The Neighborhood Stabilization Program

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					The Neighborhood Stabilization Program
      Housing and Economic Recovery Act of 2008




  Application Workshop – February 19, 2009
Welcome & Introductions


     Jacquelyn Dupree
 CDBG Program Administrator




                              2
Your State Program Partners
Jacquelyn Dupree, CDBG Program Administrator
   Gail Stafford, Grant Management Unit Planning Mgr
       Patrick Howard, Program Specialist
       Mark Nixon, Program Specialist
   Judy Peacock, Operations Unit Planning Manager




                                                       3
                 Federal Law
Title III of Division B of the Housing and Economic
Recovery Act, 2008 (HERA)

  Signed by the President on July 30, 2008

  Section 2301-Emergency Assistance for the Redevelopment of
  Abandoned and Foreclosed Homes
     Neighborhood Stabilization Program (NSP)

  Special Allocation of 2008 CDBG Funds

  Amounts determined by HUD formula using HERA criteria


                                                               4
                                     U.S. Congress
                               Total Allocation to Florida
                                 $541 million


                               U.S. Dept. of Housing &
                                 Urban Development
                                        (HUD)




                  State Allocation                                HUD Direct Allocation
                  $91 million                                        $450 million


 Allocated to 26 Local
                                                   Allocated to 48 Local
     Governments
                                                    Governments with
through CDBG program
                                                       HUD Oversight
  with DCA Oversight

                                                                                     5
 HUD Direct-Funded Communities
Grantee                 NSP Allocation   Grantee               NSP Allocation
FLORIDA STATE PROGRAM   $91,141,477.58   MIAMI-DADE COUNTY      $62,207,200.11
BOYNTON BEACH            $2,963,311.39   MIAMI                  $12,063,702.18
BREVARD COUNTY           $5,269,666.83   MIAMI GARDENS CITY      $6,866,119.02
BROWARD COUNTY          $17,767,588.93   MIRAMAR                 $9,312,657.81
CAPE CORAL               $7,065,483.92   NORTH MIAMI             $2,847,088.52
COLLIER COUNTY           $7,306,755.32   ORANGE COUNTY          $27,901,772.52
CORAL SPRINGS            $3,378,141.82   ORLANDO                 $6,730,262.69
DEERFIELD BEACH          $2,005,699.10   PALM BAY                $5,208,103.79
DELTONA                  $6,635,908.82   PALM BEACH COUNTY      $27,700,339.55
ESCAMBIA COUNTY          $4,565,917.57   PASCO COUNTY           $19,495,804.66
FT LAUDERDALE            $3,700,096.38   PEMBROKE PINES          $4,398,575.04
FT MYERS                 $2,297,318.25   PINELLAS COUNTY         $8,063,758.60
HIALEAH                  $5,385,046.04   PLANTATION              $2,016,308.73
HILLSBOROUGH COUNTY     $19,132,978.19   POLK COUNTY            $14,586,258.48
HOLLYWOOD                $7,534,603.03   POMPANO BEACH           $4,366,156.92
HOMESTEAD CITY           $2,887,009.65   PORT ST LUCIE          $13,523,132.46
JACKSONVILLE-DUVAL      $26,175,317.48   SARASOTA COUNTY         $7,140,861.12
KISSIMMEE                $2,371,748.84   SEMINOLE COUNTY         $7,019,513.53
LAKE COUNTY              $3,136,967.20   ST PETERSBURG           $9,498,962.31
LAKELAND                 $2,005,781.01   SUNRISE                 $3,494,985.59
LAUDERHILL               $4,293,287.80   TAMARAC                 $4,772,218.49
LEE COUNTY              $18,243,867.46   TAMPA                  $13,600,915.02
MANATEE COUNTY           $5,283,121.89   VOLUSIA COUNTY          $5,222,831.33
MARGATE                  $2,106,554.95   WEST PALM BEACH         $4,349,546.00
MARION COUNTY            $6,324,054.65                 TOTAL   $541,364,778
                                                                                 6
        Key Sources of Information
Federal Register / Vol. 73, No. 194 / Monday, October 6, 2008

State Substantial Amendment to 2008 CDBG Action Plan

Notice of Intent to Apply
   Preliminary citizen participation information


Application and Instructions

State Emergency Rule
   Clarifies state procedures; waives some regular CDBG rule provisions

NSP Policy Guide
   Will clarify State Requirements

                                                                          7
Federal Register Notice




                          8
                    Federal Register Notice
I. Allocations

A. Formula: Allocation
   Who received funding

B. Formula: Reallocation
   HUD will recapture funds not obligated at end of 18 months
      Must be contracted for at the local level.
          State will “obligate” $ in DRGR when subgrantee has them under
          contract.




                                                                           9
                  Federal Register Notice

II. Alternative Requirements and Regulatory Waivers

  Limited focus

  Identifies CDBG Regs that cannot be waived
     Uniform Relocation Assistance Real Property Acquisition Policies Act of
     1970 (URA)
     National Affordable Housing Act (NAHA)
     Others include Environmental Review, Fair Housing, etc.

  Identifies CDBG Regs that apply
     24 CFR part 570 subpart I for states, including 24 CFR part 570
     subparts A, C, D, J, K, and O, as appropriate

  Describes alternative requirements that replace certain CDBG Regs
     Waives Consolidated Plan Regs
         Amend 2008 CDBG action plan
         Reporting in DRGR
                                                                          10
                    Federal Register Notice

A. Definitions
   Abandoned. Mortgage or tax foreclosure proceedings have been initiated
   for the property, no mortgage or tax payments have been made by the
   property owner for at least 90 days, AND the property has been vacant for
   at least 90 days.

   Blighted structure. Exhibits objectively determinable signs of
   deterioration sufficient to constitute a threat to human health, safety, and
   public welfare.

   CDBG funds. In addition to definition at 24 CFR 570.3, grant funds
   distributed under NSP notice.

   Current market appraised value. The value of a foreclosed upon home
   or residential property that is established through an appraisal made in
   conformity with the appraisal requirements of the URA at 49 CFR 24.103
   and completed within 60 days prior to an offer made for the property by a
   grantee, subrecipient, developer, or individual homebuyer.


                                                                             11
                 Federal Register Notice

Foreclosed. A property ‘‘has been foreclosed upon’’ at the point that,
under state or local law, the mortgage or tax foreclosure is complete. HUD
generally will not consider a foreclosure to be complete until after the title
for the property has been transferred from the former homeowner under
foreclosure proceeding or transfer in lieu of foreclosure, in accordance with
state or local law.

Land bank. A governmental or nonprofit entity established, at least in
part, to assemble, temporarily manage, and dispose of vacant land for the
purpose of stabilizing neighborhoods and encouraging re-use or
redevelopment of urban property; operates in a specific, defined
geographic area. It will purchase properties that have been abandoned or
foreclosed upon and maintain, assemble, facilitate redevelopment of,
market, and dispose of the land-banked properties.

Revenue for the purposes of section 2301(d)(4). Has the same
meaning as program income, as defined at 24 CFR 570.500(a) with the
modifications in this notice.



                                                                           12
                 Federal Register Notice


Subrecipient. Has the same meaning as the first sentence of 24 CFR
570.500(c); includes any nonprofit organization (including a unit of general
local government) that a state awards funds to.

Use for the purposes of section 2301(c)(1). Funds are used when
they are obligated by a state, unit of general local government, or any
subrecipient thereof, for a specific NSP activity. Funds are obligated for an
activity when orders are placed, contracts are awarded, services are
received, and similar transactions have occurred that require payment.

States may define other program terms.




                                                                           13
                    Federal Register Notice
II. B. Pre-Grant Process

1. General (things to consider)

2. Contents of an NSP Substantial Amendment

3. Continued Affordability

   Grantees must ensure that sale, rental, or redevelopment of abandoned and
   foreclosed-upon homes and residential properties remain affordable to
   individuals or families whose incomes do not exceed 120% of AMI or, for
   units originally assisted with funds under section 2301(f)(3)(A)(ii), remain
   affordable to individuals and families whose incomes do not exceed 50% of
   AMI.

       Substantial amendment defines “affordable rents” and “affordability.”

       “Affordable rents” are defined as the Fair Market Rents published annually
       by HUD.

                                                                               14
                      Federal Register Notice

    Homebuyers must receive at least 8 hours of homebuyer counseling by a HUD
    approved agency.

    If NSP funds assist a property that was previously assisted with HOME funds,
    but on which the affordability restrictions were terminated through
    foreclosure or transfer in lieu of foreclosure pursuant to 24 CFR part 92, the
    grantee must revive the HOME affordability restrictions for the greater of the
    remaining period of HOME affordability or the continuing affordability
    requirements of this notice.

4. Citizen Participation Alternative Requirement
    Notice of Intent to Apply
    Emergency Rule
    Policy Guide (will be provided at a later date)

5. Joint Requests
    Permits joint applications and interlocal cooperation.


                                                                              15
                     Federal Register Notice


6. Effect of Existing Cooperation
    Cooperative agreements in place for Entitlement funding are acceptable.

C. Reimbursement for Pre-Award Costs
   Some pre-award costs are eligible; send written requests to incur pre-award
   costs to Jackie Dupree.


D. Grant Conditions
   HUD will apply grant conditions to high risk grantees (N/A).




                                                                              16
                Federal Register Notice

E. Income Eligibility Requirement Changes

   Provides for low-moderate-middle income
      Serve persons with income up to 120% of AMI
      25% set-aside (of state’s overall funds) to serve persons at or below
      50% AMI

   Describes national objectives

   Allows land banking (see application)

F. State Distribution to Entitlement Communities and
Indian Tribes

G. State’s Direct Action

                                                                        17
                  Federal Register Notice

H. Eligibility and Allowable Costs
   Eligible activities; excludes foreclosure prevention.
   Requires national objective be met.
   Discusses admin costs.
       See Emergency Rule and Application for State requirements.


I. Rehabilitation Standards
   Codes
   Energy efficiency
   Sustainability

J. Sale of Homes
   Discusses sales and required documentation.


K. Acquisition and Relocation
   One for one housing replacement is waived.
   URA not waived.                                                  18
                  Federal Register Notice


L. Note on Eminent Domain
  The State will not permit use of NSP funds for eminent domain.

M. Timeliness of Use and Expenditure of NSP Funds
  Funds must be obligated (under contract at the local level) within 18
  months.
  4 years to expend.


N. Alternative Requirement for Program Income (Revenue)
Generated by Activities Assisted With Grant Funds
  Defines program income.
  All program income must be returned to the state for re-distribution.



                                                                          19
                   Federal Register Notice
O. Reporting
   State will use DRGR; will require certain reports to update data.


P. FHA Properties Are Eligible for NSP Acquisition and
Redevelopment

Q. Purchase Discount
   Minimum discount of 5% for each residential property purchase.
   Minimum average discount for the NSP portfolio is 10%.
   If not, the minimum average discount is 15%.


R. Removal of Annual Requirements

S. Affirmatively Furthering Fair Housing
   Affirmatively further fair housing.
                                                                       20
State Substantial Amendment
  to 2008 CDBG Action Plan

           Judy Peacock
 Operations Unit Planning Manager




                                    21
                Florida’s Approach
Incorporates federal register provisions

Explains Florida’s approach to neighborhood stabilization

HUD data and methodology

$88 million allocated to 26 communities

Two separate NSP allocations:
    Regular NSP Allocation
    Supplemental Low-Income Rental Allocation

Grant administration (6.8%)
                                                            22
              Greatest Need
26 communities will receive State NSP funding
   Non-entitlement and Entitlement participants

Of these, 10 were awarded to, or within, counties that
also received direct funding from HUD

As a result, $40,661,761 (or 46%) is allocated to or
within counties determined by HUD to be areas of
greatest need.




                                                         23
                Greatest Need
                       Total HUD-Direct           State NSP Allocation
       County     NSP Allocations by County        to or within County
                (includes direct-funded cities)


Brevard                 $10,477,771                   $4,033,972

Broward                 $69,146,875                   $2,316,292

Manatee                  $5,283,122                   $2,576,267

Miami-Dade              $92,256,166                   $2,549,551

Orange                  $34,632,036                   $1,909,966

Osceola                  $2,371,749                  $14,091,818

Palm Beach              $35,013,197                   $1,905,005

Pinellas                $17,562,721                   $2,845,751

St. Lucie               $13,523,132                   $6,069,997

Volusia                 $11,858,740                   $2,363,142



                                                                         24
                      Distribution of Funds
                                        Regular    Supplemental
Local Government
                      County          Allocation      Allocation         Total
   Jurisdiction
                                         Amount          Amount
Alachua County     Alachua            $1,411,917      $1,517,321    $2,929,238
Bay County         Bay                $1,615,436        $908,311    $2,523,747
Melbourne          Brevard            $1,343,243        $576,948    $1,920,191
Titusville         Brevard            $1,625,481        $488,300    $2,113,781
Davie              Broward            $1,715,568        $600,724    $2,316,292
Charlotte County   Charlotte          $5,364,020      $1,423,037    $6,787,057
Citrus County      Citrus             $1,478,164        $693,256    $2,171,420
Clay County        Clay               $2,722,894        $915,629    $3,638,523
Palm Coast         Flagler            $2,177,980        $486,923    $2,664,903
Hernando County    Hernando           $4,299,472      $1,344,912    $5,644,384
Indian River Co.   Indian River       $3,598,543      $1,082,282    $4,680,825
Tallahassee        Leon               $1,693,435      $1,252,235    $2,945,670
Bradenton          Manatee            $1,975,077        $601,190    $2,576,267
Ocala              Marion             $1,313,887        $429,318    $1,743,205
Martin County      Martin             $2,645,982        $891,481    $3,537,463
Miami Beach        Miami-Dade         $1,641,832        $907,719    $2,549,551
Okaloosa County    Okaloosa           $2,255,252      $1,003,183    $3,258,435
Apopka             Orange             $1,547,689        $362,277    $1,909,966
Osceola County     Osceola           $11,524,826      $2,566,992   $14,091,818
Delray Beach       Palm Beach         $1,351,043        $553,962    $1,905,005
Clearwater         Pinellas           $2,034,862        $810,889    $2,845,751
Santa Rosa Co.     Santa Rosa         $1,662,215        $703,188    $2,365,403
St. Johns County   St. Johns          $1,761,096        $728,347    $2,489,443
Ft. Pierce         St. Lucie          $1,505,403        $579,993    $2,085,396
St. Lucie Co.      St. Lucie          $3,144,510        $840,091    $3,984,601
Daytona Beach      Volusia            $1,668,161        $694,981    $2,363,142
                           Total =   $65,077,988     $22,963,490   $88,041,478
                                                                                 25
                Distribution of Funds
Regular NSP Allocation
Same data and methodology as HUD for direct allocations
     Awards range from $1.25M to $11M
     Minimum grant $1.25M




Supplemental Low-Income Rental Allocation
Targeted to <50% AMI (25% of $91M must assist this group)
     Rental Housing
     Sub-grantees must have 5 yrs experience working with this income
   group or required to partner with PHAs or NPOs
     Allocated on Foreclosure Need and Share of <50% AMI Population

                                                                    26
                  Eligible Uses
NSP funds may be used for activities including:

  Purchase and rehab abandoned or foreclosed homes and
  residential properties

  Establish financing mechanisms for purchase and redevelopment
  of foreclosed homes and residential properties

  Establish land banks for foreclosed homes

  Demolish blighted structures

  Redevelop demolished or vacant properties


                                                              27
                 State Substantial Amendment

  Provides for state recapture of unobligated funds:

       10 months after execution of HUD agreement, state will recapture
       unobligated funds (including applicable admin funds) from subgrantee
       except for percent of original grant.

       15 months after execution of HUD agreement, state will recapture
       unobligated funds from subgrantee except for 5% of original grant.

       At 10 and 15 month recapture, subgrantees can keep unobligated
       funds that they can obligate within 18-month deadline.



Recapture of unobligated funds will be discussed in detail at the Implementation Workshop.
                                                                                        28
         State Substantial Amendment

Recapture of unspent funds:

  If subgrantee has not spent $$ in two years, state will evaluate
  progress to determine if extension may be granted.

  If progress is being made, and 50% of the $$ have been spent, state
  may grant up to 2 extensions up to 18 months).

  Following these extensions, state will recapture unspent $$ except for
  10% of original grant.

  A “special extension” is required in order to spend $$ after expiration
  of the regular extensions.

  10% that subgrantees can keep at end of regular extensions is
  considered to be what can be spent within the 4-year period.

                                                                     29
        State Substantial Amendment

Provides for an incentive based set-aside:

  Recaptured unobligated funds at 10 and 15 months.

  Unspent funds recaptured at end of grant or extension.

  Distributed based on NSP funds subgrantees have
  obligated or spent.

  Subgrantees that had funds recaptured are not eligible.

  Must be obligated within 18 months of HUD award to
  state.
                                                        30
       State Substantial Amendment


If Incentive-Based Set-Aside funds to be redistributed
exceeds capacity of subgrantees to obligate in 18 month
period or spend in 4-years, state allocate recaptured funds
to local governments receiving HUD NSP funds or to entity
it deems appropriate to accomplish NSP program.

State will give priority to projects that ensure compliance
with requirement to address low income target group.



                                                        31
        State Substantial Amendment


Outlines state program income (PI) requirements:

  All PI must be returned to state for reallocation based on
  greatest need and capacity to obligate and spend.

  PI received on or after July 30, 2013 must be remitted to
  the state to be returned to HUD.

  We anticipate revised requirements for Program Income.

                                                         32
          State Substantial Amendment

Uses of funds:

  Funds must benefit those whose incomes do not exceed 120% AMI.

  Use of NSP funds for public facilities must be directly related to and
  in support of the primary NSP activity approved in the application.

  Site visits will be conducted.

  Activity delivery costs are permitted.




                                                                     33
         State Substantial Amendment

Sets out monitoring plan

Addresses fraud mitigation:

  To prevent fraud or fiscal mismanagement related to real estate and
  financial transactions, sub-grantees must work with a third party
  management or accounting entity that can assist with asset valuation
  and secured transactions, unless they can demonstrate significant
  experience in these areas.

  State will provide T/TA, monitoring, etc.


                                                                  34
     State Substantial Amendment


Provides definitions and descriptions:

  Blighted
  Continued affordability
  Rental housing
  Owner occupied housing
  Duration of assistance
  Tenure of beneficiaries
  Housing rehab standards

                                         35
        State Substantial Amendment

Provides approach to low-income targeting:

  No less than 25% of total state funds, or $22.8 million, must be
  allocated to assist Low-Income not exceeding 50% AMI.

  Funds must provide rental housing.

Addresses acquisition and relocation:
  No dwelling units can be converted.

  Demolished units must be replaced and made available to individuals
  and families under 120% AMI.

Discusses public comment process
                                                                     36
        State Substantial Amendment

Provides information by activity

Outlines activities the State will undertake




                                               37
                             Activities
Housing Acquisition/Rehabilitation of homes for sale to individuals and
families with incomes less than 120 % of AMI (Purchase and
rehabilitate residential properties that have been abandoned or
foreclosed in order to sell the homes to qualified individuals or families)

CDBG eligible activities
   24 CFR 570.201(a) Acquisition
   24 CFR 570.201(b) Disposition
   24 CFT 570.201(e) Public Services for housing counseling
   24 CFR 570.201(i) Relocation
   24 CFR 570.201(n) Homeownership Assistance
   24 CFR 570.202(a) Rehabilitation

National Objective: LMMH

Minimum purchase discount - at least 5%.

Average purchase discount - at least 15%.


                                                                        38
                             Activities
Housing Acquisition/Rehabilitation of homes for sale to individuals and
families with incomes less than 50% of AMI (Purchase and rehabilitate
residential properties that have been abandoned or foreclosed in order to
sell the homes to qualified individuals or families)

CDBG eligible activities
   24 CFR 570.201(a) Acquisition
   24 CFR 570.201(b) Disposition
   24 CFT 570.201(e) Public Services for housing counseling
   24 CFR 570.201(i) Relocation
   24 CFR 570.201(n) Homeownership Assistance
   24 CFR 570.202(a) Rehabilitation

National Objective: LMMH

Minimum purchase discount - at least 5%.

Average purchase discount - at least 15%.


                                                                    39
                               Activities
Housing Finance - Establish financing mechanisms for purchase and
redevelopment of foreclosed homes

CDBG eligible activities
    24 CFR 570.206(g) Administrative expenses to facilitate housing
    24 CFR 570.201(n) Homeownership Assistance

National Objective: LMMH

Subgrantees must establish an affordability plan that ensures the sale, rental, or
redevelopment of abandoned and foreclosed-upon homes and residential
properties remain affordable to individuals or families whose incomes do not
exceed 120% or 50% of AMI as applicable.

Tenure must be no less than the affordability period established for the property.

For homeownership activities - a non-amortizing 5-year second mortgage for
homebuyer projects under $15,000, 10 years for projects between $15,000 to
$40,000, 15 years for projects over $40,000, and 20 years for new construction.

                                                                              40
                             Activities
Establishing Land Banks – limited to 10% of total regular allocation (not
limited by subgrantee)

CDBG eligible activities
   24 CFR 570.201(a) Acquisition
   24 CFR 570.201(b) Disposition

National Objectives): LMMA OR LMMH

A land bank will operate in a specific, defined geographic area.
   Purchase properties that have been abandoned or foreclosed upon and
   maintain, assemble, facilitate redevelopment, market, and dispose of the
   properties.
   Governmental entity may maintain abandoned or foreclosed property that it
   does not own, provided it charges the owner of the property the cost of the
   service or places a lien on the property for cost.

Subrecipients must submit a strategic plan for the acquisition,
redevelopment and disposition of land banks.
   Must incorporate requirement that land bank may not hold the property for
   more than 10 years without obligating the property for NSP activity.
                                                                          41
                                Activities

Establishing Land Banks (continued)


   Cannot pay more than appraised value of property; cannot displace a
   tenant/homeowner.

   For rental property, tenure must be long term, without planned limits on
   tenancy.

   For homes developed for the purposes of being sold to LMMI, tenure cannot be
   less than the affordability period established for the property.

   For homeownership activities - a non-amortizing 5-year second mortgage for
   homebuyer projects under $15,000, 10 years for projects between $15,000 to
   $40,000, 15 years for projects over $40,000, and 20 years for new
   construction.




                                                                              42
                                 Activities

Establishing Land Banks (continued)


   Subgrantees must establish affordability plan that ensures sale, rental, or
   redevelopment of abandoned and foreclosed-upon homes and residential
   properties remain affordable to individuals or families whose incomes do not
   exceed 120% or 50% of AMI, as applicable.

   Minimum purchase discount - at least 5%.

   Average purchase discount - at least 15%.

   NSP financing provided will be through a grant or a loan at zero % interest rate.




                                                                                  43
                               Activities
Demolition and Clearance/ Housing Redevelopment (Demolish blighted
structures/redevelop demolished or vacant properties)

CDBG eligible activities
    24 CFR 570.201(a) Acquisition24 CFR 570.201(b) Disposition
    24 CFR 570.201(d) Clearance and remediation
    24 CFR 570.201(i) Relocation
    24 CFR 570.201(n) Homeownership Assistance
    24 CFR 570.201(o) Counseling

National Objectives: LMMA OR LMMH.

Activity must be directly related to overall plan to address foreclosure.

State is limiting funds spend for this activity to 5% of regular allocation
Minimum purchase discount - at least 5%.
Average purchase discount - at least 15%.


                                                                              44
                              Activities
Housing Acquisition/Rehabilitation of homes for lease to individuals and
families with incomes less than 120% of AMI. (Purchase and rehabilitate
residential properties that have been abandoned or foreclosed in order to
rent to qualified individuals or families)

CDBG eligible activities
    24 CFR 570.201(a) Acquisition
    24 CFR 570.202(a) Rehabilitation
    24 CFR 570.201(b) Disposition
    24 CFR 570.201(i) Relocation

National Objective: LMMH

Affordability requirements apply to non-owner-occupied units in single-family
housing purchased with NSP funds.

For rental activities - a non-amortizing 5 year land use restriction agreement for
rental projects under $15,000, 10 years for projects between $15,000 to
$40,000, 15 years for projects over $40,000, and 20 years for new construction.

                                                                              45
                                Activities
Housing Acquisition/Rehabilitation (continued)


   Subgrantees must establish affordability plan that ensures sale, rental, or
   redevelopment of abandoned and foreclosed-upon homes and residential
   properties under NSP remain affordable to individuals or families whose incomes
   do not exceed 120% or 50% AMI, as applicable.

   Maximum NSP rents are defined as the fair market rent for existing housing for
   comparable units in the area as established by HUD under 24 CFR 888.111.

   Tenure is expected to be long term, without planned limits on tenancy.

   Minimum purchase discount - at least 5%.

   Average purchase discount - at least 15%.

   NSP financing provided will be through a grant or a loan at zero % interest rate.



                                                                                46
                               Activities
Housing Acquisition/Rehabilitation of homes for lease to individuals and
families with incomes less than 50% of AMI.

CDBG eligible activities
   24 CFR 570.201(a) Acquisition
   24 CFR 570.202(a) Rehabilitation
   24 CFR 570.201(b) Disposition
   24 CFR 570.201(i) Relocation


National Objective: LMMH OR LMMC


All properties must be leased to individuals and families with incomes at or below
50% of AMI.


Affordability requirements apply.
                                                                             47
                                 Activities
Housing Acquisition/Rehabilitation of homes for lease to individuals and families with
   incomes less than 50% of AMI (continued)

   For rental activities - a non-amortizing 5 year land use restriction agreement for
   rental projects under $15,000, 10 years for projects between $15,000 to
   $40,000, 15 years for projects over $40,000, and 20 years for new construction.
   All subgrantees must establish an affordability plan that ensures the sale, rental,
   or redevelopment of abandoned and foreclosed-upon homes and residential
   properties under NSP remain affordable to individuals or families whose incomes
   do not exceed 120% or 50% AMI, as applicable.

   Maximum NSP rents are defined as the fair market rent for existing housing for
   comparable units in the area as established by HUD under 24 CFR 888.111.

   Tenure is expected to be long term, without planned limits on tenancy.

   Minimum purchase discount - at least 5%.

   Average purchase discount - at least 15%.

   NSP financing provided will be through a grant or a loan at zero % interest rate.
                                                                                 48
                            Activities
Administration/Technical Assistance

Local government admin limited to 6.8%

State is conducting TA activities

CDBG eligible activity
   24 CFR 570.201(p)
   24 CFR 570.205
   24 CFR 570.206




                                         49
         Emergency Rule


             Gail Stafford
Grants Management Unit Planning Manager




                                      50
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
 Emergency Rule was filed on February 11, 2009
 Effective Immediately
 Submitted to the Florida Administrative Weekly
 (FAW)
 Published in FAW on February 20, 2009




                                              51
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
 Purpose
 Specific to NSP
 Applicable to State-funded NSP recipients




                                             52
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
 Portions of 9B-43 are waived
 24 CFR part 570 subpart I is applicable to
 NSP.
 24 CFR part 570 subparts A,C,D,J,K and O.
 NSP Policy Guide




                                              53
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
Definitions
Activity Delivery Costs limited to 10 percent
Developer
Developer Fee
State Sub-recipient vs. Sub-recipient



                                                54
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1

 Interlocal Agreements (applicable for
 infrastructure activities)
 Allows for $100,000 Cash on Hand for 21
 days
 Escrow Accounts




                                           55
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
Establishes 6.8 percent as the maximum
administrative cost allowed.

Establishes 12 percent as the maximum for
developer fees.




                                            56
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1

Incorporates 2008 Substantial Amendment
  requirements such as:
     Program Income
     Recapture Provisions
     Incentive-Based Set-Aside



                                          57
 Neighborhood Stabilization Program
     Emergency Rule 9BER09-1
Outlines standard procedures for the following
 processes:
     Amendments
     Time Extensions
     Housing Rehabilitation Standards
     Administrative Closeout



                                            58
Neighborhood Stabilization Program
    Emergency Rule 9BER09-1
Emphasizes requirements under HERA
 Purchase Discount
 Homeownership Counseling
Department specific requirements
 Eminent Domain is prohibited
 Minimize settlement costs
 Temporary Relocation only
                                     59
Break Time!




              60
NSP Specific Topics


Florida Housing Coalition




                            61
Lunch!




         62
Q&A




      63
Application Format and Information


            Mark Nixon
         Program Specialist




                                 64
    NSP Application Basics
Applications will only be accepted from
local governments listed in Florida’s NSP
Substantial Amendment to the 2008
Florida Small Cities CDBG Program Annual
Action Plan.

Must meet Citizen’s Participation
requirements as outlined in the NSP
Application Instructions and the NSP
Florida Emergency Rule.
                                        65
     NSP Application Basics
Submit two (2) applications to DCA with
original signatures by the applying local
government’s chief elected official or a
person designated with signature
authority by local government resolution.




                                            66
    NSP Application Basics
Mail one copy of the Application to the
Florida State Clearinghouse, Department
of Environmental Protection,
Commonwealth Building, Tallahassee,
Florida 32399.
A transmittal letter should accompany the
materials requesting that the
Clearinghouse send copies of any
correspondence to the Applicant and to
the Department of Community Affairs.
                                          67
     NSP Application Basics
One copy of the application must be sent
to the Regional Planning Council that
serves the applying local government.

Submit one copy of the Application to the
State Historic Preservation Office, Florida
Department of State, 500 South Bronough
Street, Tallahassee, Florida 32399-0250.

                                           68
     NSP Application Package
           (Outline of Application Package)

Cover Page – Include Name of Local
  Government Applying for NSP Funds
I. Applicant Information Sheet
II. Neighborhood Stabilization Plan
    (Overall strategy – tie to each Strategy (1 -5)
III. NSP Individual Strategies and
      Administration Page (Show Admin Budget %
     & Entities)
                                                  69
       NSP Application Package
            (Outline of Application Package)

IV. Assurances, Certifications and Signature
Attachments A (s) – six (6) required
    Must complete an Attachment A for each of the
    Five (5) Strategies Addressed (only for ones that
    are addressed)
    Overall Attachment A (ROLL-UP BUDGET)

Attachment B - Housing Assistance Plan (to be
  covered by Gail Stafford)
                                                  70
     NSP Application Package
         (Outline of Application Package)
Enclosures
    Maps
     May need one for each strategy
     Also need one overall map showing all
     locations of Activities (Strategy Areas)
   Interlocal Agreements (if applicable)
   Land Banking Strategic Plan
   (if applicable)
                                                71
 NSP Application Package Details
Applicant Information Sheet
   Applicant – Name of local government
   Jurisdictions to be served
   Applicant local government plus others that
   may receive assistance (May be Sub-
   Recipients)
   Indicate whether or not the jurisdictions or
   neighborhoods to be served are located in a
   flood plain.


                                             72
NSP Application Package Details
Applicant Information Sheet - continued
  Indicate whether or not compliance with
  federal and state historic preservation
  standards may be applicable.
  Flood plain and historic preservation issues will
  need immediate attention once an Award
  Agreement is executed by the Department.
  Applications preparer information
  Agency or firm or name of primary local
  government employee that prepared the
  application
                                                  73
NSP Application Package Details
 Overall Neighborhood Stabilization Plan
   Applications must include a narrative description
   of their overall Neighborhood Stabilization Plan.

   Should specify where large numbers of
   abandoned or foreclosed properties are located
   and whether or not the area identified will be
   addressed.

   If another target area is selected, provide
   justification as to why the use of the funds in
   such area(s) will make a more meaningful
   impact.

                                                       74
NSP Application Package Details
 Overall Neighborhood Stabilization Plan -
 continued
     Should tie to each of the five individual
     Strategies (ones addressed only).
     The Plan should describe all activities that
     are proposed to be undertaken, sources of
     any other funds, and when possible what
     parties the Applicant will work with to
     implement the Plan.
     Need map(s) that depicts all strategy
     areas.
                                                75
NSP Application Package Details
 Overall Neighborhood Stabilization Plan -
 continued
   As noted in the NSP Strategy descriptions in
   the application, each activity addresses either
   homeownership or rental or both
   homeownership and rental.
   Keep this in mind as you plan your project.
   All activities must meet the national objective
   of providing benefit to low, moderate and
   middle income persons and must be directly
   related to the Applicant’s overall strategy to
   address foreclosed and abandoned housing.
                                                 76
       NSP Application Package
             Individual Strategies
NSP Strategy 1: Housing acquisition/rehabilitation
of homes for sale to individuals and families with
incomes less than 120 percent of AMI (includes
some portions of strategy 2 per <50% AMI).
NSP Strategy 2: Housing finance
NSP Strategy 3: Establishing land banks
NSP Strategy 4: Demolition and
clearance/housing redevelopment
NSP Strategy 5: Housing acquisition/rehabilitation
of homes for lease to individuals and families with
incomes less than 120 percent of AMI (Includes Low
Income supplemental funds - 25% of total for
rental).
                                                   77
                                                  77
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1:
   Housing Acquisition/Rehabilitation of Homes
   for sale to individuals and families with
   incomes less than 120% of AMI (includes
   some portions of strategy 2; per <50% AMI).




                                             78
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1
   The purpose of this NSP strategy is to stabilize
   neighborhoods of greatest need by providing a
   means for the acquisition, rehabilitation,
   renovation, and subsequent provision of homes and
   other foreclosed or abandoned residential
   properties to individuals and families whose income
   does not exceed 120 percent of the area median
   income. (includes some portions of strategy 2; per
   <50% AMI).
   NSP sub-grantees will be required to work with
   lenders to acquire homes that have been foreclosed
   within the areas designated as having the greatest
   need.                                              79
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1 - Activities
 Indicate the Eligible Activities to be addressed by
 checking the following:
    _____24 CFR 570.201(a) Acquisition
    _____24 CFR 570.201(b) Disposition
    _____24 CFR 570.201(e) Public Services for
           housing counseling
    _____24 CFR 570.201(i) Relocation
    _____24 CFR 570.201(n) Homeownership
            Assistance
    _____24 CFR 570.202(a) Rehabilitation
                                                       80
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1
 (Items Below are for All Strategies)
   Indicate your total budget for this strategy.
   Indicate other funds committed for this
   strategy.
   Describe target area chosen (key to maps).
   Identify Non-profit or For-profit subrecipients
   or partners – include property management
   entities.
   Identify potential lending partners (if known).
   Potential counseling agencies (if known).
                                                 81
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1 - General
   Include a tentative timeline that, in general,
   reflects the start dates for each of the
   activities that will be conducted under the
   particular NSP strategy.
   Proposed accomplishments and beneficiaries
   by income level.
   A description of any unmet need that you
   wish to be taken into consideration should
   recaptured funds from another grantee or
   program income be made available for
   persons at or below 50 percent AMI.
                                                    82
NSP Application Package Details
            Individual Strategies
 NSP Strategy 1 – Timeline
   Activity (show tentative start dates)
   Identification of units for acquisition
   Appraisal of units
   Negotiation of price at closing
   Rehabilitation of units (if needed)
   Solicitation and qualification of buyers
   Closing


                                              83
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1 - Performance Measures
   All activities funded with State NSP funds
   must meet one or more of the following
   performance measures:
   Estimated units of housing to be acquired
   Estimated units of housing to be rehabilitated
   Estimated units of housing to be demolished
   Estimated units of housing to be sold
   Estimated parcel(s) to be acquired
   Indicate number of units by income ranges
     50% AMI and Below; 51-80%; 81-120%
                                                84
NSP Application Package Details
           Individual Strategies
 NSP Strategy 1 - For all Strategies,
 indicate as appropriate
   Unmet Need: Please describe any unmet
   need that you wish to be taken into
   consideration should recaptured funds from
   another grantee or program income be made
   available.
   Provide the Strategy
   Give approximate amount of funds needed

                                            85
NSP Application Package Details
            Individual Strategies
 NSP Strategy 2 – Housing Finance
   The purpose of this NSP strategy is to
   improve access to mortgage capital on flexible
   terms, maintain occupancy of foreclosed
   homes, facilitate property renovation, and
   help individuals and families access
   responsible credit and financing to promote
   homeownership by promoting long-term
   affordability.
   Indicate which activities you plan to
   undertake with NSP and/or other funding
                                               86
NSP Application Package Details
            Individual Strategies
 NSP Strategy 2 – Housing Finance – Activities
   _____24 CFR 570.206(g) Administrative
   expenses to facilitate housing
   _____24 CFR 570.201(n) Homeownership
   Assistance
   Administrative expenses for this do not count
   against total administration for the project
   These administrative amounts must be
   budgeted and tracked to allow auditing and
   monitoring
   Other items are the same
                                               87
NSP Application Package Details
            Individual Strategies
 NSP Strategy 3 – Establishing Land Banks
   The purpose of this NSP strategy is to
   improve access to mortgage capital on flexible
   terms, maintain occupancy of foreclosed
   homes, facilitate property renovation, and
   help individuals and families access
   responsible credit and financing to promote
   homeownership by promoting long-term
   affordability.
   Indicate which activities you plan to
   undertake with NSP and/or other funding
                                               88
NSP Application Package Details
            Individual Strategies
 NSP Strategy 3 – Establishing Land Banks -
 Activities
 _____24 CFR 570.201(a) Acquisition
 _____24 CFR 570.201(b) Disposition

 Justification for this strategy (estimated number
 of foreclosures, etc.).

 Justification for this strategy must include a
 land bank disposition plan if you intend to
 spend NSP funds on land banking
                                                  89
NSP Application Package Details
            Individual Strategies
 NSP Strategy 3 – Establishing Land Banks
   Activity list and tentative start dates should
   include identification of parcels for acquisition
   If acquired parcels have vacant units that will
   be demolished, indicate tentative date for
   demolition
   Appraisal of parcel
   Negotiation of price at closing
   Closing

                                                   90
NSP Application Package Details
           Individual Strategies
 NSP Strategy 3 – Establishing Land Banks
   Performance measures to indicate
     Estimated number of parcels
     Estimated units of housing or other
     properties to be demolished
     Estimated parcel (s) to be acquired




                                            91
NSP Application Package Details
            Individual Strategies
 NSP Strategy 4 – Demolition and
 Clearance/Housing Redevelopment
   The purpose of this NSP strategy is to turn
   vacant or blighted properties into productive
   use that will help stabilize a neighborhood
   which has been negatively impacted by
   foreclosures.
   Indicate which activities you plan to
   undertake with NSP and/or other funding


                                                   92
NSP Application Package Details
            Individual Strategies
 NSP Strategy 4 - Demolition and
 Clearance/Housing Redevelopment -
 Activities
 ____ 24 CFR 570.201 (a) Acquisition
 _____24 CFR 570.201 (b) Disposition
 _____24 CFR 570.201 (d) Clearance and
 Remediation (including housing replacement or
 new construction)
 _____24 CFR 570.201 (n) Homeownership
 Assistance
 _____24 CFR 570.201 (o) Counseling
                                                 93
NSP Application Package Details
            Individual Strategies
 NSP Strategy 4 – Demolition and
 Clearance/Housing Redevelopment - Timeline
   Identification of units for acquisition
   Appraisal of units
   If acquired units will be demolished, indicate
   tentative date for demolition
   If new construction will occur, indicate
   tentative date for completion
   Negotiation of price at closing
   Closing
                                                    94
NSP Application Package Details
            Individual Strategies
 NSP Strategy 5 – Purchase and
 Rehabilitation of Homes for Lease
   Housing acquisition / rehabilitation of homes
   for lease to individuals and families with
   incomes less than 120 percent of AMI.
   Funds for this NSP strategy must include all of
   the supplemental funding, but may also
   include the regular state allocation



                                                95
NSP Application Package Details
            Individual Strategies
 NSP Strategy 5 – Purchase and Rehabilitation
 of Homes for Lease
   The purpose of this NSP strategy is to turn
   foreclosed or abandoned properties into decent,
   safe and affordable housing for low, moderate
   and middle income individuals and families.
   This form must reflect the 25 percent set-
   aside for rental housing for households at
   or below 50 percent of AMI as well as for
   rental housing funded from the regular
   allocation that meets the income
   requirement.
                                                96
NSP Application Package Details
           Individual Strategies
 NSP Strategy 5 – Purchase and
 Rehabilitation of Homes for Lease -
 Activities
   Indicate which activities you plan to
   undertake with NSP and/or other funding:
   _____24 CFR 570.201 (a) Acquisition
   _____24 CFR 570.202 (a) Rehabilitation
   _____24 CFR 570.201 (b) Disposition
   _____24 CFR 570.201 (i) Relocation
                                              97
NSP Application Package Details
            Individual Strategies
 NSP Strategy 5 – Purchase and
 Rehabilitation of Homes for Lease -
 Timeline
   Identification of units for acquisition
   Appraisal of units
   Negotiation of price at closing
   Rehabilitation of units (if needed)
   Closing


                                             98
NSP Application Package Details
            Individual Strategies
 NSP Strategy 5 – Purchase and
 Rehabilitation of Homes for Lease –
 Performance Measures
   Enter estimated number of units that will
   benefit each income level:
   Estimated units of housing to be acquired
   Estimated units of housing to be rehabilitated
   Estimated units of housing to be demolished
   Estimated units of housing to be rented
   Estimated parcel(s) to be acquired
                                                99
      Administration Sheet
Administrative costs must be associated
with overall program management.
This does not include costs associated
with carrying out activities eligible under
Section II(B)(3)(b) regarding homebuyer
counseling or activity delivery costs.
Admin budget cannot exceed 6.8 %
Indicate potential subrecipients and /or
consulting firms

                                              100
  Assurances, Certifications and
           Signature
This section includes a list of federal regulations,
certifications of documentation, and other
assurances requires for submission with this
application.
The local government jurisdiction must certify the
validity and availability of statements and data
contained within the application.
Applications must contain original signatures of
the Chief Elected Official or individual authorized
by resolution to sign on behalf of the local
government.
If applicable, submit a copy of the resolution.
                                                   101
Completion of Attachment “A”
          Budgets
Each Recipient must submit a project
budget and proposed accomplishments
and beneficiaries for each
Activity/Strategy undertaken.

This information should be provided on an
Attachment A - Activity Form.


                                       102
Completion of Attachment “A”
          Budgets
Attachment A – Summary of all
Activities. This form should reflect the
total budget (and related information) for
all activities.
This form should also be used to tabulate
the overall proposed project
“ROLL-UP BUDGET”.


                                        103
 Completion of Attachment “A”
           Budgets
Activity – enter specific activities to be carried out
on the appropriate Activity form. After all forms
have been completed, summarize the information
on the Attachment A - Activity and Budget
Summary.
Accomplishments – Enter the unit of measure and
estimated number of units to be addressed.
Beneficiaries – Enter the estimated number of low,
moderate and middle income beneficiaries as
required for the activity. For Application purposes,
beneficiary information will be measured by
housing unit (HU). Actual beneficiaries will be
required for closeout and monthly reporting.
                                                   104
 Completion of Attachment “A”
           Budgets
Budget – Enter the amount of NSP funding that will
be allocated to the activity.
Enter the amount budgeted for overall program
administration separately (this amount should not
include project delivery costs).
Enter the amount of other funds that will be
allocated to the activity and identify the source of
the other funding.



                                                105
    Enclosures to Include
Maps as discussed
Interlocal Agreement
Strategic Plan for Land Banks (if applicable)
Identify any policies that the local government
currently has adopted that related to CDBG
(i.e., citizen complaint policy, acquisition and
relocation policy, fair housing plan,
procurement policy, revised housing assistance
plan, etc.).
These policies will be reviewed during the site
visit prior to execution of the Award
Agreement.
                                              106
    Administrative and Activity
         Delivery Costs
Overall program administration costs
cannot exceed 6.8 percent of the
allocation.
All activity delivery costs should be
included in a “non-administrative” activity
(i.e. rehabilitation, acquisition, disposition,
etc.) and should not be reflected as
overall program administration.


                                             107
      Activity Delivery Costs
To be eligible activity delivery costs, the activity
being "delivered" must be CDBG-eligible.
Activity Delivery Costs (for housing rehab and
construction) may not exceed 10% of the
housing construction budget.
DCA will expect all local governments that utilize
activity costs to make sure the activity delivery
costs are reasonable and can be justified.
Activity Delivery Costs will be monitored


                                                  108
Definition of Activity Delivery Costs
 “Activity delivery costs” are non-
 administrative costs which can be
 directly associated with and required
 for an eligible NSP activity and may
 Not exceed 10 percent of the housing
 construction budget.
 If paid to the developer, these costs shall
 be included in the developer fee.


                                          109
  NSP Policy


  Patrick Howard
Program Specialist




                     110
             NSP Policy
DCA’s NSP Policy Guide will outline
Florida’s parameters for applying for and
using Florida’s NSP assistance

NSP Policy Guide should be used in
tandem with NSP Emergency Rule, the
NSP Application and directions, Florida’s
NSP Amended Action Plan and the
October 6, 2008 Federal Register Notice to
implement your NSP Program

                                            111
             NSP Policy
Primary goal of buying and rehabilitating
foreclosed or abandoned residential
properties to be sold or rented to persons
from median to low, moderate and middle
income persons or families

Limitations placed on $$$’s for Activities
that do not directly achieve this primary
goal

                                             112
              NSP Policy
General summary of allocations
  Each local government has two allocations
    Regular NSP Allocation
    Low Income Supplemental Allocation – 25%
Citizen’s Participation
  One Public Hearing
  Advertised in local newspaper – 5 & 20 day
  rule applies
  One CATF
  15 day public comment

                                               113
              NSP Policy
Application Preparation and Submission
  Signed by Chief Elected Official or designee by
  resolution
  2 original Applications to the Department
  1 copy to Florida State Clearing House
  1 copy to Regional Planning Council




                                              114
                 NSP Policy
Application Preparation and Submission –
  Applicant Information Form included with Application
  Narrative that describes:
    A comprehensive, detailed description of each
    strategy the Applicant intends to undertake,
    including all proposed activities, their quantities
    and their costs.
    Estimated activity delivery tasks and their costs.
    Amounts of NSP and amounts and sources of non-
    NSP dollars (if applicable).
    Proposed project location(s) (if known).
    A list of potential Nonprofit or For-profit
    subrecipients (including Property Management
    Companies), Lending Partners, and Counseling
    Agencies (if applicable/known).                     115
                NSP Policy
Application Preparation and Submission
  Narrative that describes: - continued
    Justifications for selecting target area(s)
    Explanation as to why the Applicant proposes to
    undertake the NSP strategy(ies) (This justification
    should be somewhat different for each strategy)
    A tentative timeline that generally reflects the start
    dates for each activity that will be conducted
    under a particular NSP strategy
    Proposed accomplishments and beneficiaries by
    income level
    Unmet Need if applicant wishes to access
    Incentive Based Set Aside
                                                       116
              NSP Policy
Application Preparation and Submission
  Cost Standards should be prepared by a Real
  Estate Professional
  Procurement documentation if seeking
  reimbursement for application preparation
  Maps
  Interlocal Agreements or Memorandums of
  Understanding
  21 Day Clean Up


                                            117
               NSP Policy
Site Visits
  Will visit each Target Service Area
  Review of Policies
Environmental Review
  In line with HUD Requirements
  Technical Assistance will be provided at the
  NSP Implementation Workshop, the
  Department’s website and by contacting Judy
  Peacock and Tammy Anderson


                                             118
               NSP Policy
General Administration
  Up to 6.8% of allocations and reallocated
  program income can be used for Administration
  Choose team that you can finish on time with
  Be prepared to be flexible (special meetings,
  etc)
  At least annually monitoring for up to four years
  6 Year Retention of Records following Final
  Closeout
  Monthly reports and other reports outlined in
  subgrant agreement
  Annual Audits ($500,000 or more drawn down
  in Federal Funds)                              119
               NSP Policy
Activity Delivery Costs
  Are not Administrative Costs
  Up to 10% of Construction Costs (e.g. work
  write ups, inspections temporary
  maintenance, etc.)
Acquisition Costs –Charged to Acquisition
Line Item
  Are not considered Activity Delivery Costs
  Are cost associated with purchasing properties
  (e.g. appraisals, title insurance, site surveys,
  etc.
                                               120
                NSP Policy
Disposition Costs - Charged to Disposition
Line Item
  Are not Activity Delivery Costs
  Are costs associated with selling properties (e.g.
  appraisals, title insurance, recording fees, etc.
Developer Fees
  Allowable profit to entities that carry out eligible
  NSP activities
  No Developer Fees to Local Governments
  May not to exceed 12%
  Not Automatic - subject to Department’s review
  and approval
                                                   121
                NSP Policy
Taxes, Liens and Assessments
  NSP Subgrantees may not provide NSP assistance
  to another party to buy tax foreclosed properties
  from itself
  May use NSP for down payment assistance for
  buyers of tax foreclosed properties
  Local governments may not reimburse themselves
  for the value of tax liens
  Local governments may not use NSP to repay taxes
  that they levied – they must waive the tax lien
  If tax was levied by another jurisdiction or the
  State, then the subgrantee local government may
  pay the taxes owed
  NSP may not pay for impact fees                   122
              NSP Policy
Acquisition
  Focus NSP Plan toward primary goal of
  purchasing abandoned or foreclosed and
  make the same available at an affordable cost
  to people or families having low, moderate or
  middle incomes.
  Choose properties to buy that are in the
  Targeted Area of Greatest Need
  Choose properties to buy in a price range that
  will be affordable to sell or rent to eligible
  beneficiaries

                                              123
               NSP Policy
Acquisition - continued
  Choose properties with minimum issues that
  might delay the project
  Establish method to solicit list of foreclosed
  properties from banks, mortgage companies
  and entities such as Fannie Mae, FHA and
  HUD that are in the targeted area. This
  method must include advertising in a daily
  paper of general circulation
  Inform holders of properties that an average
  15% discount of the properties is mandatory

                                               124
              NSP Policy
Acquisition - continued
  May contact sellers directly as well
  Maintain spreadsheet that includes each home
  purchased
  URA applies with allowances for 15% discount
  No review appraisals are required, but
  Department supports
  Appraisals within 60 days of final offer



                                            125
               NSP Policy
Acquisition - continued
  Must appraise each property individually
  Appraiser must be state licensed or certified in
  good standing with the State of Florida
  Department encourages subgrantees to solicit
  for the services of more than one appraiser
  State NSP funds cannot be used in
  conjunction with properties that have been or
  will be acquired through eminent domain



                                               126
                NSP Policy
Rehabilitation
  Must meet or exceed Section 8 Housing Standards,
  local and state building codes after rehabilitation
  completed
  NSP can rehab units to be sold or rental units
  Local governments are required to have an NSP
  Housing Assistance Plan (HAP) – can be a modified
  existing HAP
  Department encourages using (and maintaining) a
  qualified list of capable licensed contractors
     Allow for inclusion throughout the process per 24
     CRF 85.36
     Publicly notice list for parties wishing to be
     included every 120 days
                                                     127
              NSP Policy
Rehabilitation – continued
  Department encourages limitations be set on
  number of units a single contractor can have
  ongoing at one time
  Rehabilitation using subgrantee’s staff must
  be approved first by the Department
  Governmental or non-profit entities may not
  compete in a competitive process for
  rehabilitation work
  NSP may be used to clear code violations,
  such as nuisance, trash and other
  environmental or health codes
                                             128
               NSP Policy
Counseling
  Homebuyers purchasing NSP assisted housing
  must complete 8 hours of home buyer
  counseling
  Counseling must be provided by a HUD
  approved housing counseling agency
  Certificates of completion should be maintained
  in files
  Prior homebuyer counseling may be considered
  with Department’s approval
  Home buyer counseling is the only public
  service activity that can be funded with NSP
                                               129
              NSP Policy
Housing Finance
  No more than 50% of purchase price can be
  provided for down payment assistance
  Non-profits contracting with a subgrantee to
  purchase homes that will be sold to eligible
  beneficiaries may be eligible for NSP financing
  assistance
  NSP funds may not be used to refinance
  existing mortgages to prevent foreclosure



                                               130
             NSP Policy
Land Banks
 Established to assemble, temporarily manage
 and dispose of vacant land with goal of
 stabilizing neighborhoods and redevelopment
 of property
 Must be in vicinity or in area that serves
 target area of greatest need
 Properties purchased with NSP for land
 banking must be maintained by the
 subgrantee or a designated nonprofit
 organization

                                           131
              NSP Policy
Land Banks - continued
  NSP funds may not pay for maintenance for
  land bank properties
  If you did not identify land banking in your
  NSP Intent to Apply and you wish to use NSP
  assistance for land banking, you should
  contact the Department for approval
  Land bank properties purchased with NSP
  must be used for CDBG eligible activities
  within 10 years


                                             132
                NSP Policy
Demolition and Clearance for Redevelopment
  Must justify that activity provides support to
  providing improved housing in targeted areas of
  greatest need
  Maximum of 5% of NSP Regular Allocation may be
  used for this activity
  May be non-residential property
  Must be in targeted areas of greatest need
  Must make the property productive (examples:
  multi-family housing, housing complex, housing
  assistance office, homeless or transitional shelters)
  May be redeveloped for non-residential uses
  (examples: public parks, or mixed residential and
  commercial use)
                                                     133
               NSP Policy
Affordable Housing
  Primary Goal is to reintroduce vacant and
  foreclosed housing to beneficiaries at or
  below 120% of area median income
  Property for sale or rent should be made
  affordable for the long-term for eligible
  beneficiaries
  Affordable for purchase means that
  beneficiaries can qualify for conventional
  loans
  May use down payment assistance or write
  down loans to assist beneficiaries in qualifying
                                                134
              NSP Policy
Affordable Housing - continued
  The 25% Supplementary Allocation must be
  used to provide rentals for beneficiaries who’s
  income is at or below 50% of area median
  income
  Affordable for rent means that rents fall
  within HUD allowances found at:

www.huduser.org/datasets/fmr/fmrs/index.asp?
 data=fmr08


                                               135
                NSP Policy
Affordable Housing - continued
  Minimum compliance is adopting HOME
  Program standards outlined at 24 CFR
  92.252(a). (c), and (f) as well as 92.254
  Must provide public notification of availability of
  affordable housing for sale or rent – within the
  Housing Assistance Plan
  Sale price shall not exceed purchase price plus
  hard costs
  No profit may be made on sell of property,
  except reasonable developer fee (if applicable)

                                                   136
             NSP Policy
Affordable Housing - continued
  No adjustable rate mortgages – fixed for at
  least 15 years
  No subprime mortgages
  No permanent relocation
  Temporary relocation may not exceed one
  year
  Subgrantee must have Anti Displacement and
  Relocation Policy


                                           137
              NSP Policy
Affordable Housing
  Ensure long term affordability with Deed
  Restrictions and Mortgages
  Periods of affordability must meet or exceed
  those of HOME Program
    Under $15,000 in NSP = 5 Years
    Between $15,000 to $40,000 in NSP = 10 Years
    Over $40,000 in NSP = 15 Years
    New housing construction = 20 years
  Subgrantee may lengthen periods of
  affordability

                                                   138
              NSP Policy
Recapture of Unobligated Funds
  NSP funds not obligated at 10 and 15 month
  intervals following the signing of the
  agreement between HUD and the Department
  will be recaptured and placed in Incentive
  Based Set-Aside
Recapture of Unspent Funds
  NSP funds not expended within allowable
  grant period and extensions are subject to
  recapture


                                               139
               NSP Policy
Incentive Based Set Aside
  Set aside to hold recaptured funds accessed by
  subgrantees that obligate and spend their initial
  allocations expeditiously
Program Income
  All income earned as a result of NSP assistance
  must be returned to the Department
  Department will reallocate based on greatest
  need and capacity to obligate
  Return to Department within 7 days of receipt
  Program Income received after 6-30-2013 will
  go back to HUD
                                                 140
              NSP Policy
Definitions

Rules and Regulations

Appendices




                           141
Break Time!




              142
CDBG Program Highlights
    Housing Assistance Plans


             Gail Stafford
Grants Management Unit Planning Manager




                                      144
NSP Housing Assistance Plan

                 Purpose
Outlines local government’s program
Modifications require DCA approval
Provides the who, what, when, where and
how



                                     145
NSP Housing Assistance Plan

NSP HAP must be submitted with
application
Must include criteria in NSP Application
Instructions
Minimum requirements




                                           146
NSP Housing Assistance Plan

         Department Expectations
Clear and concise
Meet needs of the area
Stick to it!!




                                   147
NSP Housing Assistance Plan

Terms of Assistance
  Who can apply
  What type of assistance is available
  How assistance will be made available




                                          148
NSP Housing Assistance Plan

Process for Conflict of Interest
Rehabilitation Standards




                                   149
NSP Housing Assistance Plan

             Acquisition
Appraisals
Negotiating with bank
Ordering environmental assessment
Title search
Closing


                                    150
NSP Housing Assistance Plan

             Disposition
Marketing
Qualifying potential homebuyer
Working with lender
Show home to prospective buyer
Handle sale to homebuyer


                                 151
NSP Housing Assistance Plan

     Homeownership Assistance
Type of financing
Terms of financing
Maximum amount of assistance




                                152
  NSP Housing Assistance Plan

       Homeownership Counseling

NSP-assisted homebuyers must receive 8
  hours.
Florida HUD-approved housing counseling
  agencies.


                                          153
  NSP Housing Assistance Plan

NSP HAP should be a living, working
  document.
Provides guidance for subrecipients
Tailored for your program




                                      154
Citizen Participation, Fair Housing &
         Equal Opportunity

             Mark Nixon
          Program Specialist




                                   155
Basics of Citizen Participation
Citizen participation, including the participation of
stakeholders or affected municipalities, is an important
part of the application process.

Applicants must conduct a public hearing on the
proposed application prior to submitting it to the
Department.

Must meet Citizen Participation requirements as outlined
in the NSP Application Instructions and NSP Florida
Emergency Rule.


                                                           156
NSP Citizen Participation Basics

Florida NSP Applicants are required to
hold no less than one public hearing
regarding NSP assistance prior to the
submission of their NSP Application.




                                         157
NSP Citizen Participation Basics
A notice of the public hearing, in a local
newspaper serving the applying local
government, must be advertised at least
five (5) days and no more than twenty
(20) days prior to the public hearing.
A period of fifteen (15) days following the
public hearing must be allowed for public
comment prior to the submission of the
NSP Application to the Department.
                                          158
NSP Citizen Participation Basics
At least one meeting of the Citizen’s
Advisory Task Force (CATF) must take
place prior to submission of the NSP
Application.
Local governments shall meet the Citizen’s
Participation Plan adopted by the Florida
Department of Community Affairs.
Citizens, potential partners, potential
subrecipients, lenders, mortgage holders
and contractors should be encouraged to
attend public meetings.
                                        159
            Fair Housing
Note concerning direct or Entitlement
grantees: Each grantee eligible for an NSP
grant already receives annual CDBG
allocations, has carried out needs
hearings, has a consolidated plan, an
annual action plan, a citizen participation
plan, a monitoring plan, an analysis of
impediments to fair housing choice, and
has made CDBG certifications.
                                         160
   Provision for Small Cities
Local Governments in Florida that have
received and carried out a previous Florida
Small Cities CDBG Grant will meet the
basic requirement for Fair Housing if the
local government has already been
through the process of developing a Fair
Housing Ordinance, (which includes a
previous analysis of impediments to fair
housing).
                                         161
 Affirmatively Furthering Fair
           Housing
Nothing in this notice may be construed as
affecting each grantee’s responsibility to carry
out its certification to affirmatively further fair
housing.
HUD encourages each grantee to review
its analysis of impediments to fair housing
choice to determine whether an update is
necessary because of current market
conditions or other factors

                                                 162
   Fair Housing Certification
Affirmatively furthering fair housing. The
jurisdiction certifies that it will affirmatively
further fair housing, which means that it will
conduct an analysis to identify impediments to
fair housing choice within the jurisdiction, take
appropriate actions to overcome the effects of
any impediments identified through that
analysis, and maintain records reflecting the
analysis and actions in this regard.

                                                    163
Civil Rights – Antidiscrimination

Compliance with antidiscrimination laws.
The jurisdiction certifies that the NSP
grant will be conducted and administered
in conformity with Title VI of the Civil
Rights Act of 1964 (42 U.S.C. 2000d), the
Fair Housing Act (42 U.S.C. 3601–3619),
and implementing regulations.


                                        164
Procurement


   Mark Nixon
Program Specialist




                     165
   Procurement Under NSP

As applies to the Neighborhood
Stabilization Program in Florida Small
Cities CDBG Program Administered by the
Florida Department of Community Affairs




                                      166
       Procurement Notes

Establish method to solicit list of
foreclosed properties from banks,
mortgage companies and entities such as
Fannie Mae, FHA and HUD that are in the
targeted area.
This method must include advertising in a
daily paper of general circulation

                                        167
    Procurement Notes:

Appraisers need to meet specs of banks,
underwriters and Fannie Mae
Appraiser must be state licensed or
certified in good standing with the State
of Florida
Department encourages subgrantees to
solicit for the services of more than one
appraiser

                                       168
       Procurement Notes:

Acquisition Costs – charged to Acquisition
Line Item
Are cost associated with purchasing
properties (e.g. appraisals, title insurance,
site surveys, etc.
Disposition Costs - charged to Disposition
Line Item
  Costs associated with selling properties (e.g.
  appraisals, title insurance, recording fees,
  etc.)                                          169
 Procurement of Professional Services

If not using CDBG funds – no review
If using CDBG funds:
   9B-43, Fla. Admin. Code (state rule)
   287.055, Florida Statutes (engineers)
   24 CFR 85.36 (HUD regulation)
   local CDBG procurement policy
Separate procurement for each service by
each grant
                                           170
  Procurement of Professional Services
Reviewed within 90 days of contract execution
If procurement does not comply:
  Use local funds to pay for contract; or
  Bring into compliance
Application services covered if CDBG will pay
Public notice critical (9B-43, FAC)
  MSA newspaper or at least 3 firms evaluated
  At least 12 days notice
  Separate evaluations for separate services
  CDBG identifier (grant number or cycle)

                                                171
  Procurement of Professional Services
           287.055, Fla. Statutes (CCNA)

Engineers & architects (and some others)
  Not grant administration
  “Design-build” contracts covered
  “Construction manager” contracts not covered
No price info before negotiations (don’t ask, don’t
accept)
Cannot reconsider firm after ending final
negotiations
Conduct “detailed cost analysis”
  Federal reg: “cost analysis”
                                                  172
 Procurement of Professional Services
    24 CFR 85.36 (Procurement Types)

Small Purchase
  Local CDBG procurement policy may have low
  threshold

Competitive Bids
  If price is primary consideration & can clearly
  define requirements


                                                    173
 Procurement of Professional Services
    24 CFR 85.36 (Procurement Types)

Competitive Negotiation
  When qualification is primary consideration
  Price must be evaluation factor, unless CCNA
  applies

Non-competitive
  Only in certain situations with DCA approval


                                                 174
Procurement of Professional Services
               24 CFR 85.36

Competition is most important review
issue
  If procedure undermines competition,
  rejection likely
  No local preference; geographic preference
  only for engineers

 All evaluation criteria must be publicized
  Cannot be deviated from during evaluation

                                               175
Procurement of Professional Services
               24 CFR 85.36

Evaluation factors:
 Relevant?
 Measurement?
 Price must be a factor, except for engineers &
 other 287.055, F.S.

Ranking procedure raw points?
 Other procedure?
 Can procedure be manipulated?

                                             176
  Procurement of Professional Services

Elected officials role vs. evaluation
committee?
  Elected officials can’t change rankings unless they
  score
  Evaluation committee can be used to “short list”
  top 3-5

Ranking – only establishes order of
consideration
  Must negotiate price
  If no price agreement, move on to next highest
  ranked firm
                                                 177
  Procurement of Professional Services

Must always conduct either price or cost
analysis
  Price analysis only if price was an evaluation
  factor
  Price analysis is “bottom line” & needs other
  prices for comparison
  Cost analysis when no prices obtained, including
  single/sole source
  Cost analysis: labor hours & cost, indirect,
  expenses, and profit
  Cost analysis presumes some knowledge of effort
  required
                                               178
             Conflict of Interest

See 24 CFR 85.36 (b) (3)
  Includes: employee, family members, partner,
  “about to employ”
  See112.312(21), Fla. Stat. for who is “related” to
  create conflict

No participation of any kind at any stage
  RFP, evaluation, award, administration

No waiver possible
  Disclose conflict & step aside; otherwise, no
  CDBG funding for contract
                                                  179
                Review Issues
Improper Public Notice
  Ad less than 12 days; ad not in MSA paper & less
  than 3 firms
  Inability of firm to obtain RFP information in
  timely manner
Improper evaluation factor
  Local preference, location (except for engineers)
Evaluation inconsistent with identified factors
Can’t document selection based on RFP factors
Mixing “unlike services” into one evaluation
                                                  180
Other Required Policies &
       Procedures

       Patrick Howard
     Program Specialist




                            181
 NSP Other Policies and Procedures
Activity Budget Parameters
  Land Banks – Limited to up to 10% of State’s
  Allocation
  Demolition, Clearance and Redevelopment – up to
  5% of Regular Allocation
  Down Payment Assistance – no more than 50% of
  purchase price
  Program Administration – up to 6.8% of allocations
  and reallocated Program Income received
  Developer fees may be no more 12% of allocations
  and reallocated Program Income received
  Activity Delivery Costs may not exceed 10% of
  construction costs for rehabilitation
  NSP assistance cannot be used for Impact Fees
                                                  182
 NSP Other Policies and Procedures

Adopted Policies You Will Need
  Housing Assistance Plan (HAP) for NSP
  Anti-Displacement and Relocation Policy if anticipating
  temporary relocation
  Citizen’s Participation Plan
  Complaint Policy (may be incorporated into the
  Citizen’s Participation Plan)
  Community Development Plan
  Citizen’s Advisory Task Force
  Fair Housing Ordinance
  Affirmative Action Plan
  Anti Displacement and Relocation Plan
  CDBG Procurement Policy
                                                      183
 NSP Other Policies and Procedures

Helpful Tools
  Florida’s NSP Emergency Rule
  Florida’s NSP Application and Directions
  Florida’s NSP Policy Guide
  Florida’s NSP Substantial Action Plan Amendment
  October 6, 2008 Federal Register Notice




                                                    184
 NSP Other Policies and Procedures

Other Rules and Regulations
  24 CFR Part 85.36 - Procurement
  Florida Statutes 287 - Procurement
  CDBG Regular Rule 9B-43.0051(4) - Procurement
  24 CFR Part 58 - Environmental
  49 CFR Part 24 – Uniform Relocation Act (URA
  24 CFR 92 - Affordability
  24 CFR 570.489 – Program Income
  OMB Circular A-87 – Local governments providing
  labor for rehabilitation
  OMB Circular A-122 – Non-profits providing labor
  for rehabilitation
                                                     185
NSP Other Policies and Procedures

Remember
 Must conduct an annual Fair Housing Activity
 NSP will be monitored at least annually for up
 to 4 years
 Each home owner assisted with NSP must
 complete 8 hours of counseling from a HUD
 approved counseling agency




                                            186
NSP Other Policies and Procedures

Remember
 Those wishing to access the Incentive Based
 Set Aside must include Unmet Need
 (additional accomplishments beyond those
 committed to for regular and supplemental
 allocations) in their application
 The Department can adjust a subgrantee’s
 Regular Allocation to ensure that 25%
 supplemental allocation is be expended for
 assistance toward rentals for beneficiaries at
 or below 50% of area median income
                                             187
NSP Other Policies and Procedures
Remember
 NSP may not be used when obtaining
 property by eminent domain
 NSP may not be used for activities to prevent
 foreclosures
 No adjustable mortgage - Must be fixed
 mortgages for at least 15 years
 No subprime mortgages




                                            188
NSP Other Policies and Procedures
Remember
 No activities that will result in permanent
 relocation – temporary relocation acceptable
 (1 year)
 Build partnerships with local Public Housing
 Authorities and local non-profit organizations
 (with 5 years experience) to implement and
 manage rental portion of NSP program
 Establish and utilize contractor, appraiser,
 realtor, and lending institution lists


                                             189
 NSP Other Policies and Procedures
Helpful Websites
  Department’s NSP Site
  www.floridacommunitydevelopment.org/cdbg/NSP.cfm
  HUD Main Page on NSP
  www.hud.gov/offices/cpd/communitydevelopment/programs/nei
  ghborhoodspg/
  HUD User NSP Data Site
  www.huduser.org/datasets/nsp.html
  Fair Market Rents (subject to change)
  www.huduser.org/datasets/fmr/fmrs/index.asp?data=fmr08
  Income Limits (subject to change)
  www.huduser.org/datasets/Section8Limits_50_120.xls
  Housing Counseling
  www.hud.gov/offices/hsg/sfh/hcc/final.pdf
  Excerpt from Housing and Economic Recovery Act
  www.hud.gov/offices/cpd/communitydevelopment/programs/nei
  ghborhoodspg/hera2008.pdf
                                                         190
Uniform Relocation Act (URA)


         Patrick Howard
       Program Specialist




                               191
    Uniform Relocation Act & NSP
URA applies for activities involving NSP
Florida’s NSP does not allow property to be
acquired using eminent domain
Florida does not allow NSP to be used for
activities that involve permanent relocation
NSP may provide assistance for temporary
relocation and moving fees
Voluntary sale notifications must be given (even
to banks, mortgage companies, etc.)
Move in notices must be given to tenants that
will be staying temporarily in NSP assisted units

                                               192
   Uniform Relocation Act & NSP
An appraisal must be conducted by a state
licensed or certified appraiser for each
property acquired with NSP
A review appraisal is not required, but is
an eligible NSP cost
Negotiations for purchase or property with
banks, mortgage companies or lending
institutions must allow for percentage
discounts to purchase prices


                                        193
Q&A




      194
        For More Information
               Visit our website at:
www.floridacommunitydevelopment.org/cdbg/NSP.cfm

              Call the Department at:
                    850.487.3644

   Join Us for the Upcoming NSP Conference Call
             Friday, February 27, 2009
                    10:00 AM EST
    Access information will be emailed to today’s
                       attendees

                                                    195
END




      196
The Neighborhood Stabilization Program
    Housing and Economic Recovery Act of 2008


                   Orlando, FL
                February 19, 2009
198
REHAB / Manufactured Homes /
  Green Tech INFORMATION
SUMMARY INFORMATION ON
    REHABILITATION




                         200
I. Rehabilitation Standards
HERA provides that any NSP-assisted
rehabilitation of a foreclosed-upon home
or residential property shall be to the
extent necessary to comply with
applicable laws, codes, and other
requirements relating to housing safety,
quality, and habitability, in order to sell,
rent, or redevelop such homes and
properties.

                                               201
      Rehab Standards
               Continued


This imposes a requirement that does not
exist in the CDBG program. This means
that each grantee must describe or
reference in its NSP what rehabilitation
standards it will apply for NSP-assisted
rehabilitation. HUD / DCA will monitor to
ensure the standards are implemented.
                                        202
HERA defines rehabilitation to include
improvements to increase the energy
efficiency or conservation of such homes and
properties or to provide a renewable energy
source or sources for such homes and
properties. Such improvements are also eligible
under the regular CDBG program.
HUD strongly encourages grantees to use
NSP funds not only to stabilize
neighborhoods in the short-term, but to
strategically incorporate modern, green
building and energy-efficiency
improvements in all NSP activities to
provide for long-term affordability and
increased sustainability and attractiveness
of housing and neighborhoods.

                                             203
HUD References to Manufactured
           Housing
FANNIE MAE Announcement 03-06
June 3, 2003
24 CFR 3280




                                204
Announcement 03-06 June 3, 2003
Fannie Mae
Amends these Guides:

Selling and Servicing Mortgage
Eligibility and

Servicing Procedures for Mortgages
Secured by Manufactured Homes


                                     205
Announcement 03-06 June 3, 2003
This Announcement restates existing
requirements and incorporates new
requirements related to the definition of a
manufactured home, identification of
loans, property eligibility, mortgage
eligibility, underwriting, pricing
adjustments, appraisal requirements, and
servicing.
In addition, for the first time we are
providing information related to titling
manufactured homes as real property.
                                              206
 Definition of a Manufactured Home
             (FANNIE MAE)
Any dwelling unit built on a permanent
chassis and attached to a permanent
foundation system is a “manufactured
home” for purposes of Fannie Mae’s
guidelines. Other factory-built housing
(not built on a permanent chassis), such
as modular, prefabricated, panelized, or
sectional housing, is not considered
manufactured housing and continues to be
eligible under the guidelines stated in the
Selling Guide.

                                         207
                24 CFR 3280
This final rule establishes new Model Manufactured
Home Installation Standards (Model Installation
Standards) for the installation of new manufactured
homes and includes standards for the completion of
certain aspects necessary to join all sections of multi
section homes.
This final rule also incorporates certain amendments
to definitions contained in the Manufactured Home
Construction and Safety Standards (MHCSS) that are
affected by definitions provided in the Model
Installation Standards.

                                                    208
       Florida Provisions

Manufactured Housing under Department
of Highway Safety and Motor Vehicles
Simple Code on Repair and Remodeling
(Rehab) of Manufactured Housing
“Nothing more and Nothing Less”
than original Construction.


                                    209
    Florida Rehab Standards
Repair and Remodeling – F.S. 320.8232 (2)
covers provisions for the repair and remodeling
of mobile homes. F.A.C. Rule Chapter 15C-
2.0081 gives guidelines for the repair and
remodeling of mobile homes. The rule basically
states that the repair and remodeling shall not
be more stringent than the standard to which
the home was originally constructed.


                                              210
Permanent Installation – F.S. 320.822
defines “Setup” or “installation” as the
operations performed at the occupancy site
which render a mobile home or park trailer fit
for habitation. Although, it does not mention
setup as a permanent foundation, we have
always considered dry stacked block piers and
anchors and tie-downs as a permanent
installation. This seems to be verified by
F.S.320.015 Taxation of mobile homes and F.S.
320.0815 Mobile homes and recreational vehicle-
type units required to have appropriate license
plates or stickers. Both statutes cover taxation
and fees only when a mobile home is
permanently affixed to the land.

                                              211
Florida Implementing Regulations
Real Property – F.S. 320.015 defines the
process of a mobile home becoming real
property.
Taxes – F.S. 320.15 and F.S. 320.0815
both cover taxation and fees of mobile
homes.




                                         212
Licensing Requirements – F.S.
320.8249 describes all licensing
requirements and the authority of the
Department of Highway Safety and Motor
Vehicles over the installer licensing
program.




                                     213