52517A (Request for Lease Approval) along with a copy of the proposed lease agreement. It is the housing authority's responsibility to review the aequest and determine if the owner In eligible to part;.cipate in the program, if the unit is e'i7ible, and if the lease complies with program requirements including state and local laws). ?be information is also used as part of the rent reasonableness process. (Reference 24 CFR 882.209) Corrective Action Required Identify and list all tenant files t%at do not presentlyhaveaRequestforLeaseApproval. At the %Zt reeram a Request for Least Approval most be obtained from each tenant on the list and placed in the tenant's file. The above process will be verified by our staff on s follow- up review. Fi ds_s . Te,@ Otility Allowaace See,edule is not reviewed and ped_tee annually. Otility allowances Used for to ant files do net QCrrespoad rite, latest adopted sae,eduiea Section 882.214 of the regulation@ states that a public Rousing Authority must at least annually, review allowances for utilities and other services to determine whether there have been substantial changes and to correct errors is the prior year determinations. 6 Utility allowances must be kept currest to assure that the gross rest (contract rest plus utilities) does not exceed the applicable fait market rest. Most importantly, accurate utility allowances most be used in determining the total tenant payment portion of rest paid by tenant). The total tenant payment cannot exceed thirty percent of the family's monthly adjusted gross income. (Reference 24 CPR 813.107) Cesreetive Act iaa Reeuiraa A review of your agency's current utility and service schedule must be done and changes incorporated into a new schedule. When the above is complete, a review should be done of all tenant files and rents must be adjusted accordingly. If the result is an increase to the tenants rent, the rest should remain the same and the adjustment made at the next'reexam. If it In a decrease, the change should be made effective immediately and go retroactive to the last reexam. The above will be verified by our staff on a follow-up review.. Randbook 7420.7 Ch. 10) If based on the current information received at reasam the breakdown of rent paid by the housing authority and paid by the tenant changes, both the owner and tenant must be notified in writing with the effective date of the change. Corrective Actium Raeeired State law requires that a tenant be given a written thirty day notice prior to a rent increase. She only exceptions are for those given on Attachment S. in the future, reexaminations most be scheduled far enough In advance to allow for proper cost increase notification. A copy of the letter sent most be kept in the Venant•fiie. It is apparent= tpa: forty are xeroxed with the Rossing Manager's signature, !-qB iaspaction sbeets have also been xeroxed with check marks in the pass column. The inspectors comments are made on the last page rather than next to the applicable items. Racairad Cerreetiva Ration Although thin procedure may result in quicker processing of applications and BOB inspections, it is not acceptable. Original signatures substantiate that information contained on an application/inspection form is true and .accurate. For the proper procedure to follow when conducting BOB inspections refer to Bandbook 7420.7 Ch S and CFR 24 882.109.) 4o clear this finding please submit two fully completed 5O8 Inspections with original check marks, comments, and signatures. Fiadiac 6.9 ha mousing Rathesity is net eoadaetiasi tbezoach imtazwiars. when an applicant is interviewed, the interviewer should go over tke application line by line. Any additional Information received should be written on the application. An applicant is Pore likely to answer honestly when asked questions directly. in cases where there is a single parent with children, the question of whether or not child support is received most be asked. At interviews, as applicant must be asked if all income and assets are on the application. For example, a tenant with one child wrote on her initial application that she currently paid 0666 a mouth for rest plus utilities. she had gross income of 0910 per mouth. After the deductions from social security and income taxes, it is doubtful that the net spendable Income would be sufficient to meet basic household costs. There is so indication on the application that she had been specifically questioned an whether child support was not received or whether there was any additional income. Corrective Ration Recaised: A complete interview should be done at both the .a:t:ai interview and at the time of seexaa. wotes•shoaid be made on the application by the interviewer. (Examples 'Bo other income received.•) in the event that a tenant is unable to fill out the application due to a disability, the interviewer can fill out the application for the applicant. To clear this finding all required corrective action noted on the file findings must be followed and respoaded to. To aid in the interview process we've attached examples of an eppliieation, verification forms, and an interim seat adjustment form. (Attachments 6-11 of Board Chairman's copy) Piadina 610 The bemsiaa eathority bea.mot eabaittad as aadi! !er lieeei care endue Jame. Lies, Jmae. 1909 and Jaae. 1990 - in accordance with Handbook 7476.1 REV -1 and 24 CPB 44, •A PRA/IRA shall engage an iA (independent Auditor) within 90 days following the end of the period to be audited. The PHA most submit 12 copies to the NOD Office of inspector General within 30 working days of the completion of the audit, but so later then one year after the and of the audit period.• Cerreative Aetioe Reaaised Twelve copies of tbe.eudits for fiscal years ending Jane 30, 1988, June 30, 1989, and June 30, 1991 must be submitted to the BOD Office of inspector General we've attached Notice 91-20 which provides further informat and the address of where the audits are to be sent. (Attacbmeat 12 of the Board Chairman's copy) Recommendation #1 Your Authority's admission and administrative policies have not been updated since 1985. Since that time, the federal preferences were mandated and should have been incorporated into your policy. There are now eleven income exclusions and your policy lists nine. in addition, a number of definitions need updat:ag. Neve enclosed an attachment of the preference definitions and a format to follow when updating your administrative policy. (Attachments 13 and 14 of Board Cbairman's copy.) Please submit -copies to our office for our review. Recommendation 12 A certificate does not need to be issued at each reexam unless the tenant is moving to a new unit. Rleemmandatiea 63 A tenant does not have to sign a new lease each year at the anniversary date unions it is agreed upon by the tenant and owner, or the tenant moves to a new unit. The lease is closed during the first twelve months. After twelve months, the lease Is open ended and the tenant may move after giving proper notice 9 ; i to the owner. We've attached a sample lease and addendum to lease/BAP contract with the ebairman's copy. (Attachments 15 and Beasime 0selitv.etesderda 18081 Imseeetlons A total of five dwelling units were inspected. Overall, the rental units were in good cosditl.on. The following unit will have to be inseeeteds (There was noose at the unit vben our staff arrived at the scheduled time.) Catharine Erickson, 17605 19th Avenue Borth, 0110 Please submit a completed Bps inspection form for the above us: t . The following unit !ailed the B08 inaoeeL:ene Zile and Patricia Millar, 3145 Barber Lane Borth, 11-302 item -4.4 and 4.5 Window screen Ripped screen in Children's bedroom. Window !s floor level and is considered a health and safety risk. Please follow-up and submit documentation to clear. The fellewia to had no BOB violstlonaI Carla Answorth, 12105 41st Avenue Borth, #318 Melanie Bora, 3641 Lancaster Lane, 15-212 Cordon Lincoln, 9720 37th Place North, #103 Leslie O'Day, 1803 aivay 101 North, 0214 September 23, 1991 17; cbw coF Mr. Thomas T. Feeney, Manger PLTI' OM PIS—St. Paul Office, Region V U.S. Dept. of Housing i Urban Develop. 220 -2nd Street South Minneapolis, NN 55401-2196 SUBJECT: DEPARTMENT OF NOUSINB AND URBAN DEVELOPMENT MANAGEMENT REVIEW OF THESECTIONSEXISTINGPROGRAMFORPLYMOUTH, MINNESOTA - YOUR LETTER OFSEPTEMBER4, 1991 Dear Mr. Feeney: 1 received the executive director carbon copy of your September 4 letter onSeptemberS. 1991. Please be advised that Gerald- Nei Is As no longer the chairperson of the Housing and Redevelopment Authority. Mr. David Crain, 13200 -38th Avenue North, Plymouth, MN 55441 is now the chairman. I have provided Mr. Crain a comompplete copy of the 'Board Chairman's' material that hadbeenprovidedtoMr. Neils previously. I have directed Chuck Dillerud, Acting Director of Community Development to coordinate response and Compliance with the findings of your managementletter. Chuck Oillerud is Housing Specialist Milt Dale's supervisor. I have advised Mr. Dillerud that I consider compliance with and responses to yourfindingstobeatoppriorityitemfortheCommunityDevelopmentDepartmentandheisdirectedtoutilizewhateverresourcesofthedepartmentare necessary to promptly respond. Mr. Dillerud has informed we that in addition to the several findings that are responded to by this letter, he expects to provide responses and/or.bring our program into compliance with your findingswellbeforethe45 -day time period specified in your management letter. Those response compliance actions that we can offer to -date are as follows: I. Staffing Pattern - Presently there are several City employees involved intheamnsratonoftheSection8Program. The current services contract between the Housing and Redevelopment Authority and the City ofPlymouthprovidesfor12positionswithintheDeparleentofAdministrationComrmenitrenDevelopmt, Finance. and Public Works to assist in varyingdegreesinadministeringtheSection8Program. The sem of the contractedhoursis1,882, or 90 percent of a full-time equivalent annual position. The cost to the NRA for this service has annually exceeds the administrative fees provided by HUD for Section 8 Program administration. Through local levies the HRA has made up the difference. I am not certain of the source of your infOmation regarding only twopersonsonourstaffbeinginvolvedinadministeringSection8andthatthisrepresents70percentofaposition. It is true that the primaryadministrationoftheourSection $ activities is handled by two personsHousingSpecialistMiltDaleandaSeniorClerk/Typist), but the services 1- ' 3400 PLYMOUTH BOULEVARD. PLYMOUTH. MINNESOTA 55447. TELEPHONE (612) 550.5000 contract between the City and the HRA specifies that even these two would constitute 78 percent of a position annually. 2. Naitino List (Finding /21 - we have completely overhauled our waiting list procedures and formst to comply with the observations of the nnagement letter and themost current HUD rules in that regard. Since we have not opened our waiting list since June, 1990, we have requested confirmation of eligibility and Federal preferences from each Tamily on our current waiting list. Based on those responses, letters will be again be sent to the applicants who are found to be ineligible stating the reason and informing them of their right to an informal hearing. Also, those found to be eligible based on Federal preferences will be placed on the appropriatewaiting list based on the date of the receipt of the original application together with the local preference that has been established by the Housing and Redevelopment Authority (Plymouth residency or employment). No time of receipt of the original application wasnoted for applicants on our current waiting list. All future applicants for Section Swill be marked as to the specific time (as well as date) of receipt to establish waiting list ranking. As Attachment A please find a copy of our waiting list format including our current applicantsrior to confirmation of current eligibility and Federal preferences, buas e —on eligibility and Federal preferences claimed at the time of application (early Summer, 1990). As noted, this list will be updated within two weeks based on new deteroinations of eligibility and Federal preferences that have now been requested of all of these applicants. 3. Quality Control Inspections (Finding I41 - On Thursday, September 12, 1991 and September 17, 19YI, 019Tu ng Official Joe Ryan conducted quality control inspections on dwelling units previously inspected by Nr. Dale. The units were selected based on a random process undertaken by other staff members. The quality control inspection documentation is submitted as Attachment B. 4. Utility Allowance Schedule (Finding 06) - As Attachment C please find your letter dated July 18, 1991 where you haie approved our proposed annual utility schedule for the Section 8 Program. You indicate that you have reviewed the schedule for reasonableness and find it complies with the requirements of utility allowance regulations, 882.214. This schedule has been implemented and since it represents no change from the previously approved utility schedule no increa:e or decrease in gross rents will result. S. Notification of Chance in Housine Assistance Payment and Famil Contribution (Finding - AS AttachMan t 0 please find a phrase file letter that we nave crested that will advise both the tenant and the landlord of any changes in rents based on the current information received at a reexamine. This letter will be sent to both parties early enough in the reexamination period to assure receipt 30 days prior to the lease renewal date. 6. Z%riainal Signatures on HOS inspections and Other Forms 1Finding 06) - Our i:aff has discontinued use of forms that have been completet-a—nd--executed 2- In advance. All forms now used by Plymouth Mill have original markings and signatures. As Exhibit E please find two fully completed HQS inspections with original checkmarks, comments, and signatures. 7. Not Conductino Thorough Interviews (Finding 0 9) - I have directed the- ITous.ng p ai sift ecce ' Certain o con uc s interviews for both inapplications and reexamination in such a manner that each a.3 everr __question is specifically directed to the applicant and tTia fiery cle of information supplied byy the ap licant is included on the application as notes. He has indicated that has been his practice is the past. Our followups and responses to the file findings that were made are continuing and will be provided under separate cover. Thank you for the examples of applications, verification fords, and interim rent adjustment forms that were included with your "Board Chairman's Copy'. I have directed Nr. Dale to substitute these forms for those that we use in any case where they may differ. S. two separate addresses prams respective years as follow: Dale Mahn has advised me years noted were sent to ion of those audits in the HUD Office of Inspector General, National Review Center for Non-federal Audits, 950 North Kings Highway, Cherry Hill, New Jersey 08034-1518, and. U.S. Department of Housing and Urban Development. Chicago Regional Office. Region V. 547 West Jackson. Chicago. Illinois 60606-5160. I have directed the Finance Director to submit 12 additional copies of these fiscal year audits to the Cherry Hill, New Jersey address that appears in HUD Notice 91-28. 9. Housino Quality Standards 09S Inspections - Please find enclosed as Exhibit F a letter from Housing3pecial sf Flilt Dale to the manager of the building at 3145 Harbor Lane North regarding the torn window screen in Unit 1-302. 'We will advise you at such time as an inspection has been made to determine compliance Mith Mr. Dale's inspections. Determination of the degree of noncompliance of our program with current fair market rents and compliance of any given current contract with fair market rents at the timeof the original contract execution requires a file -by -tile audit that is currently underway. At the same time, as we are determining the matter that you had requested regarding compliance with fair market rents Finding /1), we are placing in each file.appropriate individualized certificate of rent reasonableness (Finding i3) and determining the status of the request for Lease Approval (Finding f5). We expect this file -by -tile audit to be completed within one week. At that time we will provide you with a summary of rents in comparison to FNR, both currently and at the time of the original contract consistent with the corrective action required for Finding /1. The survey of rental markets to establish rent reasonableness certificates has been completed as of this date. 3- Me are preparing amendments to our Admission and Administrative Policies responding to the Management Letter reca. endations,for adoption by the NRA Board of Commissioners at their regular meeting of October 17. 1991. Mr. Feeney, let me assure you that the City of Plymouth has taken your 1991 Management Review of our Section 8 Program very seriously. Corrective action was undertaken the day after your audit team departed (based on our verbal understandings of program problems at that time) and parties responsible or allowing our program procedures and process to fall short of Section 8 guidelines have been.reprimanded for their oversight. I can offer no excuses for the problems your management audit team found, only our pledge to overcame those problems and to maintain a Section 8 Program in Plymouth consistent with the applicable Federal Rules. Should you have any specific questions on these matters, please feel free to contact me at 550-5011 or Chuck Dillerud, Acting Community Development Director, at -550-5059. Sincerely yours, James G. Millis Cit• Manager hra/cd/feeney:jw) 4- D October 7, 1991 C (CX- Thomas T. Feeney,ManagerYMOV 1:fMinneapolis/St. Paul Office, i U.S. Dept. of (lousing 8 urbanDeDevelop m0 220 2nd St. S. Minneapolis, IN 55401-2195 SUBJECT: DEPARTMENT OF MOUSING AND URBAN DEVELOPMENT NANAGENENT REVIEM OF iNE SECTION 8 EXISTING PROGRAM FOR PLVIDUi1, 0 - YOUR LETTER OF SEPTEMBER 4, 1991 Bear Mr. Feeney: This letter is an additional response to your captioned letter of September 4, 1991, and a supplement to my letter of September 23, 1991 on the subject.. No have completed our file -by -file audit of the Section 8 Certificates administered by the City of Plymouth. Based on that audit we offer the following additional documentation and information in response to your Management Letter of September 4, 1991: 1. Gross Rents Exceeding FNR (Finding 01) We have audited our Section 8 Certificate files on a file -by -tile basis, and we have prepared tabular summaries regarding gross rents and FNR rents as follow: a. Attachment 1 is a tabular summary of •initial Gross Rants, Initial'FMR', •Initial Percent Over FMO, •Currant Gross Rent', 'October 1, 1990 FMO, .and, 'Percent Over October 1, 1990 FMR•. Attachment 1 also provides the Initial Contract Date and the most current lease renewal date. The attachment documents 86 of Plymouth's 87 Section 8 certificates. The 87th certificate was Oetwmen users at the time of the tabulation. b. Attachment 2 is a tabulation of certificates for which the Initial Year Gross Rant exceeded the Initial Year FMR. certificates that had an Initial Gross Rent equal to, or less than, the applicable FMR for that year have been deleted from this list. c. Attachment 3 is a tabulation of certificates where the Initial Gross Rent exceeded the Initial FMR end the Current Rant exceeds the FNR of October 1, 1990. d. Attachment 4 was not reested you but is provided for your information. Thiqus attachment s titutes the FNR for the aeon Pwmom eouLEw= PLVMDM. SUMMMOU SW7. TELEPHONE 0148504010 THE ADJACENT DOCUMENT WAS SUPPLIED BY AGENCY NAMED BELOW. DURING THE Metropolitan area offectlVe October 1, 1991 for the October 1, 1990 FM. and clearly displays the fact. that no Section 8 gross rents that currently exist exceed the October 1, 1991FM. indeed, many of the existino ratsts are significantly under the October 1, 1991 Fitt. 2. Reauest For Lease Aoaroval (Finding 051 Attachment 5 states whether the Request For Lease Approval was found In the certificate files. As you can see, the =Jerity of thecertificatefilesdidnotevidencetheRequestForLeaseApproval form. All subsequent certifications or recertification$ will result Ito Request For Lease Approvals being obtained, and placed in the appropriate file. 3. Rent Reasonableness Data (Finding 03) Following our file -by -file audit, this. wilt confirm placement. of Rent Reasonableness docueentation and a Rent Reasonableness Certificate in each Section 8 file. 4. Waitina List (Finding 02) We have completed our determination of eligibility and federal preferences for those families that were on our waiting lists as of the time of management tem review. Based an the responses received, all of our waiting lists have been updated. As Attachment 6 please .find the updated Two Bedroom Waiting lists as you had requested. We are continuing with our verifications and inquiries : .. -,-..g the filereviewsnotedinyourFinding09. As soon as those actLort. , complete, NO will submit those under separate cover. Should you have any questions concerning these or previously ;«trditted responses to the management review, please feel free to contact em 550-15M or Chuck Oillerod, Acting Camunity Development Director at 550-5030. Sincerely yours, J s 6. Willis Cit Manager Attachments hra/cd/feeney.2sdh) r 18, 1991 Thomas Feeney HUD Area Office 22D South 2nd Street Minneapolis, NN 55401 SMUECTs DEPARTMENT OF MOUSING AND URBAN DEVELOPNENT NANAGOI NT REVIEW OF TNE. SECTION 8 EXISTING PROGAM FOR PLYMOUTH, MN - YOUR LETTER. OF SEPTMER 4, 1991 Dear Nr. Feeney: This letter is an additional response to your captioned letter oftuber 4, 1991., and a supplement to ,Y letter of September 23, 1991 on the subject. We have completed our file reviews as noted in the File Review summery sheets pales 1-4 as part of the Section 8 Certificates administered by the City ofPlymouth. Based on that audit we offer the following additional documentation and information in response to your Management Letter of September 4, 1991: I. File Review Summery Sheets, pages 1-4 We have completed the column PRA Response. Letters with verification forms have all been wiled to app ropr a e persons. All verification forms have not been returned at this time. 2. Attachments to File Review Summary Sheets a. Erik and Patricia Miller III Rent Reasonableness Documentation 2 Utility Allowance Schedule 3 Cop of ilorksheet 8 6/27/91 Notification 4 lA/14/91 Letter to Nillers b. Catherine Eckerson 1 10/14/91 Letter to Eckerson 2 Rent Reasonableness Documentation 31 Copy of Norksheet c. Leslie O'Day 1311 CopyofWorks= 2 RentReasonableness Documentation Utility Allowance Schedule d. Gordon Lincoln 1 Rent Reasonableness Documentation 2 Coopp r of Norksheet 3 Utility Anasarca Schedule 340 PLYMOtiTM BOULEVARD. PLYMOM MONFA fA 15W. TELEPHONE (612) MIN= e. Melanie Norn 1 10/14/91 Letter to Norn 2 Rent Reasonableness Documentation 3 Copy of Morksheet f. Carla Ainsworth 1 Rent Ih:asonableness Docusaotation 2 .10/14/91 Letter to Ainsworth 3 Copy of Worksheet It is our belief with your receipt of these items, our response to the No 91.1 t findings have been completed. 1: is our intention to continue close contact with Patti Nannay to Improve. the quality of our magesent of the Section 8 Program. Me also wish to avail ourselves of training sessions sponsored by the MUD office. Plaase keep usWormedofsuchtrainingopportunities. Should sroteumttilsng lereootatiis IMIPOnsetohsareview,peae feel free tcntactetS5SOI1 or Chuck Dillerud, Acting Community Development Director at SSD-SOSg. Sincerely. L J s 6. Millis Executive Director/City Manager osures hra/md/feensysdh) Wert9 v t Nov 14 1911 CITY OF PLYMOUTH oo1(w.m+1(t oe r. Hr. David Craia, Chairperson nousims and Redevelopment Authority of Plymouth 132'00 Uth Aveaje .worth Flymeutb, Minnesota S5441 Pear lira. Craiae Sub4cate Status of Beetles 8 Managausat Review Thank YOU fat Four lettere dated deptember 23. 1991, October 7, 1991, and October 18, 1991, is which you responded to the Beetles 8 Hanageaest Review report.. We appreciate your tlmeiiveaa An respondiag. in addition, we appreciate the excellent job your agency has dome is impieaeatlag the seQuired corrective actions outlined is out report. Daaed oa the responses we received to the above letters, we have cleared Fiadaags 1S, 18, 010 and the RQB inspection. Clearance of Finding It is pend ag until our Follow-up review. At that tine be assessment of the penalty can be determined. Hb have reviewed Fair response to Finding 19. We will be so - reviewing this ase& at our tallow -up visit and a determination will be male .at that tine. e ase aware that updating an Administrative plea takes a substantial sanest of time, we will review the policy when it is subr.itted and respond to it separate Crew the review glad -ago. 110 have also cleared Fiadings 12, 11, 14, 14, and 47 with the following oerrents- and/or recommeadatiesse liadiae •2 In addition to the applicant iaformation esrrently listed ea your waiting list, a number of ether Items must be tracked. We've ettacbed & sample Section 8 waitieg list for Your refereace. Attachment A) 2 A Column should be 44604 to allow for an applicant's sane aad' ethaioity. This gives your authority and our.agency a quick system for verifying that all applicants are selected equitably.- Ton oust also track, either on your surrest waiting list or on another list. the date and season why an applicant bas been withdrawn, datermised ineligible, or Moved ter or down eo the waiting list$. When applicants are issued a Certificate, a date should be entered. adiag •! As was recently discussed with Ns. Niit Dale, the only comparable matte are those buildings that currently hoose Booties 0 participants. The mower omits to plymoutb have seats which exceed the Mae. when gathering rest reasonableness date, be mase that it is for unassisted malts in the buildings. nadisg f4 Tess agency most maintain a file of ongoing 4gality central Inspections in aeeor4anee with the section B !misting NodsLeg Inspection Manna&, page 41, and Nandboek 7420.1, Chapter S. risOise /6 Toss revised utility allowance sobedule was received and - approved shortly after ear.on-site review. No were also Concerned . that tenant files did not contain a eery of the utility schedule and a number of files did not use 1o. the latest adopted sobodulep Finding of we strongly recommend the Goo' of our sample Lease/Contract addendum form to notify families and owners of the change is rest distribution. (Attachment of The staffing •data used to ;determine 701 of, a•full .time position administering the Bentsen 0 . program, was . A.41sed'' -os Information given to us at the time of our review•:. Noosing• ipeoiai:at: .: %550 Br. .Click Typist, - al 700. The September 23. 19910 resposse letter.we received rased a concern by your agency that the administrative ties provided -by a00 did not meet the actual. Booties 4 adnislstrative seats Cos 'year agency. .. •• •.. • . a IN reviewing your sear sad sea,UNests for lens ao, 19916 asOperatingReservebalasc• •E 196,169 to above. theOperatingReserve &vacant is the account that is Gr•dited •itb Gass•¢ adsieistrat loos that Osgood ssP•sditure• fes Fragra a4aleistsatiesea. •,% Fos4e09 .Tose 30, 1991, Else&& year ssd, less' agency Sassed943,251 to oagolag admiaiatratl.ve goes, of that, g2a.a94',wasactuallyspent. :a summary, year agency was .abletoyouroperatiagreserve.. foe Nasal •!ead 112,470add 80, 2990., 013.790 was a4de4.to yoos •peratln¢ yeas nd:ng reserve asset&%• Our records ladivate that administrative less.Provided bt Rhasectionaprogramhaveexceededactualwents••i"a fiscal year024189Sun* 20..190l. a feller-tp rOvicv has base scheduled Eos. soadiy, November 1d, 1991.. Ms. Patti !assay and Os- Bays Pistilli will arrive at youreEficeapprosiateiy •goo a.. Please have allperilaestInformationavailableatthatties. we @as be of any aa&is%gacBanner09thePublicBossingDiviles a! 37A721;etast Na. Putti Very slaeevely years, lhoaas !. Feeney, sanager S-9FR SO Mgat Re.iew File Voweentive Director S.9FB Reader 5-98Ma,8assay,bae.:il/14/91 BMa.IBaBBas 882L00 IAi @@Poo a ormum 8 and 18hea OaaM/swd Yosy Ba, NWANO mal4 m Ms. David Crain, Chairmen [ NEr ! EVED Bossiag and Radevelopeent Authority Of Plymouth 3400 Plymouth Boulevard SAM SS 02 Plymouth, Minnesota 55441 DeMr. Cruise OCOW mny ITY OF Pm `manDow Subjects section 8 Managemout Follow-up Review This Is to summarise the follow-up review conducted by our office on November 18, 1991, by Ma. Patti Rainey and No. Raye Pistilli, and to report the status of the section Management Review issued on September 48 1991. In response to our section s Management Review we received three thorough response letters from Mr. James G. Willis, Plymouth City Manager, defining what ectiow your agency was taking to clear the reported findings. Based on those throe letters we were able to clear eight of the ten findings. in order for us to clear the remaining two, we conducted a follow-up review. At the follow-up review, our staff examined the same six tenant files from the original review, Liles of three now certificate holders, and three recertification that were completed after our initial review in June. unfortunately, in carrying out our follow-up review, we noted little Improvement in the area of tenant files. We've prepared tenant file review sheets which summarise the file findings noted at our review follow-up. Attachment A are the findings that remain open from the six tenant files In our first review and some additional items that may not have been addressed in our original report. Attachment B are findings noted on recent lease -ups. Attachment C are the findings noted as recent recertification. Please respond to each tenant file finding and explain all steps that will be taken to ensure future compliance. Finding 69 will remain open until we are able to visit your agency a third time to follow-up on the file findings above. We anticipate a day sometime this spring. a our letter to your agency dated November 14, 1991, w Gloated the 508 finding based on a copy of a letter sent to the apartment manager at Harbor Lase Apartments. The unit of Eric and Patricia Miller, 2145 Barbor Lan North, 41- 302, had failed the 898 inspection due to a torn screen in the children's bedroom. The rindw is floor level and is considered a safety risk. At the time of oar follow-up review there was no indication in the file that the window bad been repaired. she only letter on file was the same one seat to our of fleet which is dated September 19, 1991, and allows a repair time of 10 days. this finding is considered reopened until documentation Is submitted to our office which clearly shows that the unit has been reinspected to verify the completion of the work. In our original report we requested that a (lousing Quality Standard (BOB) Inspection be done at 17605 19th Avenue North, 0110. Tbis suit was to be Inspected at the time of our original review but the tenant was not at base when our staff arrived at the scheduled time. To date, we have not received a copy of the Inspection. Clore-out meetings were held following both the original swi.w and follow- up ollowupreview. At those meetings, discussions were bold regarding the sanction that would be assessed against your authority's administrative reserve. The basis for the Proposed genetics was a result of your agency eontraetisg for mite with gross rents in excess of the fair market rent in effect at the time of lease up. Please refer to Finding 09 of your Section S Management Review report dated September 4, 1991.) We have since decided to forgo the sanction. This is In rest Part, due to your prompt response to our initial report, and the immediate attention given to implementing our required actions. Nowever, should this practice continue, we will require a reimbursement to your housing assistance psyments account, or administrative fees for soy unit+ in excess of the twenty percent allowable under program regulations viii be withheld. In your September 23, 1991, response letter and at the closeout meeting held at the follow-up review in November, our staff was tatosmed that your agenoy did Dot have the $96,169 operating reserve that was reported on your year and financial statements for June 30, 1991. At the folies-up closeout mus staff was informed that the financial director would be reviewing the financial records to determine if the year en!' statement is correct. We have not received word as to the result of his/her findings. Please provide us with your findings in your next response. We were very pleased that Mr. Milt Dale and Me. Demme Nutt were able to attend s training session with Ms. Patti Naaoay of our Public Rousing Division. The session Mao hold .00 December 6, 1991" following out secoDd visit to your office. We are confident that the session vas beneficial to our office as well as your staff, and will aid in resolving the recurring problems with tenant files. We also encourage both Mr. Dale and Ms. Nutt to attend our statewide training sessions coming up in April. to the interim, please encourage than to contact our office with any questions that may arise. In summary, findings 01 and 19 Cousin open. To clear finding $i please submit an "planation of the process that' will be used to track the twenty percent exceptions. To clods finding 09 please respond to the tenant file findings listed os attachments At Be and C. We are requesting that the unit located at 3145 anchor Lane Worth, 11-305 be reinspected and unit 17605 19th 1lvonae Worth, 0110 be !aspected. In addition, we are requesting that you infosn es on the status of your search in locating the $96,169, which should be in your section a Operating Reserve as of June 30, 1991. If you have any questions, planes contact Pa. Patti Sammy of the Public Running Division at 370-3212. Very sincerely yours, s T. Posner, Rsueges February 12, 1992 r; cnv)c)(- Wom Thomas T. Feeney NUD Area Office 220 S. 2nd St. Minneapolis, MN 55401-2195 SUBJECT: DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT MANAGEMENT REVIEW OF THE SECTION 8 EXISTING PROGRAM FOR PLYMOUTH, MINNESOTA - YOUR LETTER OF JANUARY 29, 1992 Dear Mr. Feeney: In response to your Section 8 Management follow-up review we have summarized below the actions we have taken to clear findings 11 and 09. We are also reporting on the status of the $96,169 in our Section 8 Operating Reserve; and, the file findings as per the file review summary sheet attached. 1. Response to the Items Noted in Your Letter of January 27. 1992. Recently, the Housing Authority purchased Nan McKay software to generate a variety of reports and documents. This software will allow 'us to track 20% exception rents as needed. All tenant data should be located on the system by February 17, 1992. The Executive Director of the Housing Authority now requires that any request for exception rent be cleared througli'-ilis office prior to approval. Since the date of HUD's initial Management Review in June, 1991, no exceptich rents have been approved. Inspection of Two Units Noted in Your Letter. An inspection was.made of Apartment 1-305, 3145 Harbor Lahe North on December 29, 1991. A copy of that inspection booklet is attached. All screens were sound at the time of that inspection, An inspection will be made at 17605 19th Avenue North 0110. We are scheduling that inspection for February 13, 1992. A copy of that inspection report will be mailed to you at a later date. 3. Section 8 Operatino Reserve The City Finance Director has located the amount of $96,169 in the City's account for the Section 8 Operating Reserve. 4. File Review Summary Sheets We have indicated our initial response on the attachment of the File Review Summary Sheet. We intend to follow-up on all findings and make necessary corrections within 30 days. 3400 PLYMOUTH BOULEVARD.. PLYMOUTH. MINNESOTA 55447. TELEPHONE (612) 550-5000 Thomas Feeney Page 2 Our new Nan. McKay Section 8 processing software has been loaded and two of our staff have been trained on a.portion of the program. Data entry will soon be complete. making the system operational.. ikcordkeeping•should thereafter be more efficient. He wish to express our apppreci•_ti"on for the assistance that has been given us by Patti Uhnnay in providing special training and also in her willingness to help us regarding our various questions. Sincerely, ba-0- Nz_ milt Dale Housing Specialist hra/md/hud:dh) April b. 1992 UCIN OF . PIYMOM Thomas T. Feeney NUO Area Office 220 S. 2nd St. Minneapolis, MN 55401-2195 SUBJECT: DEPARTMENT OF MOUSING AND URBAN DEVELOPMENT MANAGEMENT REVIEW OF THE SECTION 8 EXISTING PROGRAM FOR PLYMOUTH. MINNESOTA - YOUR LETTER OF JANUARY 29, 1992 AND OUR FOLLOW-UP ON SEVERAL ISSUES Obar Mr. Feeney: In response to your Section 8 Management follow-up review we have followed-up on our earlier actions and believe we have responded to all file findings. Enclosed you will find a memo with attachments detailing our response. We wish to express our appreciation for your staff's patience and help in seeing us through this process. Sincerely. f 'lf-,- Milt Dale Housing Specialist hra/md/hud:dh) 34M PLYMOUTH BOULEVARD. PLYMOUTH. MNNEBOTA 65447. TELEPHONE 012) MSM 4. MEMO CITY OF PLYMOUTH 3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA 55447 DATE: April 10, 1992 TO: HRA Board of ommissioners FROM: Charles E. rud, Executive Director SUBJECT: ATTORNEY OPINIONS REGARDING SENIOR HOUSING Attached please find three opinions of the City Attorney/NRA Attorney regarding senior housing for Plymouth, as follow: 1. Opinion dated March 20, 1992 regarding general authority of the HRAandtheCitywithregardtotheseniorsproject.. 2. Opinion dated April 3, 1992 to the HRA regarding mandatory age, Income and residency preference issues. 3. Opinion to .the NRA dated April 9, 1992 regarding public versus private ownership of a senior project. In addition to these attorney opinions, Dan Nelson of the MRA's law firm Best and Flanagan will be in attendance at our meeting of April 16, 1992 to assist the HRA with any other questions that may be raised regarding these topics. Dan has had substantial experience in HRA housing matters. hra/cd/board) I.. 04-10-1992 12:47 339 5897 BESTUFLANAam P.05 MENORANDUN TO: PLYMOUTH CITY MANAGER AND CITY COUNCIL FROM: PLYMOUTH CITY ATTORNEY DATE: March 20, 1992 RS: City of Plymouth/MRA: Seniors, Program Introduction The Plymouth Housing and Redevelopment Authority (the HRA") is exploring the development of 8 -housing development project for senior citizens (the "Project" or "Seniors' Project"). Should the Project prove feasible, the HRA may propose Project financing in the form of revenue bonds supplemented by a property tax levy to meet the debt service coverage requirements. We have been askedto review the relationship between the HRA and the Council to ascertain whether the HRA is authorized to sell bonds and levy property taxes without Council approval. Nothing in the Plymouth Code or the HRA bylaws addresses these concerns. Short Answer i. Bond Issuance: Although the HRA has broad authority to issue bonds without City Council approval, it must 04-10-1992 12:47 339 5897 6EMPLANAGm p,08 receive Metropolitan Council and Minnesota Housing Finance Agency approval of the Seniors' Project before it can issue bonds to finance the Project. Further, the HRA must consider the negative political ramifications of issuing bonds and implementing the Project without City Council input or approval. 2. Property Tax Levy. The HRA cannot levy property taxes without City Council approval. Diseusslon The HRA receives Its powers from Minnesota Statutes Sections 469.001 to 469.047 (the "Act"). The HRA has "all the powers necessary or convenient to carry out the purposes of (the Act), except that the power to levy and collect taxes or -special assessments is limited to the power provided in sections 469.027 to 469.033." Minn. Stat. § 409.012. These sections, in part, authorize methods by which the HRA may finance projects such as the Seniors• Project, including bond issuance and property tax levy. fe Minn. Stat. S 469.033, subd. 3, 6. Bond Issuance Before it can issue any bonds for a housing development project, (assuming that a comprehensive housing plan already exists in Plymouth), the HRA must prepare a "program" and submit it to both the Metropolitan Council and the Minnesota Housing 2- 04-10-1992 12:47 339 5897 BESTC:FLANA M P.07 Finance Agency for review. See Minn. Stat. S 469.0171. A "program" is defined as "an individual component of the housing plan for which one or more issues of revenue bonds or obligations is proposed." Minn. Stat. S 462C.02, subd. 2. The Seniors' Project fits under this definition. The manner in which the NRA must submit the program for review by the Metropolitan Council and the Minnesota Housing Finance Agency is described in Minnesota Statutes Sections 462C.04, subd. 2 and -462C.05. subd. 5. The statutes do not specifically require City Council approval for bond issuance. ProoertX Tax Levy The NRA isnot authorized to levy property taxes without City Council approval. The governing statute is self-explanatory: All of the territory included within the area of operation of (the HRA) -shall constitute a taxing district for the purposes of levying and collecting special benefit taxes as provided in this subdivision. . . . Sub-ect to the consent 3- 04-10-1992 12:48 339 5897 SESTufLANAG M p,OB market value to a used to eEra costs of rovid n i f rmetional sery ce and.reloca ion assistance as set.forth In section 469.012, subd. 1. Theamount of the tax.levv for the following ear hell be based on that bud et and shall be approved by the KC2,ungill. Minn. Stat. S 469.033, subd. 6 (emphasis added). Conclusion Although the HAA has broad authority to develop, finance and manage its projects, it must observe statutory program approval guidelines prior to bond issuance and must receive City Council approval .prior to property tax levy. Because the Seniors' Project is a discrete program within Plymouth's comprehensive housing plan, no City Council approval of the program or bond issuance is required. The HRA must, however, receive Metropolitan Council and MHFA approval before it can issue bonds for the Project. 4- 04-10-1592 12:45 339 5897 BESTULANAMY p;O2 MEXORANDUM TO: Plymouth HFA FROM: City Attorney DATE: April 3, 1992 RE: Seniors• project Ace., Income and Residency Issues Issues 1. Can the City of Plymouth Housing and Redevelopment Authority ("HRA') impose age, income and durational residency requirements on admission into its proposed senior housing project (the Project')? 2. Would statutory limits on age, income and residency differ if the Project were privately owned? Short Answers 1. Within statutory limits, the HRA may restrict entrance into the Project based on age, income and residency requirements; however, it may not impose durational residency requirements. 2. Projects funded by private activity bonds are subject to many of the same restrictions to which publicly funded projects are subject. In addition, pursuant to various tax and housing laws, these projects are generally considered no longer feasible for private developers to undertake. Discussion Age The Plymouth HRA may impose age restrictions upon Project applicants. The federal Fair Housing Act and the Minnesota Human Rights Act do not prohibit discrimination based on age in the sale or rental of housing. Under both statutes. housing for older persons" is defined, in relevant part, as housing "intended for, and solely occupied by, persons 62 years of age or older. . ." or "person[a] 55 years of age or older . provided that [enumerated services and facilities are provided to the residents)." 92 U.S.C. 3607; Minn. Stat. S 363.02, subd. 2. 04-10-1992 12:46 339 5897 BESTOFLANAGAN P.03 Income The HRA may impose income limitations on Project applicants. Minnesota Statutes provide the following guidelines for housing development projects such as the HRAs proposed Project: within its area of operation, (the HRA is authorized) to determine the level of income constituting low or moderate family income. The HRA) may establish various income levels for various family sizes. In making its determination, the (HRA) may consider income levels that may be established by the Department of Housing and Urban Development -or a similar or successor federal agency for the purpose of federal loan guarantees or subsidies for persons of low or moderate income. The (HRA) may use that determination as a basis for the maximum amount of income for admissions to housing development projects or housing projects owned or operated byit. Minn. Stat. § 469.012, subd. S. Alternatively, Plymouth may wish to refrain from imposing any income limitations upon Project applicants. This action would be appropriate pursuant to Minnesota Statutes which impose no income limits upon elderly housingdevelopmentprojects. bee Minn. Stat. S 462C.05, subd. 4. Residency Although the HRA may impose a minimal residency preference upon Project applicants, it cannot impose a durational requirement. In other words, the NRA may give qualified Plymouth applicants who are residents priority for entrance into the Project, but it cannot give preference to a tan -year resident over a one-month resident. By analogy to laws governing "housing projects" which, pursuant to statute, are targeted at low income individuals), the HRA is subject to the following guidelines in relation to its "housing development project" (which, pursuant to statute, is targeted at moderate income individuals): As between applicants equally in need and eligible for occupany of a dwelling and at the rent involved, preference shall be given to families of service persons who died in service and to families of veterans. In admitting families of 2- 04-10-1992 12:46 339 5897 BEBTAFLANA6AN P.04 low ncome to dwellino accommodations in an housing protect the HRA1 shall as!ar a is reasons roct le iv cons der tion t s licat ons trom . res den Elm 1 es to - whom pubi c as iisstance_or_ouvplemental security IncoiFe for the aged, blind d disabled is payable, when those [amilie¢ anareotherwiseeliglible. Minn. Stat. S 469.021 (emphasis added). An important concern is whether ttiy residency preference will result in a diacriminatory effect in relation to one of the "protected" categories. For example, if the preference resulted in racial, religious or gender discrimination, it would run afoul of constitutional protections. See e.g. United States. v. Housing Authogity of the City of Chckasaw, 504 F. Supp. 716 (1980); Shapiro v. Thomason, 394 U.S. 616. 89 S. Ct. 1322 (1969).. ?his would be true whether the Project were publicly or privately owned. The HRA is subject to the following statutory guidelines: There shall be no discrimination in the selection of tenants because of race or religious, political, or other affiliations, but if the number of qualified applicants for dwelling accommodations exceeds the dwelling units available, cefer nca shall i -en to inhabitants Qf the municipal ty in which the project_ is located, and to the families who occupied the dwellings eliminated by demolition, condemnation, and effective closing as part of the project, as far as is reasonably practicable without discrimination against families living in other substandard areas within the same municipality. Minn. Stat. S 469.020 (emphasis added). Conclusion The HRA can impose age and income requirements within statutory guidelines. Mindful of potential problems related to discriminatory effect, the HRA can implement residency preferences, so long as no durational limitation is imposed. 3- 04-10-1992 11:04 339 5897 BE5TDFLANAGAN P.03 I. MEMORANDUM TO: Plymouth Housing and Redevelopment Authority FROM: City Attorney DATE: April 9, 1992 RE: Plymouth Senior Housing Project You have asked us to outline the various structuring options available to the Plymouth Housing and Redevelopment Authority (the "Authority") for the development of a proposed senior apartment project (the "Project") in the City of Plymouth the "City"). This memorandum is intended to outline the various aspects, both advantageous and detrimental, of three different structures which the Authority should consider in its determination of the development and financing structure of this Project. These three structures can be summarized as: 1. full ownership by the Authority; 2. ownership by a public/private partnership formed by the Authority and a private developer; and 3. ownership by s private developer with assistance from the City and the Authority. 1. Full Ownership .the Authority. Under this structure the Project would be undertaken by the Authority as a "housing development project" under Minn. Stat. $§ 469.002, subd. 12 and 469.017, as described in our earlier memoranda to you dated March 20, 1992 and April 2., 1992. The Project would be financed by the Authority through the issuance of tax exempt essential. function bonds, which would require that no non-governmental entity can have any interest in the Project. This would not, however, prevent the Authority from entering into service contracts with various development and property management professionals to do the work necessary for the development and 04-10-1992 11:05 339 5897 9ESUFLANAGM p,O4 operation of the project which is beyond the Authority's current staffing and technical capacity. Because of the advantages described below this structure is likely to produce the highest quality housing at the lowest possible rents, but would require the greatest involvement by the Authority over the term of the financing. A. Advantages Pull control of all development and management decisions by the Authority; ii. Tax exempt bonds are available without an allocation of bonding authority from the State and without two percent limitation on costs of issuance which can be financed from bond proceeds; iii. Income limits and tenant eligibility are set by Authority, not federal or State requirements; iv. Project makes payments in lieu of property taxes equal to five percent of shelter rents rather than full property taxes; V. Exception from public bidding requirements under Minn. Stat. 469.015, subd. 4 would allow Authority to fix construction costs early in development process (see proposed legislation, H.F. 2965); vi. Sales tax exemption on building materials could provide significant cost savings (but proposed legislation Will likely remove this exemption); and vii. No profit motive or return on investment is required so Authority can keep cents as low as possible. B. Disadvantages: i. Authority will be fully responsible for Project operations and bond debt service for full term of the bonds; ii. pledge of City levy to support debt service on the bonds will likely be required to successfully market the bonds; 2- 04-10-1992 11:05 339 5097 eESTSFLANAGMI iii. Authority will be "at risk" for construction cost overruns, initial lease -up of Project and potential future operating losses; and iv. No outside equity investments can be raised in ezchange for an interest in the Project. P.05 2. QXnershig Ora Public/Privets Partnershi . As an intermediate alternative the Authority may consider forming a limited partnership to act as the developer of the Project with the Authority acting as general partner and syndicating the limited partnership interest in ::rder to raise additional equity for use in the Project. This additional equity source could be used to reduce the City's and Authority's contributions to the Project or to keep debt service and rents as low as possible. The Authority's participation in this partnership is authorized by the some statutory provisions described above, and as general partner the Authority would have a large degree of control over the development and operation of the Project. However, the involvement of non-governmental limited partners would eliminate the availability of essential function bonds and private activity bond financing is not generally available for senior projects. This structure would protect the Authority by passing the development's risks onto the limited partnership, but would force the Project into conventional financing and operating requirements. Even with the Project ownership being one step removed from the Authority, you should also consider the practical and political question of whether the Authority would still be called upon to cure any problems with the Project in order to satisfy residents and avoid a potential loss of the Project in an event of default, even though the Authority would have.no legal obligation to.do so. A. Advantages' I, Authority can retain a large measure of control over the development and management. of the Project, subject to terms of the partnership agreement; ii. Equity raised from limited partners is an additional source of funds; 3- 04-10-1992 11:06 339 5697 eE5TUFLANAGAN p.06 lit. Partnership structure would remove Authority [rom direct responsibility for consttuction, lease -up and operating risks; and _ iv. Bidding laws do not apply. B. Disadvantages: I. Tax exempt financing not available without on allocation of State bonding authority, which is not generally available for senior projects without change in State law !see Minn. Stat. 474A.07); it. TE bonds are used, federal income limits would apply; iii. Project pays full property taxes although tax increment financing may be available to return some of those taxes to the Project); iv. Project would likely still require some form of City pledge to make bonds marketable; and V. Limited partners would require market rate return on their investment, which would raise rents. Private Ownership with Authority Assistance. The Authority would have the least risk in the development of this Project if it could find a private developer to construct and operate the Project for the purposes desired by the Authority in exchange for an initial contribution from the City and the Authority of the land for the Project and an ongoing contribution through tax -increment financing. We understand, however, that this option hes been pursued by the Authority for some time without a satisfactory response from the private development community. without going into a more detailed list of the advantages and disadvantages which the Authority and City are well aware of, it is sufficient to note that this structure results in the least exposure to the Authority and could result in a a Project meeting all of the Authority's policy goals. However, given the private development market and the extent of the public subsidies which would be required to make a privately -owned project 4- 04-20-1992.11:08 339 5897 OF5MFLANAGM P. 07 feasible, it is understandable that the Authority would conclude that its investment in such a development would be too large in eschang r the limited return to the City, and that the ty's interests would be better served by the Authority taking a more direct and active role in the ownership and operation development of this Project as described above. If you have any additional questions regarding this Project or the structures described above, please feel free to call us. DRN : Mr 0019v 5- 5• MEND CITY OF PLYMOUTH 3400 PLYMOUTH BOULEVARD., PLYMOUTH, MINNESOTA 55447 DATE: April 1, 1992 for Housing and Redevelopment Authority Meeting ofApril16, 1992 TO: Charles E. Dillerud, Executive Director FRQi: Housing Specialist Milt Dale *VZ— SUBJECT: SCATTERED SITE HOMEOWNERSHIP PROGRAM - REVIEW OF PLANS 2.AND 3 ACTION REQUESTED: Information and status report on this program. BACI06ROUH0: In January of 1992, the City of Plymouth entered into a contract with Thibault Associates to develop several mode', plans for a Scattered Site Homeownership Program in Plymouth. At last month's meeting the Model Planfor1992wasdescribed. Thisplan is now in use, but likely will not befeasibleafterOctober1, 1992 due to HUD rules changes. Part of Mr. Thibault's charge was to provide the City '•h two more Scattered Site Homeownership plans to be used after Octobe "hese plans have been prepared along with a comparative matrix shoe.._ .e Plymouth Program Plan of 1991 and the three model plans. PRIMARY ISSUES AND ANALYSIS: For comparative purposes, refer to the matrix developed by the consultantwhichisanattachmenttothismemorandum. The primary issues to consider relate to funding in Model Plan 2 and the method of using a "double closingvInModelPlan3. Attached are the consultant's model Plan 2 pages 1, 2, and 3 and Model Plan 3 pages 1 and 2. In the case of Model Plan 2, the City/HRA would use either Section 8 reserves and/ora HRA tax levy to fund the activity. In future years, the City/NRA should also be recovering monies returned when current first time homebuyers resell their houses. According to Real Estate industry statistics, the average first time home buyer sells his/her house within 5 to 7 years after purchase. Since the City has.a 20 year repayment agreement with the first'10 years requiring a full repayment and the second 10 years a decreasing percentage repayment, there is a strong likelihood of return of significant funds. This would likely not materialize, however until 1997 and beyond. Model Plan 3 depends on the use of a "double closing" with the City/HRA taking title of the property for a matter of minutes and then reselling it to an eligible participant. By utilizing this method, the use of COBS funds Is legitimized. True, this ma sound like HUD "double -s ak" but we have been given assurance by HUD Staff that it is within HUD guidelines. Consultant's schedule for both Model Plan 2 and 3 would require taking applications in January of 1993. Due to the considerable number of applications we received during the last two weeks, those persons that are not selected in the drawing will be informed that they are put on a "waiting list" similar to that for Section B. Further, we will inform them that in January of 1993 we will consider initiating the Scattered Site Home Ownership Program again. He may need to do some modifying to either Model Plan 2 or 3 based on our experience that we will gain in the next 3 to 4 months with Model Plan 1. CONCLUSIONS AN RECON1101DATIONS: It is my raccomendation that we continue on schedule with the Model Plan I program and bring the..matter of utilization of either Plan 2 or 3 before the Housing Authority in October of 1992. At that time, I believe we will be better able to recommend either Plan 2 or 3 for use in 1993. ATTACHMENTS: 1. Comparative Matrix for Plymouth Scattered Site Homeownership Program. 2. General Description of Model Plans 2 and 3. 3. Booklet Containing Entire Outline of Model Plans 1, 2, and 3. hra/md/4-16) CITY alp PLYi00li NCs't'i'iaiD illi IV PLs>t POR Lam s VNRT LW Iil1ki%64M= iCi MO= PUN s 199! The draft of Model Plan 2, 1992 is based on the assumption that COW monies will not be allowed to be used for the kind of plan that is envisioned in the 1992 pian. That is, CDBG monies could only be used for acquisition of property by the City/HRA and a write down on a sale to the buyer. Plan 2 differs from Pian 1 in the following respects: 1. References to the 1992 plan are deleted. 2. The funding amount is not identified. 3. The number of families to be assisted is -deleted as well as reference to the group of 20 and the standby group. 4. The schedule is more open and does not need to be as detailed. S. The funding source is set C monies. It is suggested that the City/Ras consider Nestles i reserves and MR& tax levy. The City could we Cm funding if the City acquired the lamiles* es CDHO ifnadiagtae osN It1h the >[ame Am pias begause the "coni matching lards must be from aoa-Pederai sources. a. Registration is deleted but the application process would remain. 7. Preference is expanded to include very low income and date of application, and a preference point system is proposed. 1 9. The waiting list would be designed to reflect and accommodate an ongoing plan. opening and closing the waiting list can be W.ased on the length of the list and funding. 9. The selection groups are eliminated. lo. Procedures are. modified to take into account the points in this report. 11. Lenders could remain the same or could be expanded if appropriate. 12. The responsibilities of the buyers and City/HRA change slightly. 1770i'"-' 7 f"fJ The draft of Model Pian 1, 1991 is based on use of CDBG funding and is patterned after Model Plan 1, except the homebuyer8a purchase agreement would permit transfer of the purchase rights to the City/BRA. if the City/BRA agree that the property meets the goals of the plan and the lender approves the homebuyerls mortgage, then the City/HRA can exercise its rights to purchase the property and at up a double closing. The first closing would be between the seller and the City/BRA and the second closing would be between the City/BRA and the first-time homebuyer. The more significant or relevant differences in Model Plan 1 as compared to Model Plan i are in bold type. a t. OaMRRRi. DESCRIPTION Plymouth*s Scattered site Homeownership Plan for Lower and Very Low Income, First-time Homebuyers provides financial assistance to selected eligible buyers to pay up to 50 percent of the downpayment, pay closing costs, and/or to reduce the mortgage Principal amount which will make the house more affordable. Families desiring to participate must apply, be eligible and be selected to participate under the provisions of this pian. Interested families can make arrangements to apply by calling the City at 550-5056. Funding is expected to be tram reserves fro® the Section 8, Certificate Plan and/or fk m the HRA tax levy account. Some preference will be given to those who work or live in Plymouth. Prospective first-time homebuyers selected to participate are responsible for finding an appropriate house for sale in Plymouth, selecting a lending institution familiar with the plan, making the arrangements for the mortgage and meeting the provisions of this plan. a. RLRM GOALS Plymouth's Scattered Site Homeownership Plan has the fol:iowing four goals: a. assist low and moderate income families in purchasing homes on scattered sites in Plymouth. b. Promote home ownership. C. Recover and recycle any funds recovered through the repayment Process to -future scattered site homeownership programs. d. Increase the supply of affordable, habitable dwellings in Plymouth. a. SC®LE in order to meet the plan goals and other requirements in a timely manner, the following schedule is established. January 20, 1993 Application for first-time homebuyere opens. January 29, 1993 Application closes. March, 1993 Selection of prospective participants begins. April, 1993 Orientation workshops for prospective buyers. May -June, 1993 Pre -application for mortgage approved by this date. May -July, 1993 Purchase agreement executed. May -Sept., 1993 Closing on properties. 3 CI'T'Y or PLYM OUTS POS Lown SSD TUT Low IMCOSB, PIRs"m YSli SODBL PLLM 1993 1. OCL DSSCRI IM Plymouthts Scattered Site Homeownership Plan for Lower and very Low Income, First-time Homebuyers provides financial assistance to selected eligible buyers to pay up to SO percent of the dowepayment, pay closing costs, and/or reduce the mortgage principal amount which will now the house more affordable. Families desiring to participate must be registered, complete the application, be eligible and have been selected to participate under the provisions of this plan. The' plan is fined :ander Community Development Block Grant (CDBC). Preference will be given to those who work or live in Plymouth. Prospective first-time homebuyers selected to participate are responsible for fining an appropriate house for sale in Plymouth, selecting a lending Institution familiar with the plan, making the arrangements for the mortgage an meeting the provisions of this plan. 20 PLU GOALS Plymouth's 1993 Scattered Site Homeownership Plan has the following four goals: a. 1lsaist lower an very low income families in purchasing homes on scattered sites in Plymouth. b. Promote home ownership. C. Recover an recycle any funs recovered through the repayment process to future scattered site hoasownersh p programs. d. Increase the supply of affordable, habitable dwellings in Plymouth. 3a 8CRMDULX In order to met the plan goals and other requirements in a timelymanner, the following schedule is established. January 20, 1993 Application for first-time homebuyers opens. January 29, 1993 Application closas. March, 1993 Selection of prospective participants begins. April, 1993 Orientation workshops for prospective buyers. I&Y-OVERS, 1993 pre -application for mortgage approved by thisdate. May -July, 1993 purchase agreement executed. May -Sept., 1993 Closing on properties. 2 to. NEND CITY OF PLYMOUTH 3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA 55447 DATE: March 6, 1992 TO: Housing an evelopment Authority Commissioners FROM: Chuck it , Community Development Director SUBJECT: SECTION 8 OPERATING RESERVE As I have reported to the HRA recently, and as you may have noticed in the monthly financial statement previously submitted for your review, the Section 8 Balance Sheet shows (as Item 2826) an amount of $96,166.94 as a Reserve Surplus --Operating Reserve as of January 31, 1992. This reserve account has been growing slowly since about 1978 as the result of expenditures from the HRA Section 8 administration account (basically payments to the City under the management contract plus auditing/accounting fees) being less than administration fees received by the HRA from HUD. The administration fees received from HUD are on a formula/per unit basis paid regardless of the actual cost of administering the program locally. Since about 1978 the actual receipts from HUD based on that formula have exceeded the actual expeditures by the Plymouth HRA under the management contract resulting in annual surpluses. in addition, the account has been accruing interest on the increasing balance. HUD rules regarding Section 8 operating reserves are outstanding in their brevity. 1 have inquired as to standards HUD may have with regard to maintaining operating reserves and 1 have found there are none. HUD rules simply state that operating reserves should be maintained to assure that sufff-:ient funds are available to administer the Section 8 certificates for which the HRA is responsible. I am sure there have been instances where PHA's have overspent for whatever reason. The combination of administrative fees due from our 87 Section 8 certificates and the net fees received by the City for administering Section 8 portability certificates will annually total approximately $65,000. It has been the practice of the Cit of Plymouth (and it is the recommendation of the Financial Task Force to maintain an operating reserve forCity purposes equalling approximately 40 percent of the annual operating budget. While the primary purpose of this operating reserve is to assure positive cash flow related to tax receipts from Hennepin County, the percentage still might serve as a 'benchmark' for the NRA to consider with respect to a permanent operating reserve for the Section 8 program. There may be unforeseen twists in future Section 8 program administration (such as portability has been) that will require the NRA to expend for administration beyond what will be available 1- from HUD --at least for a portion of a fiscal year until the HUD fee schedule catches up°. if we assume the standard of maintaining an operating reserve in the Section 8 fund equal to 40 percent of the annual operating budget an amount of $25,000 would be appropriate at this time. If that amount is properly invested, the Interest earnings should increase the operating reserve at a pace close to the need to increase that reserve to match increases in the operating budgets. If we, therefore, assume $25,000 to be the amount of the operating reserve that is retained as a"rainy day account", approximately $75,000 will remain in that account by the end of this Section 8 budget year (June 30, 1992). We have now revised the management agreement to °track° with the Section 8 budget and increase the amount of labor and materials attributable to Section 8 Ministration as a result. Additional surplus shouldggenerated in the Section 8 fund during this program year (July 1, 1991 -June 30, 1992) because these adjustments did not take place until January/February 1992. Chapter 8 of the HUD Section 8 program rules discusses expenditures of Section 8 operating reserve funds found by the PHA Board of Commissioners to be in excess of amounts necessary to assure the continued administration of the program. Other than specifying that direct expenditures must be made out of the operating reserve account --as authorized by the PHA Board of Commissioners --no specific guidance is provided by HUD with regard to how these funds are expended except that they must be expended for mother housing purposes consistent with the PHA's authority under State and ;.kcal Law, provided that the amounts used for other housing purposes are not required for projected administrative expense through the remaining ACC terms". The HRA Board of Commissioners may wish to, at this time, begin consideration of potential areas of expenditure for these excess Section 8 operating reserve amounts (approximately $75,000 if a 40 percent true reserve is considered appropriate). It should be understood that I do not now anticipate continued annual surpluses as have developed in the past. I believe that in creating those surpluses we °shorted" our administration of the Section 8 program and the extensive management findings of 1991 are ample proof that there is a direct relationship between funds received for administrative purposes and use of those funds for those administrative purposes. i have heard that some other PHA's may have deliberately created Section 8 operating fund surpluses to "free up" money orf otTier housing purposes. I do not advocate that approach. Some other °housing purposes° that have been mentioned, from time -to -time, as potential uses for the excess Section 8 operating reserve include the following: 1. A locally designed rental subsidy program similar to Section 8 but, perhaps more flexible in terns of rules to better meet locally perceived needs. An example I have heard about is the St. Louis Park "Max 200" program. Here the HRA has used Section 8 operating reserve funds for a local Federal assistance program. They have limited the amount of assrstance however to no more than $200 per month per unit and have developed other local rules governing the program. For comparison, the average assistance per unit per month now provided through our Federal 2- Section 8 program is well over $300. Approximately 30 "unit years° of rental assistance could be provided under a local program adopting the Max 200" concept to the amount of subsidy rovided. This could be 15 additional units over a 2 year period or 6 additional units over a 5 year period or some other combination totally 30 unit years. 2. Perhaps in a similar manner to No. 1 above, but more focused, would be the application of the available Section 8 operating reserve funds as additional local subsidyto the senior housing project. Unlike applying CDB6 funds to that proect it does not appear that Federal low/moderate income constrictions and occupancy rules would necessarily be tied to the use of the funds for these purposes. If it were the desire of the HRA to pursue this evidence a mcre specific finding would be necessary regarding any °strings° that would be tied to these funds. 3. There has been a suggestion that the HRA could expend some of the operating reserve funds for capital items -=such as an enhanced or new computer system for HRA purposes. While this could be an eligible expenditure, we generally have been hesitant to purchase capital items with Federal funds due to the rather complex accounting procedures required for such transactions. Our usual approach in this instance is to allow respective City capital equipment cost center to acquire the nece3sary eeqquipment and charge back the HRA over an extended time period. This type of accounting arrangement would work here as well. 4. There have been suggestions that City/HRA retain additional staff in the administration of the Section 8 program and other housing related activities. While this may be a desirable activity in the future, i do not believe it to be an immediate need. Perhaps any decision regarding expenditrre of the operating reserve funds should be delayed until such time as I have completed my review of the Community Development Department organizational structure and manpower needs. I have not as yet made a determination as to whether our current staffing related to HRA activities is or .is not adequate in comparison to the other Community Development manpower requirements. sr:hra/cd/2-19:jw) 3- I. EMD CITY OF PLY"DUTH 3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA SS447 DATE: April 8, 1992 TO: Charles E. Dillerud, Executive Director FROM: Milt Dale, Housing Specialist Nt_ SWECT: INFORMATION ITEMS The following are information items that would be of interest to NRACommissioners: a. Response to Plymouth's First Time-Homebu er Pro ram. The deadline for receiving applications for UO FirSt-Tin Homebuyer Program was 4:30 p.m. on Monday, April 6, 1992. Denise has since tabulated the number of applications received and determined that we have a total of 140 applications. This compares with a total of 183 families or in4ividuals that registered. Applicants with a preference out number those in the non -preference category over 2::, i.e., 96 with a preference and 41 non - preference applicants. A drawing will be held on Thursday, April 9, 1992at6:00 p.m. to select the top 20 applicants who will be given first opportunity to receive financial assistance. Orientation meetings will be held on Saturday, April 11, 1992 at 0:00 a.m., and again on Tuesday, April 14, 1992 at 7:00 p.m. I will provide Commissioners will more detailed information on the process at their May Housing Authoritymeeting. b. Section 8 Summary Statistics Report, 4/1/92. c. Section 8 Financial Report for Period 1/1/91 Through 2/29/92. (Balance Sheet and Operating Statement. sr:hra/info.4-16) SUMMARY STATISTICS REPORT m=--------- 140DATES04/01/92 SELECTION CRITERIA• ALL TENANTS WERE INCLUDED I. HEAD .C.- 146USEHOLD COMPOSITION. (Y. OF ALL HEADS IS IN PARENTHESES) A. THEPE ARE 126 HEADS OF HOUSEHOLD. MAY BE MORE THAN 1 IN A UNIT.) THERk" ARE 126 HOUSEHOLDS. 0.0 0.0 G. RACE/ETHNICITY• B. AGES UNDER 30 30-39 40-49 50-59 60-69 70-79 80(+) NOs 44 Z4 13 0, 3 7 5 PCTs 34.9 42.9 10.3 0..0 2.4 5.6 4.0 AVERAGE AGE$ 36.6 HISPANICS 0 ( 0.0) NON -HISPANIC: 126 100.0) H. MISCELLANEOUS: C. SEX• MALES 17 ( 13.5) FEMALES 109 ( 86.5) D. SINGLE PARENT HEAD -OF -HOUSEHOLD FAMILIES ASSISTEDs MALE: 1 ( 0.8) FEMALE$ 93 ( 73.8) E. ELDERLY HEAD -OF -HOUSEHOLD FAMILIES ASSISTED: OBR 1BR 2BR 3BR 4BR 5+BR NOs 0 19 11 0 0 0 PCTs 0.0 15.1 8.7 0.0 0.0 0.0 F. NON -ELDERLY HEAD -OF -HOUSEHOLD FAMILIEE ASSISTED• OBR IBR 2BR :ifR 4BR 5+BF. NOS 0 0 86 10 0 0 PCTs 0.0 0.0 68.3 7.9 0.0 0.0 G. RACE/ETHNICITY• WHITES 107 ( 84.9) BLACK: 14 ( 11.1) AMER IND/ALASKAN NATIVE: 3 ( 2.4) ASIAN/PACIF ISLANDERS 1 ( 0.8) OTHERs 1 ( 0.8) HISPANICS 0 ( 0.0) NON -HISPANIC: 126 100.0) H. MISCELLANEOUS: 62 YRS OR OLDER• 15 ( 11.9) HANDICAPPEDs 14 ( 11.0 DISABLEDs 1 ( 0.8) FULL-TIME STUDENT (18 +)$ 1 ( 0.8) NONE OF THE ABOVE• 96 ( 76.2) PHA Manager 3.40 (c)86-91 * CITY OF PLYMOUTH SUMMARY STATISTICS REPORT (cont): Dates 04/01/92 Paged . II. ALL MEMBERS COMPOSITION: (PCT IS PGT OF ALL MEMBERS) A. -THERE ARE 308 MEMBERS. B. AGE: 0-12 13-17 18-29 30-39 40-49 50-59 60-69 70-79 80(+) 148 16 54 60 13 0 3 8 648.1 5.2 17.5 19.5 4.2 0.0 1.0 2.6 1...9AVERAGEAGE: 20.6 C. SEX: ALL - MALE: 107 ( 34.7) ADULTS - MALE: 29 ( 9..4) Is +) D. RACE/ETHNICITY: WHITE: BLACK: AMER IND/ALASKAN NATIVE: ASIAN/PACIF ISLANDER: OTHER. HISPANIC: 0 ( 0.0) E. MISCELLANEOUS.: 62 YRS OR OLDER.: HANDICAPPED: DISABLED: FULL-TI.ME STUDENT (18 +)1 MONE OF THE ABOVE: F. FAMILY SIZE: FEMALE: .201 ( 65.3) FEMALE: 115 ( 37.3) 248 ( 80.5) 43 ( 14.0) 11 ( 3.6) 3 ( 1.0) 3 ( 1.0) NON -HISPANIC: 30B (100.0) 17 ( 5.5) 14 ( 4.5) 1 ( 0.3) 1 ( 0.3) 276 ( 89.6) N0: 1 2 3 21 50 38 4 5 12 5 6 0 7 8 0 0 9 10 11(+) PCT: 16.7 39.7 30.2 9.5 4.0 0.•., 0.0 0.0 0 0.0 0 0 0.0 0.0AVERAGEFAMILYSIZE: 2.4 G. RELATIONSHIP CODE: (AVG I.S AVG PER HOUSEHOLD) HEAD SPOUSE ADULT DEPEN FOSTER LIVE-IN OTHERNO: 126 8 10 163 0 1 0AVG: 1.00 0.06 0.08 1.213 0.00 0.01 0.00 PHA Manager 3.40 (c)86 -9E * _ITY OF PLYMOUTH SUMMARY STATISTICS REPORT (cont): Date: 04/01/92 Page: III- INCOME/EXPENSES: A. INCOME BREAKDOWN: (INCOME BEFORE ADJUSTMENTS) UNDER 2500- 5000- 7500- 10000- 12500- 1500o- 2500 4999 7499 9999 12499 14999 17499 17500(+) N0: 3 7 63 21. 10 13 5PCTs2.4 5.6 50.0 16.7 7.9 10:.3 4.0 3.2AVERAGEINCOMEe68328 AVERAGE INCOME AFTER ADJUSTMENTS: $ 7170 B- INCOME SOURCESe (AVG IS AVERAGE FOR THAT ITEM) PUBLIC WELFWAGESASSISTPENSIONASSETSOTHERRENTHSLDSWITHe31742619180PERCENT: 24.6 58.7 20.6 15.1 14.3 0.0AVGAMOUNT: 11440 5847 7110 197 4072 0 C..INCOME CATEGORIES AT MOVE-INe INCOME CATEGORIES AT REEXAM: VERY LOW INCOME: 48 ( 38.1) VERY LOW INCOME: 80 ( 63.5) LOWER INCOME: 0 ( 0.0) LOWER INCOME: 3 ( 2.4) OVER INCOME: 0 ( 0.0) OVER INCOME: 0' ( 0.0) EXCEPTIONS: LOWER INC FAMILIES REQUIRING LI EXCEPTIONS: 0 D. RENTS (Averages per Household, except for URP) TOTAL TENENT PAYMENT: 180.1TENANTRENT: 155.7 HOUSING ASSISTANCE PAYMENT: 374.2 UTILITY REIMBURSEMENT PAYMENT:********* (Avg for only Hshlds with URP) SECURITY DEPOSIT: 98.3 E. EXPENSES: (AVG IS AVG PER HOUSEHOLD WITH THAT ITEM) MEDICL HSLDS WITH: CH CARE OTHER ASSIST DEDUC ELDERLY 15 PERCENT: 11.9 16 1.2.7 0 0 0.0 0.0 97 77.0 30 AVG AMOUNT: 1037 2623 0 23.8 0 787 400 PHA Manager 3.40 (c)86-91 * CITY OF PLYMOUTH SUMMARY STATISTICS REPORT (cont); Datee 04/01/92 Pagee IV. UNITS/CERTIFICATES/VOUCHERS (PCT is from units on file except Where A. UNIT REPORTS (Calculated only if report includes a single project) - UNITS ON FILE: 0 OBR 1BR 2BR 3BR 4BR 5+BR 1. UNITS IN ACC: 0 0 0 0 0 0 0.0) < 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0) 2. LEASED: O 0 0 0 0 0 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0) 3. OUTSTANDING 0 0 0 0 0 0 OR EXTENDED; ( 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0) 4. BALANCE (OVER 0 0 0 0 0 0 UNDER ACC: ( 0.0) ( 0.0) ( 0.0) ( 0.0) ( 0.0.) ( 0.0) B. PROGRAM UTILIZATION: Includes ALL units. Use. Rpt #13 for more detail.) PCT OF NUMBER PERCENT UNITS TOTAL ISSUED/ UTILI- AVAIL. AVAIL. LEASED ZATION SECTION 8 CERIc 4 100.0 123 96.9' SECTION 8 MR: 0 0.0 0 0.0 VOUCHERe 0 0.0 3 100.0 PUBLIC HOUSING 0 0.0 0 0.0 TOTAL: 4 100.0 126 96.9 C. GROSS RENT UNDER 200 200-299 300-399 400-499 500-599 600-699 700+ NOS 2 0 0 10 99 8 7 PCTs 1.6 0.011. 0.0 7.9 78.6 6.3 5.6 AVERAGE GROSS RENTS 554.3 D. CONTRACT RENT UNDER 200 200-299 300-399 400-499 500-599 600-699 700+ NO: 2 0 0 18 97 4 5 PCT: 1.6 0.0 0.0 14.3 77.0 3.2 4.0 AVERAGE CONTRACT RENT: 529.8 E. UTILITY ALLOWANCE - UNDER 25 25-49 50-74 75-99 100-124 • 125-149 150; NO a 74 50 0 2 0 0 0 PCTs 58.7 39.7 0.0 1.6 0.0 0.0 0.0 AVERAGE UTILITY ALLOWANCEe 24.4 PHA Manager 3.40 (c)86-91 s CITY OF PLYMOUTH SUMMARY STATISTICS REPORT (tont): V. LEASING. INFORMATION: TOTAL A. LEASE -IN-PLACE FAMILIES: 1 Dates 04/01/92 Page: ELDERLY NON -ELDERLY 1 (100.0) 0'( 0.0) B. CERTIFICATE/VOUCHER SIZE VS ACTUAL UNIT SIZE: ACTUAL SIZE: OBR 1BR 2BR 3BR 4BR 5+BR OBR: 0 0 0 0 0` 0 CERTIF/ IBR: 0 19 0 0 0 0 VOUCHER 2BR: 0 0 97 0 0 0 SIZE: 3BR: 0 0 0 10 0 0 4BR: 0 0 0 0 0 0 5+BR: 0 0 0 0 0 0 C. EXCEPTION RENTS FOR CERTIFICATES: F. NUMBER OF ASSISTED FAMILIES WHO, BECAUSE THEIR GROSS RENT IS LESS THAN PAYMENT STANDARD, RECEIVE A SAVINGS: OBR IBR 2BR 3BR 4BR 5+BR. VOUCHER: 0 0 0 0 0 0 AVERAGE SAVINGS: 0.0 0.0 0.0 0.0 0.0 0.0 NUMBER OF ASSISTED FAMILIES RECEIVING SAVINGSe 0 RNA Manager 3.40 (c)86-91 * CITY OF PLYMOUTH OBR IBR 2BR 3BR 4BR 5+BR 10% EXCEPTION AUTHORIZEDc 0 0 0 0 0 0 20% EXCEPTION AUTHORIZED: 0 0 0 0 0 0 ANNUAL ADJ. FACTOR APPLIED: 0 0 2 1 0 a CURRENT GR OVER FMR: 0 0 0 0 0 0 1-10% OVER FMR: 0 0 0 0 0 0 10-207. OVER FMR: 0 0 0 O 0 0 MORE THAN 20% OVER FMR: 0 0 0 0 0 0 D. COMPARISON OF GROSS RENT TO FMRSe OBR 1.BR 2BR 3BR 4BR 5+BR CURRENT FMRS (AVG): 0 526 612 774 0 0 GR > 1.lxFMR: 0 0 1 0 0 0 GR > FMR < 1..lxFMRs 0 0 0 0 0 0 GR = FMR: 0 9 13 3 0 0 GR > .9xFMR < FMRs 0 4 4 0 O GR < .9xFMR: 0 5 3 0 0 TOTAL: 0 18 10 O 0 E. NUMBER OF ASSISTED FAMILIES WHOSE GROSS RENT EXCEEDS PAYMENT STD: OBR 1BR 2BR 3BR 48R 5+BR VOUCHER: 0 1 2 0 0 O AVERAGE Y. OVER PS: 0.0 100.0 100.0 0.0 0'.0 0.0 NUMBER OF ASSISTED FAMILIES WHOSE GROSS RENT EXCEEDS PAYMENT STD: 3 F. NUMBER OF ASSISTED FAMILIES WHO, BECAUSE THEIR GROSS RENT IS LESS THAN PAYMENT STANDARD, RECEIVE A SAVINGS: OBR IBR 2BR 3BR 4BR 5+BR. VOUCHER: 0 0 0 0 0 0 AVERAGE SAVINGS: 0.0 0.0 0.0 0.0 0.0 0.0 NUMBER OF ASSISTED FAMILIES RECEIVING SAVINGSe 0 RNA Manager 3.40 (c)86-91 * CITY OF PLYMOUTH SUMMARY STATISTICS REPORT (cont): Date: 04/01/92 Paget G. UNIT TYPES: SINGLE FAMILYc 2 DUPLEX: 3 ( 2.4) GARDEN: 121 ( 96.0) HIGHRISE: O ( 0.0) TOWNHOUSEe 0 ( 0.0) H. HOUSING TYPESe LEASED NOT LEASED IND GROUP RESIDENCE: 0 0 CONGREGATE: 0 0 MOBILE HOME PAD: O 0 SINGLE ROOM OCCUP: 0 0 SHARED HOUSINGe O 0 RENTAL REHAB: 0 0 PROJ SELF SUFFICe 0 0 OVERISSUED: 0 0 FLAGGED: 0 0 OTHER: 0 0 I. TURNOVER: CERT MOD REH VOUCHER PUB HOUSAVGTIMESUSED/LEASEDe 0.01 0.00 0.00 0.00 J. CANCELLATIONS OF CERT/VOUCHERc OVERINCOME: 0 ( 0.0) HOUSING NOT LOCATED: 0 ( 0,0) NO LONGER INTERESTEDe 6 ( 0,6) OTHER SUBSIDY: 0 ( 0.0) OBLIGATION UNMET: 0 ( 0.0) TERMINATED BEFORE 60 DAYS: 0 ( 0,0) 07H'2: 0 ( 0.0) K. HAP/LEASE CANCELLATIONS: OWNER UNCOOPERATIVE: 0 ( 0,0) TENANT UNDESIRABLE: 0 ( 0.0) TENANT DECEASEDc O ( 0.0) NO LONGER IN JURISDICTION: 0 ( 0.0) NO LONGER INTERESTED: 0 ( 0.0) SUBSTANDARD HOUSING: 0 ( 0.0) NO LONGER ELIGIBLE: 0 ( 0.0) SALE OF PROPERTY: 0 ( 0.0) PHA INITIATED: 0 ( 0,0) OTHER: 0 ( 0.0) L. OWNER DATA: THIS REPORT ALL OWNERSOWNERSW/CONTRACTS: 23 23FAMILIESUNDERLEASE: 126 126AVGFAMILIESPEROWNER: 5.48 5.48 WHITE: 0 0.0) 0 ( 0.0) BLACKe 0 0.0) 0 ( 0.0) AMER IND/ALASKAN NATIVE: 0 0.0) 0 ( 0,0) ASIAN/PACIF ISLANDER: 0 0.0) 0 ( 0.0) OTHER: 0 0.0) 0 ( 0.0) PHA Manager 3.40 (086-91 * CITY OF PLYMOUTH v x5080 PLYMOUTH MRA S:CTION 4 EX CO INDICATES CR=_DIT AMOUNT) PAGE 1 an I Nu_ • JISCRIPTI]N P:4IJO AAT TO DA U AMT 3UDGET ANT OVER UND E R 3ALANCE SH3:T ASSETS CASH 1111.1 G:-N:RAL FUND CASH 62.248.39 135066.56 00 13 .966.56 1117 PcTTT CASH 00 00 00 00 TGTAL C4SN 2.244.3) 135.946.56 00 135.946.36 ACCOUNTS R:CeIVABLE 1115 ACCOUNTS R:C. NUC 00 3.429.92 00 39429.52 o1129 ACCOUNTS P C. OTnE R 03 00 00 0 TJTAL ACCCJaTS A:C°IVASL_ 00 3.629.92 00 3.429.41 z 31162 CiEN FUND IMV:STc9ENTS 03 00 0 0 s DEFARR20 CHARGES e 1211 PR:P;:5 111SJRANCc. 00 00 000 0 71291) O NER JEF:RZeD CHARG 00 00 00 00 e TJTAL 31FIRRE0 i4ARGES 00 60 00 000 9 o LAND9 STRUCTUAS 6 :QUIP• 11475.1 OFFICE FU2N 6 EO. 00 39219.97 00 39219.97 z 14 AU T U P . 3 TOTAL LANG• STxUCT 6 E7. 00 3.219.91 00 3.219.97 a s1690 UN BU c0 OEdXTS 000 000 goo 099 e 7 TOTAL ASSETS 429248.39 1429596.45 00 142.596.43 a 3 e 7 e 5080 OLTHOUT.i MRA S:CTION I EX (3 INDICATES CREDIT AMOUNT) PAGS 2 NUN wore ws-ir- 24.r - W OESCRiPTiou PER= AMT TO OATS 4MT eU36ET ANT OVER BALANCE SNEeT UNDER LIABILITIES 9 SURPLUS a ACCOUNTS PAYABLE 2311 YE400 & CONTRACTORS 00 60 00 pps2117.1 FEDERAL INC TAX Mn O0 30 00 0C92137.2 S=CZAL SeCURITT wH 00 CJ 00 0072117.3 STATE INC TAX M:1 00 00 00s2117.4 HEALTH INS MN 00 00 00 00 002117.S INSURANCE UN 00 00 00 00a2117.1 CETIRiMENT MN 00.00 00 0 112116 ACCCJNTS PAYABLE MU2 JO 00 00122119JT" ---R ACCOUNTS PAY. 00 00 00 JO 00a319.1 ACCT PAT - CITY 00 00 00 r i. TOTAL ACCOUNTS PATA6LE OD 00 Be 00to r in 2210 R: A:0 ANNUAL CJNTR 7: 3:69715.003 31661 -1 -5, -Go* 17 18224 i;TnE-R JE-FERREJ CRF:.. 00 00 00 0: 19 2690 UNDISTRIBUTED CREDIT fig 00 00 00 22700 INC S EXP CLEARING 299:27.51 2739537.46 430929e.00 1569790..543a s SURPLUS 2810 UNRESERVED SURPLUS 00 396979894.44 239157.00 398749727.44 ' 72826 RES SURPLUS -OPER RES 00 969168.940 00 969168.940 a2927RESSURPLUS-PRJJ ACC 00 1609670.770 00 16d9870.7732040CUM. HUD CONTRI9. 00 397329233.640 4539455.000 392789778.640TOTALSURPLUS00999.368.910 4309296.000 3309909.09 1 TOTAL LIA8. A SURPLUS 429248.390 1429596.453 00 1429596.450 . PQ -33F 00 00 00 00. s f 5080 PLYMOUT4 NRA SECTION i EX (0 INOICATSS CREDIT AMOUNT) PAGE 3 DESCRIPTIOi1 --- --P ER ICO------ ---YEAR TO DATE---- -------BUDGET------ PUN AMOUNT PUN AMOUNT PUN AMOUNT OPERATINu STATEMENT CHAN3F 3000 ESTIMATED AONIN.FEE 47.35 4.119.75 45.37 31.580.34 000 00 31.580.34 a 3001 RENO ACCT OFFSET 47.35 49119.750 45.37 31.580.340 00 00 31.580.344 s 49761.68 OPERATING INCOME 21.254.48 42.07 439926.00 22.671.520 ' 2 94136 MAL EXPENSE 000 e 3300 INT RESERVED SURPLUS 00 J0 00 00 00 00 30 00 3301 ADMIN FEE INCOME 27.31 2.375.654 6-.50 5.913.680 0 000 91 •6 6 • 00 3610 INT GEN "ND INVEST 2.66 231.320 3.27 2.273.200 00 00 2.273.200 ' 9 3690 OTHER INCOME 00 00 00 00 00 00 00 o TOTAL OPe12ATING INCOME 29.97 9636.970 11.76 8.186.880 00 00 1 6.a so 1: OPERATIN; EXPENSES 13 ADMINISTRATION 1.4110 ADMIN. SALARIES 54.73 49761.68 30.54 21.254.48 42.07 439926.00 22.671.520 ' 2 94136 MAL EXPENSE 000 00 014 99.32 00 00 99.32 76-4140 STAFF RA NIN 1-6-.00 00 0 00 000 Do 174150 TRAVEL 00 000 00 00 00 00.00 194170 ACCCUNTING 1.37 119.25 1.37 9S4.00 00 00 954.00 194171 AUDIT 00 0 00 48 500009 sca.vus- 4180 OFFICE RENT 00 00 00 00 00 00 00 14190 SUNDRY ADMIN EXPENSE 5.07 441.1E 1.25 966.65 17 180.00 656. 63 MAL Au4:41STRATION 61.1 5. 2 .11 33.30 Z39174.65_ 94 . 250 a SeNERAL EXPeNSE INSURANCE 00 do 00 000 x4530 TERMINAL LEAVE PAY. 00 00 00 00 00.0 00 00 74540 ENPLOYEE BEN. CONT2. 10.33 699.00 9.99 69*52.00 00 00 69952.00 4 M Y . 0 uu 4591 A4M/N P-9TABILITY 12.40 1.073.00 96 669.47 00 00 664.w7 TOTAL ZENERAL EXPENSE 2:.74 1.97d.00 10.95 7.621.47 00 00 7.621.47 MOUSING ASSIST. PAYMENTS 4715.1 NAP -OCCUPIED UNITS 452.15 39.337.10 446.94 312.461.12 369.44 385.692.00 T3.230.880 4715.1 NAP-SMG/UNPD RENT 00 OJ 00 00 00 uu 00 00 4115.4 UTILITY ALLOWANCE 03 00 00 00 000 00 00 70115*5 MAP -PORTABILITY 170.15 1403OZ0639 90035 6998839790 SOO egg TOTAL MOUSING ASSIST. PAT282.01 249534.47 356.59 249.577.42 369.44 3AS9692.00 136.114.580 cXPiNSK 365.91 319334.59 4 z.a• zsuv3T3eJ4 419s&6. b.560 5039 PLYMOJTM 4 Ra Sk TiDii o EX CO iNDICATEi CREDIT AMOUNT) PAGE s KUM 0916 Y DESCkIPTION CURF.I.Solow P:RIOD------ Kcrualf YEAR r. -Y TO SATE ---- BUDGET------ CHANGE PUN AMOUNT pum AMOUNT PUN AMOUNT OPERATING STATEMENT 2 SURPLUS ADJUSTMENTS 2 6010 PRIOR TEAR AOJ-ARR 00 00 1.90 1 321.00 00 0 19321.00 6120 GAIW LOSS NCNEXP EQ 00 00 00 00 00 00. 00 TOTAL SURPLUS ADJUSTMENTS 00 00 1.90 19321.00 00 00 1931.00 6 PROVISION FOR RESERVES s 7016 PR2V FOR OPER RESERV 00 00 00 00 00 00 00 917027 PROV FOR P93J ACCT 00 GO 00 00 22.18 239157.00 2391S7.000 i to TOTAL PROP. FOR RESERVES 00 00 00 00 22.18 239157.00 23s15T.006 12 CAPITAL EXPEN21TURES 137520 REPLACE NONEXP EQUIP 00 00 00 00 00 00 00 47330 RECEIPT NON-exP EQUIP 00 00 00 00 00 00 00 , 157540 PROPERTY SET 6 ADD 00 00 00 00 00 00 00 167590 CONTRA FOR 75005 00 00 00 00 00 00 00 7 TOTAL 00 03 00 00 00 00 00 127610 VANDALISM EXPEND. 00 09 00 00 00 00 00 CONTRIBUTIONS EARNED X3026 ANNUAL CONTR-CUR Vk 00 03 00 00 434.34 4!3.455.006 4S39435:00 28027 ANNUAL CONTR-PA IR 03 00 OA 00 00 00 00 2 TOTAL 00 0) 00 00 434.34 4539455.000 453.455.00