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IHCDA CDBG Compliance Training. IHCDA Compliance and Asset Management Staff.

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Presentation on theme: "IHCDA CDBG Compliance Training. IHCDA Compliance and Asset Management Staff."— Presentation transcript:

1 IHCDA CDBG Compliance Training

2 IHCDA Compliance and Asset Management Staff

3 TODAYS WORKSHOP: 1.Will provide a brief overview of the chapters located within the Strategic Investment Process (SIP) Compliance Manual focusing specifically on CDBG. 2.Will focus on educating you on how these items will tie into the monitoring of your award. Letting you know what to expect and what we expect when we monitor. 3.Will be brief. As a recipient or potential recipient of CDBG funds, the expectation is that you will read, review, get familiar, and ask questions after the fact about things that you are unsure of for your award. 4.At the conclusion of this afternoons workshop will respond to any questions, comments, or concerns you may have.

4 CHAPTER ONE: POLICY REQUIREMENTS Strategic Investment Priority Requirements Compliance Auditor will check at monitoring to ensure threshold requirements were met Match/Leverage Requirements For CDBG, 10% of total funds drawn minus administration costs No requirement for CDBG-D Banked Leverage Only eligible on awards made in1999 or later Banked leverage generated on a CDBG or CDBG-D award cannot be used as match on a future HOME award Banked match generated on a HOME award may be used as leverage on a future CDBG or CDBG-D award Program Income Gross income received by a state, local unit of government, or a subrecipient that was generated from the use of CDBG funds Page 7 of the SIP Compliance Manual outlines what is considered program income and how it should be treated CDBG Public Hearing Requirements Required at application submission and program completion

5 CHAPTER ONE: POLICY REQUIREMENTS Legal notice(s) must be published (Sample notice found in Exhibit C) Copies of publishers affidavit(s), minutes, and sign-in sheet must be retained Rental Project Requirements Rent and Income Restrictions Utility Allowances Information regarding IHCDA utility allowances can be found on our website at Lease Language/Program Agreements Minimum requirements & prohibited language can be found on pages 11 – 12 of the SIP Compliance Manual Owner-Occupied Rehabilitation Requirements Eligible forms of ownership Fee simple title 99 year leasehold Condominium ownership Membership in a cooperative or mutual housing project Maintains an equivalent form of ownership approved by HUD Ineligible forms of ownership Life estates Land contracts/contracts for deeds Duplication of Benefits Certification (CDBG-D ONLY) Must be completed and kept on file for each beneficiary

6 CHAPTER TWO: LEAD BASED PAINT REQUIREMENTS The primary cause of childhood lead poisoning is deteriorating lead-based paint and lead-contaminated dust and soil in older housing units. Although lead was banned from residential house paint in 1978 by the Consumer Product Safety Commission (CPSC), an estimated 57 million older homes still contain some lead-based paint. In most cases, LBP work should be the highest priority for rehabilitation in a home. Key Items Brochures – ensure that the right people receive them and/or that they are posted in the appropriate location For contractors and subcontractors Lead Paint Safety – A Field Guide for Painting For homeowners and renters Protect Your Family from Lead in Your Home Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools For organizations The Runs Better Unleaded Poster must be displayed at the offices of the recipient, subrecipient, and administrator

7 CHAPTER TWO: LEAD BASED PAINT REQUIREMENTS Lead Hazard Testing and Clearance Process 1.Determine whether or not property is exempt from testing 2.Indentify the Approach to Lead Hazard Evaluation and Reduction Varies depending on the level of assistance to the unit 3.Conduct the Lead Hazard Evaluation Paint Testing Risk Assessments 4.Notify the occupant of the Lead Hazard Evaluation Must be notified within fifteen (15) days after the results have been determined 5.Complete Lead Hazard Reduction activities as directed according to the level of assistance and the results of the Lead Hazard Evaluation Safe Work Practices Paint Stabilization Interim Controls Abatement 6.Conduct the Lead Hazard Reduction and Clearance Test Must be conducted by a licensed lead-based paint inspector, risk assessor, or clearance technician

8 CHAPTER TWO: LEAD BASED PAINT REQUIREMENTS 7. Provide the occupant with the Notification of Hazard Reduction and Clearance Must provide occupants with the Notification of Lead Hazard Reduction and Clearance within fifteen (15) days of completion. 8. Complete and submit the Lead Form for Set-up and Clearance (see Chapter 12, Funds Management – CDBG-D, Exhibit C) Other things to consider Relocation On-Going Lead Based Paint compliance (rental only) Annual requirements regarding lead-based paint $25,000 in federal assistance triggers abatement Lead Hazard reduction activities that are part of the federal assistance do not count towards this limit Example - $27,000 in rehab work on home…..$10,000 of this $27K is related to lead reduction activities… this case only count $17,000.

9 CHAPTER THREE: ACCESSIBILITY Recipients cannot discriminate against an otherwise qualified individual with disabilities, solely by reason of his or her disability, with regards to participation in any program or activity receiving CDBG funds. This chapter defines the recipients responsibilities in terms of physical and program accessibility of their CDBG program. Recipients must include the accessibility logo on all client related materials

10 CHAPTER THREE: ACCESSIBILITY (CONT.) New ConstructionSubstantial Rehabilitation Rehabilitation 5 or more units Required minimum of 5% of the units or at least one unit accessible for mobility impairments; Minimum of 2% or at least one unit accessible for hearing or vision impairments Recommended minimum of 5% of the units or at least one unit accessible for mobility impairments; recommended minimum of 2% or at least one unit accessible for hearing or vision impairments 15 or more units Required minimum of 5% of the units or at least one unit accessible for mobility impairments; Minimum of 2% or at least one unit accessible for hearing or vision impairments Recommended minimum of 5% of the units or at least one unit accessible for mobility impairments; recommended minimum of 2% or at least one unit accessible for hearing or vision impairments

11 CHAPTER FOUR: UNIFORM RELOCATION ACT "Each award recipient shall provide for reasonable benefits to any person involuntarily and permanently displaced as a result of the use of assistance received…. Owner-Occupied Rehabilitation Award recipients are required to provide temporary relocation assistance in the event that a unit becomes temporarily unlivable during rehabilitation Can be provided in the form of paying for meals, hotel, housing participants in another unit, etc. Participation is voluntary so participants are not eligible for permanent relocation assistance Participants are not required to receive relocation advisory notices but should be informed that relocation might occur during the initial eligibility review. Rental Housing Property Acquisition – Willing Buyer/Seller Transaction

12 CHAPTER FOUR: UNIFORM RELOCATION ACT (CONT.) Once negotiations begin the Voluntary Acquisition Disclosure to Seller notice (Exhibit I) should be sent. Notice must be sent via certified mail or hand-delivered with signed receipt If purchasing with federal funds cannot exceed the appraised fair market value Willing buyer/seller transactions are ineligible for relocation assistance However, any tenants residing in the building(s) are eligible for relocation assistance Property Acquisition – Non-Willing Buyer/Seller Transaction Property Owner Notification Send a notice to the seller as soon as feasible Include HUD booklet 1041-CPD, When a Public Agency Acquires Your Property (Exhibit S) with this notice This packet of information must be sent via certified mail or hand-delivered with signed receipt Determine the Value of the Property If below $10,000, a licensed real estate appraiser may determine value If above $10,000, a fee appraisal by a licensed real estate appraiser must be obtained For properties that have been damaged and are located within the 100-year floodplain, both a fee and review appraisal must be completed

13 CHAPTER FOUR: UNIFORM RELOCATION ACT Property owner must be notified of the time and date of the appraisal as they can attend if they choose Notify property owner of offer after completion of the market valuation or appraisals Should be sent via certified mail or hand delivered with a signed receipt Sign the purchase offer If this is done prior to the ER release of funds and Section 106 clearance, you should enter into a purchase option that documents the completion of these processes as a condition of sale Complete the Recipient Questionnaire (Exhibit A – Acquisition-Relocation Summary Form) Property Acquisition with Rental Tenants General Information Notices must be provided as soon as feasible Residential Tenant that will not be Displaced (Exhibit B) Residential Tenant to be Displaced (Exhibit C) If displacement is possible, HUD Booklet 1042-CPD, Relocation Assistance to Tenants Displaced from their Homes (Exhibit T) Other Notices to be provided Notice to Tenants Moving in After Application (Exhibit R) Notice must be issued to each prospective tenant BEFORE the tenant agrees to move into the development.

14 CHAPTER FOUR: UNIFORM RELOCATION ACT Notice of Non-displacement (Exhibit D) For residents who will remain in the project after completion Temporary Relocation Notice For tenants who are not required to move permanently Must receive reasonable advance written notice Notice of Eligibility for Relocation Assistance (Exhibits F, G, & H) Issued to residents who will be displaced 90 (and 30 Day) Notices Must specify the date by which the property must be vacated URA to Displaced Households Replacement Housing Different types depending on whether the resident is a homeowner or rental tenant as well as how long they have lived in the property Moving and Related Expenses URA to Remaining Households Suitable Housing Affordable Housing Temporary Relocation Assistance Moving and Related Expenses

15 CHAPTER FIVE: FAIR HOUSING AND CIVIL RIGHTS The Fair Housing Act states that it is illegal to discriminate against any person because of race, color, religion, sex, disability, familial status, or national origin All CDBG award recipients are required to take an action to affirmatively further fair housing The action must reach the general community at-large and not be limited to low- moderate income residents only CDBG rental projects with 5 or more assisted units must complete an Affirmative Fair Housing Marketing Plan using HUD Form 935.2A (Exhibit B) Award recipients, subrecipients, and administrators are required to post the Fair Housing Equal Opportunity Poster in their offices Award recipients must include the Fair Housing logo on all client related materials Award recipients must provide all beneficiaries with a copy of the HUD brochure entitled You May Be A Victim Of…

16 CHAPTER SIX: CONFLICT OF INTEREST Persons Covered Provisions apply to any person who is an employee, agent, consultant, officer, or elected official or appointed official of the state, or of a unit of general local government, or of any designated public agencies, or sub-recipients which are receiving CDBG funds. Conflicts Prohibited No person who exercises or have exercised any functions or responsibilities with respect to CDBG activities. Persons in a position to participate in a decision-making process or gain inside information. Persons that may obtain a financial interest or benefit from the activity, or have an interest or benefit from the activity. Persons that have an interest in any contract, subcontract or agreement.

17 CHAPTER SIX: CONFLICT OF INTEREST Conflict of interest requests should be submitted in writing and contain the following: A request for an exception to the conflict of interest prohibition. A copy of the minutes from a public meeting denoting that the affected person has publicly disclosed the conflict and has stated that he/she has withdrawn from functions or responsibilities with respect to the assisted activity in question. An opinion from the recipients attorney that the interest for which an exception is sought would not violate state or local law. Uniform Conflict of Interest Disclosure Statement (Exhibit A) If an exception is allowed, this document must be completed and submitted within fifteen (15) days to the following parties: Indiana Housing and Community Development Authority State Board of Accounts Clerk of the Circuit Court of the county in which the contract was executed

18 CHAPTER SEVEN: SECTION 3 Applicability of Section 3 Recipients of HUD Community Planning & Development construction funding in excess of $200,000 in a program year Contractors and subcontractors that receive contracts in excess of $100,000 for Section 3 covered projects/activities The Section 3 language (Exhibit B) must be included in or attached to such contracts Requirements Attempt to offer 30% of new employment opportunities to Section 3 residents Attempt to award 10% of the total dollar amount of all covered construction contracts to Section 3 businesses Mandatory Reporting Requirements Whether or not an IHCDA award generated a need for new employment or contracts, the recipient must still submit Section 3 quarterly reports to IHCDA indicating this information. Quarterly reports are due February 1, May 1, July 1, and November 1 Recipients are also asked to submit their own annual report directly to HUD on Form HUD (Exhibit A)

19 CHAPTER SEVEN: SECTION 3 Definitions Section 3 Residents are one of the following: Residents of Public and Indian Housing; or Individuals that reside in the metropolitan area or nonmetropolitan county in which the Section 3 covered assistance is expended and show income does not exceed the local HUD income limits set forth for low- or very low-income households Section 3 Business Concerns are one of the following: Businesses that are fifty-one percent (51%) or more owned by Section 3 residents; or Businesses whose permanent, full-time employees include persons, at least thrity (30%) of whom are currently Section 3 residents, or within three (3) years of the date of first employment with the firm were Section 3 residents; or Businesses that provide evidence of a commitment to subcontract in excess of twenty-five percent (25%) of the dollar amount of all subcontracts to be awarded to businesses that meet the qualifications described above.

20 CHAPTER EIGHT: INCOME VERIFICATION All households must be income eligible to receive assistance Each applicant must receive an income verification IHCDA uses the Part 5 definition of income which looks at the gross household income anticipated for the coming 12-month period Owner-Occupied Rehabilitation Households must be income eligible at the time the construction contract is executed Rental Projects Households must be income eligible at the time the lease is executed When do income verifications expire? Income verifications are good for 6 months from the date of the initial certification. If more than 6 months lapse, the household income must be re-verified For rental developments funded in conjunction with LIHTCs, income verifications are good for 120 days from the date of initial certification. If more than 120 days lapse, the household income must be re-verified For rental projects, tenant income must also be re-verified on an annual basis

21 CHAPTER EIGHT: INCOME VERIFICATION Record Keeping Recipients are expected to keep the following information in each beneficiary/tenant file: Beneficiary application for assistance Tenant Eligibility Questionnaire (Exhibit D) Tenant Income Certification Form (Exhibit C) All sources of income w/ supporting documentation (wages, Social Security, child support, etc.) 3 rd party verifications are preferred When utilizing paycheck stubs as support documentation, you must obtain the number of paystubs that cover three (3) consecutive months of payments All sources of assets w/ supporting documentation (checking, savings, CDs, etc.) Receipt of the applicable brochures (Fair Housing, Lead Based Paint) Initial and subsequent leases (Rental Only) For tenants receiving rental assistance, a copy of the contract showing the amount of rental assistance being received Any other documentation verifying the beneficiaries eligibility (i.e. joint custody of a child documentation, all management clarification documents, etc.)

22 CHAPTER EIGHT: INCOME VERIFICATION Income Inclusions/Exclusions Pages of the SIP Compliance Manual Asset Inclusions/Exclusions Page of the SIP Compliance Manual Treatment of Assets Imputed Income from Assets vs. Actual Income from Assets Imputed Income from Assets If the total cash value of all assets is greater than $5,000, multiply that amount by the HUD passbook savings rate which is currently 2% Actual Income from Assets The actual income generated by the asset through interest, dividends, etc. The greater of the imputed income from assets and the actual income from assets is the figure used in the total household income calculation Rent and Income Limits The current rent and income limits can be found on our website at

23 CHAPTER NINE: LABOR STANDARDS (DAVIS BACON) Applicability of Davis Bacon Requirements 1) The rehabilitation or new construction of a residential property containing eight (8) or more units in a CDBG undertaking Therefore, if CDBG funds finance only a portion of the construction work, labor standards are applicable to the entire project Property is defined as one or more buildings on an undivided lot or on contiguous lots or parcels, which are commonly owned and operating as one rental, cooperative, or condominium project 2) The construction, alteration and/or repair, or painting of a public building or facility 3)Any construction work on non-residential property valued at more than $2,000 Additionally, all migrant seasonal farm worker housing projects are required to pay Davis Bacon prevailing wage rates Types of Wage Decisions Residential Construction Includes the construction, alteration, or repair of single-family houses, apartment buildings of no more than 4 stories in height

24 CHAPTER NINE: LABOR STANDARDS (DAVIS BACON) Building Construction Includes construction of sheltered enclosures with walk-in access for the purpose of housing persons, machinery, and equipment or supplies Heavy/Highway Construction These are projects that do not typically fall under residential or building construction Examples include work on bridges, water and sewer line projects, alteration or repair of roads, streets, highways May be applicable to residential developments of five stories or more Requesting a Wage Decision/Additional Classifications Request a wage decision from your compliance auditor using Exhibit B When requesting additional classifications we need the following info: Job title Wage rate and fringe benefits you are seeking for this classification Detailed description of type of work being completed Use of Apprentices and Trainees Must be registered in a bona fide apprenticeship or training program registered with the US Department of Labor or a Department of Labor –recognized State Apprenticeship Council

25 CHAPTER NINE: LABOR STANDARDS (DAVIS BACON) The allowable ratio of apprentices and trainees to journeymen on the job site is the allowable ratio under the approved program Weekly Certified Payroll Reports Must be kept on Department of Labor payroll form WH-347 (Exhibit M) Must be completed every week by every contractor/subcontractor working on the project through completion Must show every employee and trade that worked on the project for every week through completion Fringe Benefits Eligible and ineligible fringe benefits can be found on pages of the SIP Compliance Manual Employee Interviews IHCDA requires a minimum of 10% of each trade working on the project be interviewed using Form HUD-11 (Exhibit O)

26 CHAPTER NINE: LABOR STANDARDS (DAVIS-BACON) Interim monitoring requirements Halfway through the award term or at 50% of funds drawn, whichever is sooner, IHCDA will conduct an interim monitoring to ensure compliance with the labor standards provisions Any issues found must be addressed before additional claims to IHCDA will be released for payment Restitution Requirements Outlined on page 89 of the SIP Compliance Manual Retainage Requirements IHCDA will hold the final $5,000 of your award until the final monitoring has been completed and all findings and concerns associated with it have been resolved. Other important information Labor Standards Officer This is the person your organization will select to administer and enforce the Federal labor standards provisions (Exhibit A)

27 CHAPTER NINE: LABOR STANDARDS (DAVIS BACON) Pre-Bid Conference Should be held by the recipient/architect approximately three (3) weeks prior to bid opening Should discuss the Davis Bacon requirements as well as the construction/rehabilitation that needs to be completed with all contractors planning to bid on the project Pre-Construction Conference Must be conducted prior to any construction work beginning Will be given by your IHCDA Compliance Auditor Every contractor/subcontractor must be present Wage Decision Update The day prior to bid opening, submit the wage decision update verification form (Exhibit D) to your IHCDA Compliance Auditor to verify the wage decision has not been modified All contracts must include the following documents: Federal Labor Standards Provisions (Exhibit C) Wage Decision Any additional classifications (if applicable) Federal Contract Provisions (Exhibit F) Davis Bacon Contract Provisions (Exhibit G)

28 CHAPTER NINE: LABOR STANDARDS (DAVIS BACON) Rules to Consider Contract Work Hours and Safety Standard Act - requires that workers receive overtime compensation at a rate of 1 1/2 times their regular hourly wage after they have worked 40 hours in one week. Copeland Anti-Kickback Act – employees paid once a week. Employer must submit weekly payroll and compliance documentation Davis Bacon Act - requires that workers receive no less than the prevailing wages being paid for similar work

29 CHAPTER ELEVEN: PROCUREMENT Any procurement action that takes place for the award regardless of the funding source must follow the outlined procurement process. Local Units of Government (LUG) are governed by the following laws: Applicable Federal Regulations CFR Part 85 OMB Circular A-110 OMB Circular A-87 Applicable Indiana Procurement Laws Public Purchases Law (IC ) Public Works Law (IC ) If the LUG is the award recipient, the local unit of governments procurement standards must be followed. A subrecipient or award administrator working on behalf of the LUG must still utilize these procurement standards. Procurement Methods for LUGs Competitive Sealed Bids Competitive Negotiation Method Small Purchase Procedures Non-Competitive & Sole Source Purchases

30 CHAPTER TEN: PROCUREMENT Competitive Sealed Bids All construction contracts procured by a LUG must be solicited through this method Solicited through formal advertising Technical Bid Specifications, Terms, and Conditions Bidders List (if applicable) Bid Opening All bids should be read aloud and the contract awarded at a public meeting Must maintain evaluation of bids and minutes of this meeting Contract is awarded to the lowest/most responsive bidder Competitive Negotiation Method Preparation of RFP Request proposals from at least two qualified firms The RFP must be publicized Evaluate the proposals Establish criteria prior to evaluation Scoring encouraged for objectivity Negotiate with at least two firms Establish a Contract File

31 CHAPTER TEN: PROCUREMENT Small Purchase Procedures For services, supplies, and materials under $25,000 At least two quotes – at least one from MBE/WBE firm Non-Competitive & Sole Source Purchases May only be used under the following circumstances: When public urgency prohibits delays in the competitive bid process The needed material or service is available from only one source Competition is determined inadequate after a number of sources have been solicited Procurement by Not-for-Profit Organizations Governed by the following federal requirements: CFR Part 84 OMB Circular A-110 Required to follow competitive procurement procedures May choose to follow their own procurement standards or the local unit of government procurement standards If utilizing your own procurement standards they MUST be pre-approved by IHCDA

32 CHAPTER TEN: PROCUREMENT Procurement by For-Profit Organizations Sole-Source Procurement A cost-price analysis must be done to ensure that the bid is in line with reasonable and customary charges for similar work Competitive Procurement Awards made as grants or forgivable loans May be done by competitive negotiation and does not require publication Awards made as loans Follows the same process as is outlined for grants, however, if the for-profit wishes to select a bid other than the lowest and most responsive they must pay the difference between the lowest and most responsive received and the bid actually selected Exception to Procurement by For-Profit and Not-for-Profit Organizations HOME, CDBG, and Development Fund projects funded in conjunction with Section 42 Rental Housing Tax Credits (RHTCs). Other Requirements MBE/WBE At least 2 MBE/WBE firms must be solicited with each procurement action

33 CHAPTER TEN: PROCUREMENT Insurance Award recipients will be required to provide proof of adequate builders risk insurance during construction and property insurance following construction for the assisted property throughout the affordability period of the award Bonding Requirements Applicable to any construction contracts or subcontracts exceeding $100,000 and require: A bid guarantee from each bidder equivalent to 5% of the bid price A performance bond on the part of the contractor for 100% of the contract price A payment bond on the part of the contractor for 100% of the contract price; OR In lieu of acquiring the payment and performance bonds, IHCDA will accept an irrevocable line of credit equal to the greater of the award amount or 25% of the total construction contract Required Contract Provisions Pages of the SIP Compliance Manual Contractor Verification Prior to bid award, grantees must verify that all contractors that are bidding on the project are not listed on the HUD debarred lists (Exhibit C)

34 CHAPTER ELEVEN: ENVIRONMENTAL AND SECTION 106 HISTORIC REVIEWS Guidance on completing the Environmental and Section 106 Historic Reviews can be found in Chapter 11 of the SIP Compliance Manual Exhibit A – Environmental Review Process Exhibit B – Environmental Review Forms The Section 106 Historic Review is now found within the forms (Exhibit G, Part 3-5) and is no longer a separate process Exhibit G exception for OOR projects Part 3 – Sample Notices Exhibit D – Resources List Keep in mind that both of these processes MUST be completed prior to executing any contracts. An IHCDA release of funds letter will not be issued until the Environmental Review process is complete. This means: For not-for-profit and for-profit recipients IHCDA has approved your Environmental Review record, the legal notice has been published, and a release of funds from HUD has been received For local unit of government recipients IHCDA has approved your Environmental Review Record, the legal notice has been published, and the comment period in that legal notice has expired

35 CHAPTER THIRTEEN: MODIFICATIONS Possible reasons for requesting a modifications: Change an award ending date Change in project activities, site or area Reallocation of funds budgeted between approved activities Change in the use of principal and interest payments received by the recipient Change in private sector participants, investments, or housing goals Change in any conditions listed in your award agreement These requests should be sent to your Real Estate Production Analyst

36 CHAPTER FOURTEEN: CONSTRUCTION STANDARDS All housing that is constructed or rehabilitated must meet the stricter of the Indiana State Building Code, local building code, or manufacturers instructions Requirements for Physical Inspections on assisted properties Must be inspected twice during the award term The first inspection will occur at the completion of the documented scope of work and prior to the IHCDA inspectors final physical inspection This inspection must be completed by a licensed home inspector, engineer, or architect If the paid staff of the recipient completes the work on the home, an outside third party inspector must be used If an outside contractor is procured to complete the work then the staff of the recipient will be permitted to complete the inspection The second inspection will be conducted upon completion of the construction of the award by your IHCDA Inspector Who can conduct third party inspections? The required inspection must be completed by a licensed residential housing inspector, engineer, or architect who has a current license with the State of Indiana Professional Licensing Agency (PLA). For information on who is licensed, how to become licensed, or how to renew/update your license, please visit the PLA website at For OOR projects only a waiver may be requested

37 CHAPTER FIFTEEN: LIEN AND RESTRICTIVE COVENANTS & AFFORDABILITY REQUIREMENTS Affordability Period - The period of time that an assisted unit must remain affordable to identified levels of low- or moderate-income persons. Begins on the date of closeout Affordability periods can be found on pages 118 – 119 of the SIP Compliance Manual Subsidies must be secured by a written, legally binding, recorded Lien and Restrictive Covenant Agreement (LRCA). Will be given to you with your award documents The recipient is responsible for filing the LRCA and any amendments hereto in the Office of the Recorder of the County in which the project is located Owner-Occupied Rehabilitation projects The final claim of the recipient will be held until IHCDA receives a copy of the executed and recorded LRCA for all assisted units under the award Rental projects IHCDA will not issue a release of funds letter until a copy of the executed and recorded LRCA has been received Rental Housing Compliance and Reporting Guidance on rental housing compliance and ongoing reporting requirements can be found in the compliance manuals available on our website at

38 CHAPTER SIXTEEN: PROGRAM MONITORING AND RECORD RETENTION IHCDA Closeout Monitoring This is completed by an IHCDA Compliance Auditor prior to the closeout of your award to ensure compliance with federal and state rules and regulations IHCDA will hold the final $5,000 of an award until both the final monitoring and final inspection have been completed and all findings and concerns associated with them have been resolved IHCDA Interim Monitoring Will be required for Davis-Bacon projects halfway through the award term or at 50% of funds drawn, whichever is sooner May also be required on a case-by-case basis if IHCDA deems necessary Ongoing Compliance Monitoring All rental projects will be subject to ongoing compliance monitoring throughout their affordability period. Will consist of: A review of annual owner certifications of compliance Periodic onsite or desktop tenant file audits Record Retention and Custodial Requirements Financial Records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of five (5) years


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