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By April Gancarz
Your Affordable Housing Program (AHP) project has been completed
and the residents have moved in. There have been problems along
the way but nothing that could not be handled. Suddenly, you receive
pages of items required from the Federal Home Loan Bank of Boston
(the Bank). Do you panic? No, of course not! Just follow the simple
steps below to ensure that your AHP monitoring requirements are
fulfilled.
Once an AHP project has been completed, the Bank prepares a closeout-monitoring
review. For ownership projects, the closeout review must be completed
within 12 months of the completion date. The Bank considers an ownership
project complete once the initiative's final mortgage closes and
the full AHP award has been disbursed.
For a rental development, the closeout review must be completed
within 12 months and 120 days of the completion date. Rental initiatives
are complete on the date a certificate of occupancy is issued or
the sponsor shows evidence that eligible tenants occupy 80 percent
of the development; all AHP funds must also be disbursed.
Once a project has been completed, both the member and the sponsor
receive a list of items to be returned to the Bank for review. This
list includes a sheet identifying the qualifying characteristics
for which the initiative received points and approval. The qualifying
characteristics serve as a check-off sheet for the closeout process.
If your project received points for the following characteristics,
supporting documentation must be returned to the Bank:
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Donated properties: Requires paperwork documenting the donation
of the property.
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Nonprofit sponsorship: Requires documentation providing evidence
of nonprofit status, for example, 501 c(3).
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Targeting: Requires a rent roll that includes the following:
home buyer/renter name, unit number, number in household, income
at move-in date, tenant-certification date, and the rent amount.
-
Homeless housing: Requires homeless certifications. If the
certifications are not available, please submit a letter from
the referral agency stating its involvement.
-
Empowerment: Requires a description of all services provided.
For example, if the project were awarded points for a residents'
council or membership on the board of directors, evidence of
the council's or board's formation, agenda, and participating
residents must be stated.
-
Special needs: Requires supporting documentation that clearly
identifies residents with special needs, for example, Americans
with Disabilities Act.
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First-time home buyers: Requires copies of home-buyer counseling
certificates or a home-buyer-education invoice.
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Member financial participation: Requires the commitment letter
and mortgage executed from the member institution.
-
Community involvement: Requires a description of all programs
that involve the residents.
-
Community stability: Requires a description of all community
actions provided by the initiative.
Please note that the Bank may ask for additional items to complete
the closeout process. The following information is required to complete
the monitoring review:
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Certificate of occupancy. All certificates must be returned.
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Final sources and uses.
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Evidence of the disbursement of funds.
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Cost certification/evidence of use. (This may include invoices
demonstrating the use of funds.)
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Affordability retention document. This is a recorded mortgage
or deed providing evidence of AHP funds in
the initiative.
-
Third-party income verification. This may include documentation
such as pay stubs, letter of verification from an employer,
and a W-2 form.
-
Affirmative marketing materials such as brochures, posters,
newspaper advertisements, etc.
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Photos. (We want to see all of that hard work!)
If applicable the following are also required:
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HUD-1(s).
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Audited financial statements and cost certificates.
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Reporting is an essential part of the affordable-housing-development
process. The purpose is to ensure that all initiatives comply
with AHP regulations.
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It is important to remember that this process is designed to
be as efficient as possible for everyone involved. If you have
any questions regarding the completion monitoring of your initiative,
please feel free to contact your community investment manager.
April Gancarz is housing and community investment compliance
analyst at the Federal Home Loan Bank of Boston.
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