Status of HUD Notices
There are several HUD notices, pertaining to both the Neighborhood Stabilization Program and to programs created or funded through the American Recovery and Reinvestment Act (ARRA) that are currently pending. The publication of several of the notices has been delayed in the interest of insuring consistency among the various requirements associated with these programs. The following is a summary of the status of those notices and related activities, based on discussions between COSCDA and HUD staff.
CDBG-R : HUD is expected to issue a Notice concerning the use of the $1 billion in additional CDBG funds included in ARRA "imminently". Issuance of the guidance has apparently been delayed by "legal issues" most of which have now been resolved in discussions between HUD and the Office of Management and Budget (OMB). Grantees should be prepared for very specific direction with respect to use of the CDBG-R funds and for requests for some additional information beyond what is usually required for use of CDBG funds. There is considerable concern that CDBG-R funded projects must be consistent with the goals of the recovery bill as well as eligible under CDBG regulations. As a result, there will be a strong emphasis on accountability in examining whether grantees are achieving the intent of the legislation with respect to economic stimulus and appropriateness of the projects they choose to fund. In addition, all projects funded will be listed on Recovery.gov, the government-wide website established to describe and track recovery spending. HUD plans a series of webinars to discuss the use of the CDBG-R funding following publication of the notice. HUD Secretary Shaun Donovan may also provide advice to grantees in a letter expected to accompany grant notification letters for FY2009 CDBG funds. These letters are expected to go out before the end of the month.
Neighborhood Stabilization Program (NSP) : HUD is planning to release an NSP "Bridge" Notice which will include information on errors and omissions regarding the October 6, 2008 Federal Register Notice on the first round of NSP funding. It will also include guidance on changes to the first round of NSP funds resulting from the ARRA which authorized the second round of NSP funds. In addition, it will include HUD's responses to several requests for policy changes to the NSP by COSCDA and other housing groups. (See COSCDA's letter to HUD which includes these requested NSP changes at www.coscda.org.) Although COSCDA has expressed the importance of NSP grantees receiving this information as soon as possible to clarify eligible activity questions, HUD could not provide a firm date for when the Bridge Notice would be released, stating that it has been delayed partially due to preparation of the upcoming FY2010 HUD budget. HUD is also working on the Notice regarding the second round of NSP funds, which will be distributed competitively. The ARRA requires that this Notice be published by May 4, 2009. The Notice will address two pots of funds in this new round of NSP funding - $1.93 billion of regular NSP funds, and $50 million in competitive technical assistance funds to build local capacity to administer NSP programs.
Tax Credit Assistance Program (TCAP): HUD is in the process of finalizing its Notice regarding the Tax Credit Assistance Program (TCAP) authorized by ARRA. The Program will provide $2.25 billion to be used for gap financing for Low-Income Housing Tax Credit projects. HUD realizes that some tax credit allocating agencies have had little experience with meeting federal requirements which will apply to TCAP, such as Davis Bacon and Environmental rules, so HUD is planning to provide technical assistance to TCAP grantees that need this assistance. No specific date was provided for the provision of the technical assistance or for the release of the Notice.
Homelessness Prevention and Rapid Re-housing Program (HPRP): The Notice related to the Homelessness Prevention and Rapid Re-housing Program was issued on March 19, 2009, as required by ARRA. Grantees should be completing their Consolidated Plan substantial amendments to submit to HUD by May 18, 2009. According to HUD, all correctly completed substantial amendments will be reviewed by July 2, 2009. HUD will host nine 1 and ½ day technical assistance meetings during May and June for grantees and potential subgrantees to learn more about the HPRP and how it is to be administered. For dates and locations of these meetings, see http://registration.hudhre.info/hprp/training.nsf/content/index.html