June 2019 Volume 1, Issue 1

Royal American Management

AFFORDABLE

COMPLIANCE QUARTERLY

NEW QUARTERLY NEWSLETTER Welcome to the first edition of the Affordable Compliance Quarterly Newsletter. This newsletter will

be an informative combination of updated rules and regulations, notices, tips, news, conference

schedules, a fun corner and more. We hope you enjoy this and look forward to hearing from you

with your feedback.

HUD AWARDS $1.5 BILLION TO SUPPORT

SEVEN STATES IN THEIR RECOVERY

FROM 2018 DISASTERS

Disaster recovery funds to repair damaged housing, businesses and infrastructure

WASHINGTON – The U.S. Department of Housing and Urban Development (HUD) to-

day awarded nearly $1.5 billion to support seven states in their recovery from major dis-

asters that occurred last year, including Hurricane Michael, Hurricane Florence and dev-

astating wildfires in California.

These funds are provided through HUD’s Community Development Block Grant –

Disaster Recovery (CDBG-DR) Program and will address seriously damaged hous-

ing, businesses and infrastructure in hard-hit areas of these states. The CDBG-DR Pro-

gram requires grantees to develop thoughtful recovery plans informed by local residents.

“Last year’s disasters left damaged homes, businesses and infrastructure in their wake,”

said HUD Secretary Ben Carson. “These recovery dollars will help the hardest-hit com-

munities in these states and allow for residents to put their lives back together again.”

On October 5, 2018, President Trump signed Public Law 115-254, which provides

$1.68 billion in CDBG-DR funding for “disaster relief, long-term recovery, restoration of

infrastructure and housing, and economic revitalization in the most impacted and dis-

tressed areas resulting from a major disaster declared in 2018.” In addition to the funds

being allocated today, HUD will allocate an additional $205 million later in the year fol-

lowing a comprehensive analysis of the recovery needs in American Samoa and the

Northern Marianas.

U.S. Department of Housing and Urban Development – Ben Carson, Secretary Office of Public Affairs, Washington, DC 20410 HUD No. 19-061 FOR RELEASE Brian Sullivan Tuesday 202-708-0685 May 14, 2019 http://www.hud.gov/news/index.cfm

INSIDE THIS ISSUE

Retro-Active GRC .................... 2

NAHMA & Literacy ................. 2

Citizenship/Noncitizen ........... 2

Verification of Eligible Status . 3

TRACS System Upgrade .......... 3

Utility Bills ............................... 4

2019 Hurricane Season ........... 4

SAHMA Webinars ................... 5

Carbon Monoxide .................... 5

Fun Page .................................. 6

Alexandria, Va., May 8, 2019 ― The National Affordable Housing Management Association (NAHMA) is promoting adult literacy by connecting affordable housing residents to a free app for improving reading and English skills. The app is available for download until Aug. 31. You can help spread the word by simply distributing flyers available on the Transforming Lives Through Literacy webpage under the About Us tab at nahma.org.

This effort is a result of NAHMA being named one of 24 finalists selected as a milestone award winner in the first phase of the Adult Literacy XPRIZE Communities Competition, which is the proposal stage of the competition. As a milestone winner, NAHMA moves onto the second phase, which consists of promoting the download and use of the free adult literacy learning app. Grand prizewinners will be announced in the fall.

“NAHMA is thrilled to have been named one of the winners in phase 1 of the XPRIZE adult literacy com-petition,” Kris Cook, CAE, NAHMA executive director, said. “We are uniquely situated to reach the low- to moderate-income Americans who are residents of affordable rental housing that are working hard to improve the financial status of their families. We believe they will be interested in taking advantage of the literacy app to improve their reading and English skills, since the app is free, self-supported and self-paced.”

To help NAHMA succeed in promoting adult literacy and demonstrating that housing is a platform for success, please distribute the English and Spanish flyers throughout your companies, communities and to on-site staff who can:

• Post the flyers on community bulletin boards or other visible locations

• Provide the flyers as handouts at special events at properties, such as English as a second language and financial literacy classes

• Include the flyers or information from them in community newsletters

• Send the flyers in broadcast emails to residents The free literacy app is self-supported and self-paced and is intended for all ages—from middle school through seniors—who may want to find better work, advance their education, help their children with homework or read stories with grandchildren. The app can be downloaded at https://abc.xprize.org/ac5588 until Aug. 31. The literacy app is available for Android devices only.

Improving literacy rates can boost labor productivity, cut billions of dollars in national health care costs and help break the cycle of poverty for families in every state. National Affordable Housing Management Association—NAHMA News

RETRO-ACTIVE GROSS RENT CHANGES (GRC) NOT PROGESSING IN TRACS AT THIS TIME

HELP NAHMA TRANSFORM LIVES THROUGH LITERACY

1. Issue/Problem

There is a recent system issue where cer-

tain retro-active (only) MAT70 GC

certifications are submitted, but no fatal

errors are returned/generated. Instead,

an internal programmatic system error

(PSFERR) is issued stating “Occurrence

of Certified Household already existed

when CREATE attempted. POTENTIAL

DATABASE CORRUPTION CONDITION

HAS BEEN DETECTED.”

2. GRC Problem Resolution

A Change Request (CR) has been created

and approved to address the issue, and

GRC processing issue will be implemented

on May 31, 2019.

3. Recommended Next Steps

Stakeholders should continue to submit

retro-active GRCs for TRACS

processing.

Beginning June 1, 2019, TRACS users

should login to WASS and check the

TRACS Certification Query to determine if

there are missing GRC transactions for

their specific rental assistance contract(s).

TRACS users will need to resubmit any

GRCs that failed TRACS processing

effective June 1, 2019, in order to be post-

ed to the system.

U.S. Department of Housing and Urban

Development

Office of Multifamily Housing

CITIZENSHIP/NONCITIZEN STATUS

Reminder: Owner/agents are to use the SAVE system to determine eligible noncitizens. If the owner does not have inter-net access, it will be necessary to verify immigration status using the paper process. DHS-approved documents listed in Figure 3-4 (HUD 4350.3 Chap-ter 3)can change. HUD 4350.3 Chapter 3 paragraph 3-12 page 3-36 E. Reviewing a Family’s Citizen-ship/Immigration Status Owners generally consider citizen-ship/immigration status once for each family, but they must do so more frequently if immigration status or family composition is likely to change (e.g., when a family member applies for a change in immigration status). (See Sample Owner’s Summary of Family in Exhibit 3-7 for tracking applicants’ declarations and the owner’s verification.) Roxy Munn, Inc.

2

HOUSING AND COMMUNITY DEVELOPMENT ACT OF 1980: VERIFICATION OF ELIGIBLE STATUS

Section 214 of the Housing and Community Development Act of 1980 (as amended) prohibits the Secretary of HUD from making financial assistance available to persons other than U.S. citizens or certain categories of eligible noncitizens in HUD’s public and specified assisted housing programs, including HUD’s Public Hous-ing programs, Section 8 Housing Assistance Programs, Housing Development Grant programs, the Rent Supplement Program, and Sections 235 and 236.

According to the proposed rule, HUD believes that the following amendments will bring its regulations into greater alignment with the wording and purpose of Section 214:

1. Verification of Eligible Immigration Status

The first proposed amendment would require that the eligible immigration status of all recipients of assistance under a Section 214 covered program who are under the age of 62 be verified through Sys-tematic Alien Verification for Entitlements (SAVE), which is administered by the Department of Home-land Security (DHS).

Current HUD regulations excuse individuals from submitting immigration status documentation if they do not contend to having eligible immigration status. This results in no actual determination of immi-gration status being made.

Under the proposed amendment to the rule, a current participant in a Section 214 covered program (with the exception of Section 235 assistance payments) who has not previously submitted evidence of eligible immigration status, will be required to do so at the first regular reexamination after the effective date of HUD’s final rule for this rulemaking. This typically occurs on an annual basis. For financial assistance in the form of Section 235 assistance payments, the mortgagor would be required to submit the required evidence in accordance with requirements imposed under the Section 235 Program. The proposed amendment to the rule would not change the timing of verification for new applicants to a Section 214 covered program.

2. Leaseholder Eligibility

The second proposed regulatory amendment would specify that individuals who are not verified in an eligible immigration status may not serve as the head of household or spouse (i.e., the holder of the lease).

Under the current regulations, the ‘‘do not contend’’ provision facilitates the indefinite use by a mixed family of prorated assistance. Further, it is possible under the current regulations for the holder of the lease to be ineligible under the Section 214 covered program for which the mixed family is receiving assistance.

HUD no longer agrees that a leaseholder, the individual who is contractually bound to the landlord and who holds conditional ownership of the unit for the lease term, can be exempted from having verified eligible immigration status.

Technical Nonsubstantive Changes

The proposed rule also makes a number of nonsubstantive (technical) changes to update terminology and formatting in the Section 214 statutory requirements. For example, the proposed rule would replace outdated references to the Immigration and Naturalization Service (INS) to refer to DHS.

Juliana Bilowich, Manager of Government Affairs National Affordable Housing Management Association 400 N. Columbus St., Suite 203, Alexandria, VA 22314 Phone 703-683-8630, ext.116 Email jbilowich@nahma.org, Website www.nahma.org

TRACS NOTIFICATION OF SYSTEM RELEASE/UPGRADE

This May 31, 2019, release/upgrade will improve data integrity, increase accessi-bility, and provide correct system pro-cessing.

1. The system will provide more flexible and accessible reports by export-ing to a standard text file format (.txt) instead of the proprietary .trx format.

2. ARAMS will ease processing by enabling the selection of multiple offices – including “select all” – for the Cancel Current Funds PAS Rejections list. The iText Attachment 14 has also been modi-fied to include the correct number of months supplied.

3. The Voucher system has been updated to more accurately address fatal errors VF040 and VF011 as follows:

Remove VF040 entry from the DB2 Reference table, F87PTVCHFA-TALERREF

Remove VF040 entry from the MAT Guide, Appendix E - TRACS Fatal Error Messages and Codes

Modify VF040 edit from LM310 procedure– Batch_Create_Shdw_Voucher_New

Generate fatal error message, VF011 (Miscellaneous request type is invalid; resubmit with valid request type), when voucher is submitted with SERV as Misc. Request Type in MAT 30 Section 6

The system will no longer generate discrepancies CE364 and CE258 if the certification is a new (initial) certifica-tion.

The system will be more flexible with the

generation of system emails to the

TRACS support/contractor team by

utilizing distribution list to accommodate

for future staff changes without code

modification.

Roxy Munn, Inc.

3

Can refusal to provide utility bills or sign a tenant release form so the O/A can collect bills directly from the Utility company be considered a lease vi-olation?

Answer: Yes.

Per HUD Notice H-2015-04, Section IX, Requirements for Tenant Households -

Tenants refusing to either provide Utility Bills or sign a release form constitutes material noncompliance with the lease agreement, as defined in the lease agree-ment, and repeated violations can result in termination of tenancy.

Further, for properties other than 236 and 221(d)(3), not providing requested information or signing the release form is a violation of the regulatory obligations of the family found at 24 CFR 5.659(b)(1).

To add clarity to the requirement, own-

ers are encouraged to include language in

their House Rules advising tenants of

their obligation to sign release forms and

to provide any information deemed

necessary in administration of the pro-

gram, or face possible termination. Any

changes to a property’s House Rules

must be done according to the proce-

dures outlined in HUD Handbook

4350.3, REV-1 paragraph 6-9

E3 Housing Solutions

2019 HURRICANE SEASON

• Andrea

• Barry

• Chantal

• Dorian

• Erin

• Fernand

• Gabrielle

• Humberto

• Imelda

• Jerry

• Karen

• Lorenzo

• Melissa

• Nestor

• Olga

• Pablo

• Rebekah

• Sebastien

• Tanya

• Van

• Wendy

The Atlantic hurricane season runs

from June 1 through November 30

with the most active month being

September. Be ready this year by:

Creating an emergency communi-

cation plan with your family before a

hurricane strikes. Know where to

meet in case you are separated.

Have emergency supplies that will

last for at least 10 days. Don’t forget

about needed prescriptions!

Ensure your insurance will cover

any possible damage caused by flood-

ing.

Be familiar with your local com-

munity’s evacuation plan and routes.

Know your evacuation zone.

Consider what you will do with

your pets if you have to evacuate.

Sign up for local emergency alerts.

Download the FEMA app.

Visit www.ready.gov/hurricane for

more important tips so that you are

prepared.

2019 STORM NAMES

4

5

EASY SOUTHERN BANANA PUDDING

20 Minutes Prep Time - 3 Hours 20 Minutes Total Time

• 3 Cups Cold Milk (whole or 2%)

• 2 packages (3.4 oz each) Vanilla Instant Pudding

• 30 Vanilla Wafers

• 3 Bananas, Sliced

• 1 Tub (8 oz) Cool Whip Whipped Topping, Thawed

1. Beat pudding mixes and milk with whisk for 2 minutes. Let stand for 5 minutes.

2. Arrange half of the wafers on the bottom and up the side of a 2 quart serving bowl; top

with layers of half each of the banana slices and pudding. Repeat all layers. Cover with

Cool Whip

3. Refrigerate for 3 hours.

Enjoy!