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R&C Housing Notices

259th Edition: 10/21/2019-10/25/2019

News of Note

HUD Releases RAD Evaluation
On October 21, HUD released its evaluation of RAD's effectiveness. The evaluation reviewed tenant satisfaction, financial leveraging and physical condition improvements, among other benchmarks, and concluded that RAD significantly bolsters capital investment, increases tenant satisfaction, and substantially improves living conditions in public housing.

R&C Comments on NSPIRE Notice
On October 21, R&C provided comments on HUD's NSPIRE Notice, which outlined the proposal to completely reevaluate and replace the 20 year old REAC inspection protocol. HUD states that NSPIRE will focus on tenant unit conditions and health and safety concerns, and provide a more objective and streamlined evaluative model; however, preliminary NSPIRE deficiency definitions appear to add complexity. Additionally, HUD has yet to release the NSPIRE scoring algorithm, making it difficult to comment on significant aspects of the proposal. R&C also commented on the scope of the demonstration and encouraged HUD to explore means of reducing administrative burden.

Upcoming Events

Iyen Acosta to Present at NAHMA's 2019 Fall Conference
October 28, 2019

R&C Associate Iyen Acosta will speak on Fair Housing matters with a focus on unintentional discrimination at NAHMA's Top Issues in Affordable Housing Conference on October 28 in Washington, DC.

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Joseph Prochaska to Present at NCBJ's Annual Conference
November 2, 2019

R&C Of Counsel Joseph Prochaska will present "Avoiding Potential Ethical Traps in Unbundling, Factoring, and Other Fee Arrangements in Consumer Cases" at the National Conference of Bankruptcy Judges' (NCBJ) 93rd Annual Conference on November 2 in Washington, DC.

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Lisa Tunick to Participate in LeadingAge Maryland and DC #HousingHappenings Teleconference
December 18, 2019

R&C Member Lisa Tunick will provide a HUD Hot Topics Update during LeadingAge Maryland and DC's joint #HousingHappenings educational teleconference on December 18.

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Federal Register Notices

EIV Debts Owed to PHAs and Terminations: 30-Day Notice of Proposed Information Collection
October 25, 2019

Docket No. FR-7011-N-47

HUD seeks OMB approval to collect information about the number of families who owe a debt to a PHA and whose tenancy or assistance was terminated. The information sought includes the amount of debt owed, whether a repayment agreement exists, whether the tenant filed for bankruptcy, and the reason for any adverse termination. HUD intends to create a national repository of the requested information to assist PHAs when processing applications for rental assistance. Comments are due November 25, 2019.

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Application for FHA Insured Mortgages: 60-Day Notice of Proposed Information Collection
October 25, 2019

Docket No. FR-7014-N-26

HUD seeks OMB approval to update and revise HUD Form-92900-A to reflect regulations and other legal requirements, ensure accuracy of information provided to FHA, reduce uncertainty in the industry, maintain the ability to enforce FHA program requirements, and remove VA requirements and certifications from the form. Comments are due December 24, 2019.

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Multifamily Default Status Report: 30-Day Notice of Proposed Information Collection
October 25, 2019

Docket No. FR-7011-N-45

An additional 30 days of public comment are provided on HUD's request for OMB approval to implement an electronic means of collecting defaulted FHA loan information from lenders. HUD intends to use information reported via the Multifamily Delinquency and Default Reporting System as an early warning mechanism to work with project owners and lenders to develop a plan to reinstate a loan and avoid an insurance claim, and to provide HUD staff with a mechanism for mortgagee compliance per HUD's loan servicing procedures and assignments. Comments are due November 25, 2019.

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Ginnie Mae Mortgage-Backed Securities Guide 5500.3, Revision 1: 30-Day Notice of Proposed Information Collection
October 21, 2019

Docket No. FR-7011-N-44

HUD seeks OMB approval to collect various information from participants in the Ginnie Mae I and II Mortgage-Backed Securities programs. Comments are due November 20, 2019.

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