National Community Development AssociationJune 2015

CPD Policy Update: CDBG

CDBG Funding in FY 15

• $3.066b - $66m for Indian CDBG = $3.0b for formula• vs. $3.03b for FY14. Roughly a 1% decrease• Formula allocations announced 2/10/15• Net increase of 8 new entitlements, but virtually no

effect on allocation amounts for existing grantees• FY 15 grants computed using 2008-2012 ACS data vs.

to 2007-2011 ACS date for FY 14 allocations - every grantee’s data will change slightly every year in comparison to every other grantee’s data

• Median change in CDBG allocations = -0.8%

Submitting FY 15 Action Plans

CPD Notice 14-015: Don’t submit your action plan until allocations announced & you can include the actual allocation amount in your plan. Expect this will become permanent policy

Most grantees submit a new 3-5 year Con Plan in ’15

Must use eConPlan Suite to submit electronically

HOME Consortia members cannot submit their CDBG plan before the lead member submits the ConPlan

6/3/15 FR Notice –comment on making this permanent

FY 15 Appropriation Provisions

20% cap on planning + PACs No exchanging of funds among units of government Eminent domain prohibition for e.d. New provision for ‘15: Underwriting is now

mandatory for e.d. assistance to private for-profit businesses

o HUD will issue a CPD Notice providing implementation guidance on this new provision

• Grant Agreement Special Conditions updated

FY 16 Budget

President’s Budget• CDBG $2.8 bil• Section 108 $300 mil auth’y• HOME $1.06 bil, includes

$10 mil for SHOP• HOPWA $332m• Homeless $2.480b: $2.223b

CoC; $250m ESG; $7m HMIS T.A.

House Committee• CDBG $3.0 bil• Section 108 $300 mil• HOME $900 mil; $10 mil for

SHOP in another budget line; zeroes out HTF

• HOPWA $332 mil• Homeless $2.185 bil: CoC

$1.905 b; $250m ESG; $5m HMIS TA

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FY 16 – Administration Budget

Pursuant to the Moving CDBG Forward initiative of 2013, HUD anticipates submitting a legislative reform package to Congress: grantee eligibility, aligning program cycles, improving grantee accountability, increasing State colonias set-aside to 15%, other state program changes

FY 16 – Administration Budget

Joint HHS/HUD Upward Mobility Initiative Proposal: • Allow up to 10 states, localities or consortia to blend

funding across 4 programs: SSBG, CSBG, CDBG, HOME• In exchange for more accountability for results, ability

to use the funds beyond the current allowable program purposes, to implement evidence-based/ promising strategies for helping individuals succeed in the labor market and improving economic mobility, children's outcomes, and the ability of communities to expand opportunity

FY 16 – Administration Budget

Upward Mobility Initiative Proposal: • Participating communities would be eligible to

receive up to $300 million per year over five years through the HHS Social Services Block Grant to support implementation of the pilot projects

Build America Initiative

• Presidential Initiative launched July 2014• Facilitate partnerships among Federal, State and local

governments and private sector investors to increase investment in infrastructure

• 1/16/15 Presidential Memorandum: “Expanding Federal Support for Predevelopment Activities for Nonfederal Domestic Infrastructure Assets” - Directs Federal to actively support construction predevelopment work

CDBG is a valuable resource to communities for pre-construction work

Build America Initiative

• May 2015 Federal Resource Guide for Infrastructure Planning and Design http://portal.hud.gov/hudportal/documents/huddoc?id=BAInfraResGuideMay2015.pdf

• Numerous postings on HUD’s blog, The HUDdle: http://blog.hud.gov/

• Additional information forthcoming

Broadband: The Electricity of the 21st Century

President’s Broadband Opportunity Council – Interagency council to speed up broadband deployment, promote adoption for our citizens, remove unnecessary regulatory & policy barriers to broadband build-out and competition

Commerce Dept. Broadband USA Initiative: online and in-person technical assistance to communities; regional workshops; publish guides and tools to address problems in broadband infrastructure planning, financing, construction, operations

Broadband: The Electricity of the 21st Century

https://www.whitehouse.gov/the-press-office/2015/01/13/fact-sheet-broadband-works-promoting-competition-local-choice-next-gener

HUD identifying ways to support Broadband initiative CDBG: public facilities, public services, economic

development

Section 108 Program Update

• 5/28 Public Offering closed: $391.8 mil• $ 500m loan guarantee authority for FY15• Previously, Congress appropriated credit subsidy for

§108 each year to cover potential defaults• HUD has never had to use this credit subsidy, but

each year must estimate the potential subsidy need• In FY 14 appropriations act, Congress directed HUD to

transition to a fee-based §108 program starting in FY 2015, to make the program budget-neutral

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Section 108 Program Update

Proposed Section 108 Fee Rule published in Federal Register on 2/5/15; comment period ended 3/9/15

Once rule is finalized, HUD will collect fees from borrowers to offset the costs of Section 108 loan guarantees. The fee in the first year is estimated to be 2.42% of the principal amount of the loan

Fee can be paid upfront, paid with CDBG funds, or paid with guaranteed loan proceeds.

TA forthcoming upon publication of final rule

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CDBG Policy Guidance Issued

• Activity Delivery vs. General Admin Costs (CPD Notice 13-07)• Closeout Instructions for NSP, CDBG-R, CDBG-DR, State CDBG,

Entitlement (CPD Notice 14-02)• Corrective Action for Violation of the Public Services and

Planning and Administration Caps (5/16/13 memo) – over-obligations must be reimbursed

• Transition to New Low/Moderate Income Summary Data (CPD Notices 14-10 & 14-11)

• Updated Survey Methodology (CPD Notice 14-13)• Code Enforcement Activities (CPD Notice 14-16) & webinar• FAQs

Future CDBG Policy Development

• Pursuant to Moving CDBG Forward, discussions regarding CDBG regulatory changes

• Rulemaking on new OMB “Omni Circular” Financial Management requirements (replaces HUD Part 84 & 85 regulations, OMB Circulars A-87, A-133, etc.)

• Rulemaking to implement Grant-Based Accounting for FY 15 grants & henceforth (elimination of FIFO drawdown process)

• AFFH Rule & Tool • Section 3 proposed rule – comments due 5/16

Neighborhood Stabilization Program

• NSP2 funds expire 9/30/15; waiver granted to certain grantees re Program Income

• HUD expects all NSP grants to be closed out within the next 3 years

• Technical Assistance is available to grantees on closing out grants

CPD Policy Update: Office of Special Needs Assistance Programs (SNAPS)

Overview of Presentation• Update on Status of Regulations• Achieving the Goals of Opening Doors –

Update on Progress• FY 2014 CoC Program Competition Results• FY 2015 CoC Program Competition• FY 2015 & FY 2016 Budgets and Implications

Status of the Regulations• Published Final Rules:

Defining Homeless – amendments to the SHP and S+C regulations• Published Interim Rules:

Emergency Solutions Grants Program with conforming amendments to the Consolidated Plan – Reopened for public comment on June 3, 2015–www.gpo.gov/fdsys/pkg/FR-2015-06-03/pdf/2015-13485.pdf

Continuum of Care Program – HUD intends to reopen for further public comments in the near future.

• Published Proposed Rules: Homeless Management Information Systems Rural Housing Stability Assistance Program

• Rules Pending Publication Final Rule Defining Chronically Homeless

Opening Doors: Federal Strategic Plan (Opening Doors):

There are four major goals in Opening Doors: 1. End chronic homelessness by 20162. End veteran homelessness by 20153. End family and youth homelessness by 20204. Set a path to ending all homelessness

The U.S. Interagency Council on Homelessness (ICH) is tracking the progress through HUD’s annual Point-in-Time (PIT) data

Worst case housing needs at a record-high 8.5 million households

Record levels of unemployment, and the worst recession in recent history

Sequestration, including decreased funding for homeless and rental assistance programs

Nearly 40% reduction in new admissions to the Housing Choice Voucher program

Despite challenges…

Reduced homelessness among Veterans by over 33% since 2010

Decreased chronic homelessness by over 16% since 2010

Significantly increased targeting of homeless people served through HUD rental assistance programs

Prevented homelessness for 1.3 million households through the Recovery Act

Significant progress…

Progress on Opening Doors

FY 2014 Funding Overview

Total Requested: $1.9 billion 8,553 Project Applications

Total Awarded: $1.8 billion 8,352 New and Renewal projects

Amount Awarded Represents: $102 Million New Projects (6%) $1.69 Billion Renewal Projects (93%)

FY 2014 and FY 2015 Budget (in millions) – Targeted Homeless Programs

• HUD is committed to making progress towards meeting the goals under Opening Doors

FY 2015 President's

RequestFY 2015

Appropriated

FY 2016 President's

Request

FY 2016 House

Proposed

Total Amount $2,406 $2,135 $2,480 $2,185Emergency Solutions Grants $215 $250 $250 $250Continuum of Care $2,184 $1,862 $2,223 $1,905HMIS $7 $7 $7 $5HUD-VASH $75 $75 $75 $75

FY 2014 CoC Funds

• Administered under the 2013-2014 CoC Program NOFA

• $1.83 Billion• Annual Renewal Demand (ARD)• Tier 1 – ARD minus 2% • Targeted PSH Bonus approximately $40 million

• CoCs are strongly encouraged to reallocate to interventions that reduce homelessness.

• CoCs may apply for High Performing Community (HPC) status for the first time.

• CoCs may apply for up to the full 3 percent of planning costs, or $1,250,000, whichever is less.

• CoC were allowed to merge, redistribute geographic areas, or split up until 5 days before the end of the CoC Program Registration period.

FY 2015 CoC Program

• HUD will continue the Tier 1 and Tier 2 funding process to promote a more competitive process between CoCs.

• CoCs will be required to rank all projects with the exception of planning, and if applicable, Unified Funding Agency (UFA) costs.

• CoCs will have the opportunity to apply for bonus projects, though no further details on project type are provided in the Notice.

• Collaborative Applicants can apply for UFA designation.

FY 2015 CoC Program

FY 2015 CoC Program CoCs may reallocate funds in whole or part from existing eligible renewal projects to create one or more new projects. CoCs may use reallocation to create:

• New permanent supportive housing projects that serve chronically homeless individuals and families, including unaccompanied youth;

• New rapid re-housing projects for homeless individuals and families, including unaccompanied youth, coming directly from the streets or emergency shelter or fleeing domestic violence;

• New projects for dedicated HMIS; and

• New Supportive Services Only (SSO) projects for centralized or coordinated assessment systems.

FY 2015 Budget

• $2.406 included in request for HAG• Includes funding for 37,000 new units of PSH

for chronically homeless• HUD intends to continue furthering the

policy priorities identified in the FY 2013 – FY 2014 CoC Program NOFA

Resources

• Up to date information regarding the McKinney-Vento Act programs, including a copy of the McKinney-Act amended by the HEARTH Act, the ESG interim rule, the CoC interim rule, and TA materials can be found at www.hudexchange.info

• Notification of the availability of future information will be released via HUD’s Homeless Assistance listserv. To join HUD’s listserv, go to www.hud.gov/subscribe/mailinglist.cfm and click on “Homeless Assistance Program”

Questions

Submit Questions to the HUD Exchange Ask-A-Question at:

www.hudexchange.info/get-assistance/my-question/

Due to the high volume of questions, please read the regulations and the training materials provided prior to

submitting your question to Ask-A-Question.