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T 1P TABLE OF CONTENTS THE NSP SUBSTANTIAL AMENDMENT...........................................................................2 JURISDICTION: CITY OF MIAIVI................. I............................................................... ...2 NSP CONTACT PERSON: GEORGE MENSAH....................................................................2 WEB ADDRESS: WWW.MIAMIGOV.COM/COMNrUNITYDEVELOPIVENT...........................................2 PAGES/REPORTS................................................................................................... 2 ADDRESS: 444 SW 2 AVENUE. 2 FLOOR........................................................................2 M/ArliI, FL 33130..................................................................................................2 TEL: (305)416-2080; FAX. (305)416-2090...................................................................2 E-MAIL: GMENSAH@MIAMIGOV.COM.............................................................................2 A. AREAS OF GREATEST NEED..................................................................................2 Graph 1. - Properties undergoing foreclosure proceedings.....................................................4 Graph 2. - Foreclosure Risk Levels..........................................................................................5 Graph 4. - Low Moderate & Middle Income Eligible Areas by Census Tract and Census Block.......................................................................................................................................... 7 Table 1. - Areas of Greatest Need by Census Block Group ................................................... 11 B. DISTRIBUTION AND USES OF FUNDS....................................................................... 15 Table 2. — NSP activities to be implemented.......................................................................... 16 C. DEFINITIONS AND DESCRIPTIONS.......................................................................... 16 BlightedStructure...............................................................................................16 AffordableRents.................................................................................................17 AffordabilityPeriod: ........................................................................................17 Housing Rehabilitation Standards.....................................................................18 Foreclosed...........................................................................................................18 Abandoned..........................................................................................................18 Current market appraised value.........................................................................18 LandBank............................................................................................................19 D. LOW INCOME TAP, GETING ................................................................................... 19 Table 3.- Low Income Targeting..............................................................................................19 E. ACQUISITIONS & RELOCATION.............................................................................. 20 F. PUBLIC COIV/MENT........................................................................................... 20 G. NSP INFORMATION BY ACTIVITY ....................................................... ................... 20 Strategy"A"............................................................................................................................. 20 Establish financing mechanisms for purchase and redevelopment of foreclosed upon homes and residential properties: .................................... ....................... ...................... ................... 20 Strategy"B.. .............................................................................................................................24 Purchase and rehabilitate homes and residential properties that have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties ................... 24 Strategy"C" .............................. ........ ............................................... ..................... .................... 25 LandBanking...........................................................................................................................25 Strategy„p............................................................................................................................... 26 Demolition................................................................................................................................ 26 Strategy"E.. ............................................................................................................................. 27 Redevelopment of Demolished or Vacant Properties............................................................. 27 NSP SUBSTANTIAL AMENDMENT CHECKLIST................................................................. 30 FY2008-2009 Action Plan Amen Amendment # THE NSP SUBSTANTIAL AMENDMENT Jurisdiction: City of Miami NSP Contact Person: George Mensah Web Address: Address: 444 SW 2 Avenue, 2 Floor www.miamigoy.com/Communitydeve/opment I Miami, FL 33130. /pages/reports Tel: (305)416-2080; Fax: (305)416-2090 E-mail: gmensah@miamigov.com A. AREAS OF GREATEST NEED The Neighborhood Stabilization Program ("NSP") was created to provide emergency assistance to state and local governments to acquire and redevelop foreclosed upon properties that might otherwise become sources of abandonment and blight within our communities. The NSP provided a grant to the City of Miami ("City") to purchase foreclosed upon or abandoned homes and to rehabilitate, redevelop and resell/rent, these properties in order to stabilize neighborhoods and stern the decline of house values of neighboring homes. This program is authorized under Title III of the Housing and Economic Recovery Act ("HERA") of 2008. The City was awarded $12,063,702 in Community Development Block Grant -like (°CDBG") dollars to implement this new program. The Department of Community Development ("DCD") is hereby revising its original Housing Market Foreclosure Assessment, which identified areas originally thought to be most affected by the current housing crisis, with a new Housing Market Foreclosure Assessment that provides for an updated and more realistic status of current housing market conditions. The City study consisted of the following steps: DCD staff analyzed the geographical distribution of home foreclosure proceedings'. This data set included properties that were already foreclosed upon and are currently owned by banks and properties that are undergoing foreclosure procedures (Graph 1). Note that the number and the geographical location of proceedings is fairly balanced and evenly scattered across City boundaries. This clearly shows that the housing foreclosure problem is spread over the entire City and not only in certain pockets as it was originally thought. 2, DCD staff then proceeded to plot the "Foreclose Risk Levels'Z dataset which is composed of a combination of factors including fallen home values, unemployment rate, percentage of loans that are of high cost, and the number of addresses vacant for at least 90 days (Graph 2). Notice that almost all city neighborhoods fall under a Foreclosure Risk Level of 6 or higher, which is properly reflected in the even distribution of foreclosures throughout the city as shown in Graph 1. 3. In addition, the City plotted census block information where the total number of homes financed by sub -prime mortgages exceeded 25 percent of the total number of loans issued for the area (Graph 3). This means that at least 1 out of 4 households in each census block represented was issued a high cost loan. This dataset again confirmed that the sub -prime ' Dataset obtained from First American CoreLogic. Dataset obtained from www.huduser.om. Sources include: OFHEO data on decline in home values as of June 2008 compared to peak home values since 2000; Federal Reserve Home Mortgage Disclosure Act (HMDA) data; Labor Deparment data on unemployment rates in places and counties as of June 2008, USPS data on residential addresses identified as being vacant for 90 days or longer. 2 FY2009-2009 Action Plan Amend An, r 2( market problem is not just concentrated in a few areas, but affecting all city neighborhoods. 4. Graph 4 utilizes data from huduser.org to highlight, at census block level, the areas that are eligible for NSP assistance based on income (LMMI). 5. Graph 5 combines the results of all four previous maps utilized and the results show that the datasets overlap almost in every city neighborhood. As such, these overlapping areas are classified as the revised "Areas of Greatest Needs" These areas are better depicted in Graph 6. 6. Graph 6 isolates the new AGN and distinguishes eligible vs. ineligible areas. 7. Graph 7 shows the number of abandoned properties in the City of Miami and their deterioration levels. This map complements Graph 1 as these properties also create a negative effect in neighborhoods contributing to the decline of housing values in the areas where they are located. Graph 1. - Pronprties underaoina foreclosure proceedings. city of Mic Legend 11 Forecdasurq Oatn Stance: RMIA Iltan iWe"E, Inc rfmvu"c ZM Graph 2. - Foreclosure Risk Levels Foreclosc Legend Foreclosure Rsl 1€3 ,9 . I a 7 Foreclosure risk is r, level based on taller percemaW of roans mai are nign cosi roans. an¢ une numuer address vacant for at least 9a days) Dale Source: H'UD User h1Ep:llwww.huduser.orgfdatawl6,fnsp_faigel.hlml, Graph 4. - Low Moderate & Middle Income Eligible Areas by Census Tract and Census Block HUD Neig Income El Legend Greater Tl �ne�gime Less Than Date Source: WD Userh9tp.ttmvw.huduser_orgtdataseWnsp_tairget.htmt 7 Graph 6.- /sola+ir-pn fho Argas of Greatest Need City of ME Legend Low. Mod, telellgltife Low, Mod, Data Source: HUD User hilp-tfreww.huafuser_orgodateseWnsp_leaget.hlml 0 Graph - '--,4ba"(10,'7e(y Properti'.. Abandoned Properties by Deteriora All Properties bY District tion Level I ugend Leve, (,_Low,,t, O 2 4 132 29,4, 772 d, I f) Statistics show South Florida as one of the top five regions in the United States that was hit the hardest by the current housing foreclosure and financial crises. Within the past five years, property values sky rocketed as a result of a buying frenzy inspired both by investors trying to take advantage of appreciating housing market conditions and of homebuyers eager to be able to share in part of the American dream at any cost, lured by attractive, but deceiving financial instruments private lenders set in place to profit from the appreciating market. These facts paired with a large sub -prime mortgage loan market and a stagnant economy with high unemployment rates contributed to the large number of foreclosure proceedings we encounter today in the City of Miami. Many homeowners found themselves with mortgages that exceeded the equity on their properties. Based upon the data and projections utilized, most of the areas in the City of Miami are under "great need" for some financial relief. As such, the City has catalogued the area represented in Graph 6 as the "Areas of Greatest Need.s3 These areas will be targeted by the City and will be given priority in the allocation of NSP funding. Table 1 below shows the census tracts and census blocks that comprise the Areas of Greatest Need. Table 1. -Areas of Greatest geed by Census Block Group Source: HUD IVSP data Census Low, Percent Block Mod, of Group Middle People Eligible <= 120 Am i Census Low, Percent Block Mod, of Group Middle People Eligible <= 120 Ami 1004.2 YES 98% 5002.3 YES 83% 95% 1302.2 YES 53% 1006.4 YES 100% 5100.2 YES 83% $3l0 52021 :YES Y .86flm, 1302.4 YES 1301.1 YES 66% 5100.4 YES 89% 1301.3 YES 67% 5100.6 YES 85% 1301.5 YES 95% 5201.2 YES 95% 1302.2 YES 53% 5201.4 YES 95% 3302.3 YEiS $3l0 52021 :YES Y .86flm, 1302.4 YES 92% 5202.2 YES 85% 13©2.5 YES b2%- 2% 1302.6 1302.6 YES 86% 5202.4 YES 97% 1(31.4_; YES . 81% 5301.3 YES `90% 1401.5 YES 94% 5301.4 YES 83% 14{1..6;_ YDS 93°/0 530 5 `YES $$°l° _ 1402.1 YES 91% 5301.6 YES 90% 3 Criteria utilized: areas with Foreclosure Risk Levels of 6+ AND where sub -prime loans comprise more than 25 percent of the total loans issued in the census block. Census Low, Percent Census Low, Percent Block Mod, of Block Mod, of Group Middle People Group Middle People Eligible <= 120 Eligible <= 120 93% Ami YLS `- �9% Ami 1402.3 YES 100% 5301.8 YES 83% 153 1 Y 1�3A _�32-'fS3°/fl 1501.2 YES 98% 5302.2 YES �93%y 1501.4 YES 101% 5302.4 YES 93% 102 1. " YLS `- �9% ` 3401 � � X1=5 7� � ��9✓D 1703.1 YES 87% 5401.2 YES 85% � 1801.1 YES 10J2�% 5401.4 YES 79% 1801.1 YES 76% 5402.1 YES 92% f - 1802.3 YES 80%K 5402.3 YESy 91% 19, < 1901.2 YES 86% 5402.5 YES 79% 1901.4 YES 78% 5501.1 YES 70% 1903.34 YES 86% 5501.3 YES 86% y 1903.6 YES 96% 5502.1 YES 84%4 106 7" YES `s502 -RE 1904.1 YES 92% 5502.3 YES 76% 1.904 2 SES 91 n/o � S�Sfl� 4 ___YES 83 �0 ,- Y - - ~ "V 1904.3 YES 91% 5600.1 YES< 65% 104 $t'ES�°% 56f31? 2 YE_J^ 7°Io 2001.1 YES 94% 5600.3 YES 76% 2001.3 YES 83% 5701.4 YES 75% 2003.3 YES 89% 5701.6 YES 72% X003,4 YES 96°Y0 5703.1 YES 93% 2004.1 YES 93% 5703.2 YES 83% 2004.2 ' YES 91 2100.1 NO 46% 5704.1 YES 88% 2100.2 ' NO 40% 07{34'.2 2100.3 NO 42% 5704.3 YES 85% 2 00.4YES . 889/0 2201.1 YES 70% 5801.2 YES 76% 220.2 YES $1% 2201.3 YES 100% 5801.4 YES 71% YES 80% - 5801fS u 659/0 2202.2 YES 83% 5802.2 YES 81% 2202.3 YES 90 °lQ - S$02:3 YES - 72%" Census Low, Percent Census Low, Percent Block Mod, of Block Mod, of Group Middle People Group Middle People Eligible <= 120 Eligible <= 120 6301.1YES Ami YES Ami 2202.4 YES 68% 6802.4 YES 73% 62% �YES / ` 2600.3 YES 94% 6500.3 YES 2202.6.. YES 82% 6301.1YES 88% YES ++ y YES 81% 84% 6301.3y YEAS+ 82% --2��30y{0.2 VYE�S* 2701.3 YES 74% 6601.2 YES 71% 2300.4 YES 81% 6302.1 YES 66% 2300.6 YES 93%yy G66302.3 YEAS+ 57%// 2401.3y BYES 97% 6401.1 YES 82% 2401.5 YES 87% 6401.3 YES 93% 2402.2 YES 81% 6402.4 YES 85% 2500.2 YES 94% 6402.6 YES 74% 4 2500.4 YES 88% 6403.2 YES 67% 2600.1 YES 96% 6500.1 YES 62% 2600.3 YES 94% 6500.3 YES 68% YES 2701.1 YES 53% 6500.5 YES 81% 27Q� 2 Yl✓S 7$°Jo 653 6'ES 7.4Jn 2701.3 YES 74% 6601.2 YES 71% p YYES 2701.5 YES 55% 6601.4 92% 2702.1~ YES 87% 6601.6 NO 38% 202`2 YES 73°10 6613 .-:. ;YES ''`' 53% 2800.1 YES 98% 6602.1 YES 94% 2$00.2_: NO 1410 6602 2 YES= 1{�2�0 _` 2800.3 YES 98% 6602.3 YES 97% 2900.,1 _YES 2900.2 YES 75% 6701.1 NO 35% 29013.3 ' YES- 2 3001.1 YES 67% 6701.3 NO 33% 30D1.2. YES �98% 67132. . ' '.YDS=� Ja' 3001.3 YES 75% 6702.2 NO 44% 3003:1: YES 94°1D : 6 7 02.3-- .. 3003.2 YES 91% 6702.4 YES 63% 3003 3: YES $$% _ 68Cf1 ` I 29%. 3004.1 YES 73% 6800.2 NO 31% Census Low, Percent Census Low, Percent Block Mod, of Block Mod, of Tabl Group Middle People Group Middle People e 1 above Eligible <= 120 Eligible <= 120 shows the Ami Arni census _ block 3100.1 YES 92% 6800.4 NO neo{= 38% groups where than 3100.3 YES 93% 6900.1 YES 71 % more 51 percent SES 990 w, 6�3fl of the 4340.1 _ --._ v�t..9`fl 3400.2 YES 99% 6900.3 YES 59% population 34 1 3 S nI9 f� } 4 E 7�2 in the area 3400.4 YES 83% 6900.5 YES 62% had .0 incomes at _,_ or less 3601.2 YES 100% 7001.2 YES 79% than 120 percent ofthe 3602.1 YES 92% 7001.4 YES 68% Area 3Efl2 'F E-_�D Median s 3602.3Y YES 95%0 7002.2 YES 86%o Income (2000). 3701.1 NO 23% 7002.4 YES 74% This 32 1 - �E B7%1Q 1BJ9 : dataset 4601.2 -- 4.. NO w. 40% 7100.2 YES 51% assisted City staff to evaluate 4901.3 YES 91 % 7100.4 YES 71% YoTo the eligibility of 4902.2 YES 81 % 7200.1 YES _....-w..�....> 64% the census 4903 xE _.�0 7_2BB` 5, 89°Io _ block's 4902.4 YES 90% 7200.3 YES 81% based on meeting y5001.2 YES 82% 7300.1 NO 15% national 5001 3 =E 7�0` �30_i#r� iN objectives 5001.4 YES 84% 7300.3 NO 30% to benefit x:001 5 _ YES 72°0 730Q'4 =:fl 22°l0 ` low-, _.. -- - - moderate - 5001.6 YES 68% and middle-income households. If or when the City identifies a project for funding outside the :areas of Greatest Needs, jUStiflCation shall be provided to the HUD field office for approval 14 B, DISTRIBUTION AND USES OF FUNDS HUD's definition of an assisted household is "one that will receive benefits through the investment of federal funds, either alone or in conjunction with the investment of other public or private funds." A renter is benefited if the household or person takes occupancy of affordable housing that is newly acquired, newly rehabilitated, or newly constructed, and/ or receives rental assistance through a budget authority. A homebuyer is benefited if a home is purchased during the year. An existing homeowner is benefited if the home's rehabilitation is completed. Under all of these three -scenarios of assistance, the dwelling unit must, at a minimum, satisfy Housing Quality Standards. One of the major challenges the City faces for the successful implementation of this program is household eligibility. Financial institutions are being more fiscally conscious when issuing new mortgage loans after witnessing the recent collapse of global financial markets due in part to the housing crisis the country is experiencing, which was sparked by the overwhelming amount of bad debt accumulated. The NSP target market makes it even more challenging as the City deals with a clientele whose income levels make homeownership difficult to attain. The current financial crisis adds an additional tier to the already complex task the City has. Creative methods of leveraging and layered financing have allowed the City to be successful in offering programs that allow for low -to moderate -income families to achieve the American dream of homeownership. Solid partnerships with private lenders helped the City build the foundations for programs that provide lasting, life -changing events for our residents, such as owning their own house for their well being and that of their children. The success of the City's current First Time Homebuyer program is reflected in the fact that only one homebuyer out of over 300 residents who received assistance through the program in the past 5 years endured foreclosure proceedings due to a death in the family. NSP funds will be distributed through the implementation of five different strategies that cover different areas of housing and address both the rental and the homeownership market. The City is confident that a combination of these strategies will provide much needed relief to City neighborhoods most affected by the foreclosure crisis. Additionally, the City will work in conjunction with the private and public sectors to fine-tune such strategies to ensure an efficient implementation of the NSP program. To be effective, strategies need to be well defined and target a specific clientele. The City recognizes that not all strategies are going to be effective to all income levels; as such, the implementation of different strategies, for renters and ready -to -be homeowners, is what will create the right balance and permit the City to assist more low-, moderate-, and middle-income residents. The City is firm in its commitment to affordable housing and clearly understands and accepts its role in the implementation of the NSP program. As such, it has taken a pro -active approach and has projected its efforts through different strategies that will benefit the ones that need housing the most while stabilizing neighborhoods in the process. Priority in applying these strategies will be placed in the areas identified as of "greatest need". Currently, the Department of Community Development is in the process of gathering data and information regarding abandoned and foreclosed upon homes in those areas and it has brought aboard a specialized team of industry professionals to assess, negotiate, manage, and monitor the progress of the NSP program. Along with a team of City underwriters, inspectors, and housing managers, the City is moving forward with the implementation of this program as the timeframe for committing NSP dollars is very demanding. The City will implement the following activities, or a combination thereof, in order to provide housing opportunities to low-, moderate- and middle- income households and to maintain or improve the value of properties in the areas of greatest need. Table 2 shows the estimated amount of funding allocated to each strategy and the estimated number of units that will result from the successful completion of each activity. Table 2. — HSP activities to be implemented Activity/ Strategy Estimated Estimated Amount Units B. Purchase and rehabilitate homes and residential properties that have $5,500,000 90 been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties. D. Demolish blighted structures. $700,000 Included under strategy `C" E ,1�edevE7opra�en of demolished orarapan# pro�iertles � v � � � �6 �3? ��� `= Administration $1,206,370 - TQTQI.} 47 := As under the regular CDBG program, the City may fund costs, such as reasonable developer's fees, related to NSP -assisted housing rehabilitation or construction activities. NSP funds may be used to redevelop acquired property for nonresidential uses, such as a public park, commercial -use, or mixed residential and commercial uses. Program Income — Any program income generated by the sale, rental, redevelopment, rehabilitation, or any other eligible use that is in excess of the cost to acquire and redevelop (including reasonable development fees) shall be used in accordance with the provisions of Section 2301 of the Housing and Economic Recovery Act of 2008 and the Notice of Allocations, Application Procedures, Regulatory Waivers Granted to and Alternative Requirements for Emergency Assistance for Redevelopment of Abandoned and Foreclosed Homes Grantees under the Housing and Economic Recovery Act, 2008; Revisions to Neighborhood Stabilization Program (NSP) and Technical Corrections. C. DEFT WTIONS AND DESCRIPTIONS Blighted Structure Policy LU -1.2.1 of the City of Miami's Comprehensive Plan defines "blighted neighborhoods" as areas characterized by the prevalence of older structures with major deficiencies and deterioration, high residential vacancies, widespread abandonment of property, litter and poor maintenance of real property. 4 Federal Register Vol. 73, No. 194 Pg. 58337. 16 In addition, Slum is defined by Florida Statutes as an area which there is a predominance of buildings, residential or commercial, that are either deteriorated, dilapidated or by reason of obsolescence, is a detriment to the public health, safety, morals, or welfare. Florida Statutes define "blight" as an area determined by the local government to have the characteristics of a slum area or one or more of the following characteristics: 1. Predominance of defective or inadequate street layout. 2. Faulty lot layout in relation to size, adequacy, accessibility, or usefulness. 3. Unsanitary or unsafe conditions. 4. Deterioration of site or other improvements. 5. Inadequate and outdated building density standards. B. Tax or special assessment delinquency exceeding the fair value of the land. 7. Inadequate transportation and parking facilities; and 8. Diversity of property ownership or defective or unusual conditions of title. The City uses a combination of the two definitions above to define a "blighted structure." Affordable (lents The City defines "affordable rents" as rental payments that do not place unnecessary burden to households. The City of Miami will use HUD's income and rent limits which are updated on an annual basis to ensure that housing provided through the NSP program is affordable. Affordable means that monthly rents or mortgage payments including taxes and insurance do not exceed 30% of the monthly gross income of eligible households as indicated in the table below: Table 3. — Affordable Rents Household Income Level Affordable Rents Moderate Income Equal to 30% of the FY2008 Income Limits for 80% of HUD AMI titfidd el fncor�e =x ._ __.a,.� .,,�m�qual #0;:30°1o,�f tie �'�'2008_Ir�cotxe �.7m�ts for '[20%of�-(UD N1t AMI = Area Median Income However, for a homebuyer, the City will not limit an individual household's ability to devote more than 30 percent of its income for housing, if the mortgage lender(s) is satisfied that the household can afford mortgage payments in excess of the 30 percent benchmark. In such a situation, the target total monthly debt obligation as a percentage of monthly income cannot be more than 45 percent. On an exception basis, the monthly payment of mortgage payments could be less than the 30 percent benchmark, if justified. In the case of rental housing, the City will ensure that rents do not exceed those rental limits adjusted for bedroom size.. Affordability Period: The City will ensure that NSP -assisted properties remain affordable to households with incomes at or below 120 percent of AMI. The City will adhere to HOME program standards (see table below), but at its discretion may choose to apply a higher affordability period to NSP - assisted properties. The maximum affordability period, however, shall not be longer than 30 years. The City monitors affordability of all its projects and activities on an annual basis and ensures that housing units that were assisted with federal funding remain affordable for the full affordability period. Amount Provided b'finimum period of affordability in years Under $15;000 5 y Over $40;000 or rehabilitation involving refinancing 15 I ev orlstruction or acq 1SIE n,of mew ly �onsuctedhousirig �0 = Housing Rehabilitation Standards For rehabilitation purposes, all materials and workmanship shall conform to the requirements of the South Florida Building Code. In addition, the Department of Community Development ensures that all repairs necessary to bring the house to a decent, safe, and sanitary condition are performed, as defined by US HUD's Housing Quality Standards as per 24 CFR 982.401. Foreclosed A property "has been foreclosed upon" at the point that, under slate or local law, the mortgage or tax foreclosure is complete. HUD generally will not consider a foreclosure to be complete until after the title for the property has been transferred from the former homeowner under some type of foreclosure proceeding or transfer in lieu of foreclosure, in accordance with state or local law. Abandoned A home is abandoned when mortgage or tax foreclosure proceedings have been initiated for that property, no mortgage or tax payments have been made by the property owner for at least 90 days, AND the property has been vacant for at least 90 days. Current market appraised value The current market appraised value means the value of a foreclosed upon home or residential property that is established through an appraisal made in conformity with the appraisal requirements of the URA at 49 CFR 24.103 and completed within 60 days of the final offer made for the property by a grantee, sub -recipient, developer, or individual homebuyer. IN Land Bank A land bank is a governmental or nongovernmental nonprofit entity established, at least in part, to assemble, temporarily manage, and dispose of vacant land for the purpose of stabilizing neighborhoods and encouraging re -use or redevelopment of urban property. For the purposes of the NSP, a land bank will operate in a specific, defined geographic area. It will purchase properties that have been abandoned or foreclosed upon and maintain, assemble, facilitate redevelopment of, market, and dispose of the land -banked properties. If the land bank is a governmental entity, it may also maintain abandoned or foreclosed property that it does not own, provided it charges the owner of the property the full cost of the service or places a lien on the property for the full cost of the service. D. LowINCOME TARGETING The estimated amount of funds appropriated or otherwise made available under the NSP to be used to purchase and redevelop abandoned or foreclosed upon homes or residential properties for housing individuals or families whose incomes do not exceed 50 percent of area median income is approximately $4,737,750. This amount equals to about 39.3 percent of the total NSP allocation for the City of Miami. Thus, the City will be meeting the statutory requirement by allocating over 25 percent of NSP funding toward housing individuals and families whose income do not exceed 50 percent of area median income. The table below illustrates low income targeting by activity. Table 3.- Lova Income Targeting Activity/ Strategy Estimated Target Low Amount Income B. Purchase and rehabilitate homes and residential properties that $4,000,000 Yes have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties. For more detailed information regarding the activities/ strategies listed above, please refer to Section G in this amendment. E. AcouislroNs & RELOCATION All acquisitions made by the City of Miami will follow and meet all federal requirements for acquiring properties utilizing federal funds and will comply with all of the Uniform Relocation Act mandates. The City of Miami will take all precautions not to demolish any occupied low-, moderate-, or middle-income housing unit as these types of projects usually involve relocation costs, which would divert funding from other activities that could potentially achieve similar or better results without having to involve occupied low-, moderate- or middle-income housing or any public housing structures. However, should it become necessary for the City to demolish such housing, all eligible residents will be relocated in accordance with Section 104 or the Uniform Relocation Act, F PUBLIC COMMENT The Department of Community Development duly advertised to the general public through a newspaper of general circulation the availability of the NSP substantial amendment and solicited comments from City residents. The comment period, as defined by NSP regulations, is of 15 - days. The NSP substantial amendment was available through the Department's website and at the offices of the Department of Community Development located at 444 SW 2 Avenue, 2 Floor, Miami, FL 33130 from November 17, 2009 to December 17, 2009. Please submit your comments in writing to: NSP Comment City of Miami — Department of Community Development 444 SW 2"d Avenue, 2nd Floor Miami, FL 33130 Attn.: Roberto Tazoe The NSP substantial amendment was available on the City's website and at the DCD reception, [Comments are found under Attachment "A"] G. NSP INFORMATION BYACTIvITY Stratep "A s' Establish financing mechanisms for purchase and redevelopment of foreclosed upon homes and residential properties; Providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income (LN M). 1911 (2) Activity Type: Providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income. (3) National Obiective: LMMH (Low-, Moderate -,Middle -Income Housing) (4) Proiected Start Date: February 2009 (4.1) Proiected Commitment Date: August 2010 (5) Proiected End Date: February 2013 (6) Responsible Oraanization: City of Miami Department of Community Development 444 SW 2nd Avenue, 2nd Floor, Miami, FL 33130 Contact Information: Alfredo Duran, Deputy Director Phone +: 305-416-2080; email: aduran@miamigov.com (7) Location Description: Areas of Greatest Needs and other areas within City limits as determined by the Department of Community Development. (8) Activity Description: This strategy shall provide homeownership opportunities within the location description defined above. The City will be targeting households who do not exceed 120% of the area median income adjusted for family size. The City realizes that there may be households that may not qualify for this strategy as they may be affected by the current tighter financial restrictions imposed by private lending institutions. 1) Equity Sharing Program Provide shared -equity investment of no less than 20% of the purchase price to homebuyers purchasing a property in the City of Miami's Areas of Greatest Need. The City will buy down the price of the purchase with the subsidy, in exchange for a guaranteed lower tax rate on the property. The buyer locates an abandoned and/ or foreclosed upon residential property within the City's AGN, meets with the bank holding title to the property and utilizes private lenders to be pre -qualified for a mortgage loan. The City of Miami inspects the property to ensure compliance with housing standards and underwrites the shared -equity investment based on all financial commitments provided to the homeowner. The City will process applications on a first-come, first -ready, first-served basis If the City of Miami inspector determines that the property has code violations and/or is not meeting Housing Quality Standards as per 24 CFR 982.401, then the property must be purchased AND rehabilitated through the City's NSP -funded program before the buyer can start occupying such property. 2) Down Payment Assistance Program Provide zero percent (0%) deferred loans to homebuyers purchasing a property in the City of Miami's Areas of Greatest Need. The buyer locates an abandoned and/or foreclosed upon residential property, meets with the bank holding title to the property and utilizes private lenders to be pre -qualified for a mortgage loan. The City of Miami inspects the property to ensure compliance with housing standards and underwrites the loan based on all financial commitments provided to the homeowner. The City will process applications on a first-come, first -ready, first-served basis. If the City of Miami inspector determines that the property has a code violation(s) and/or is not meeting the safe, sound, and sanitary standards, then the property must be purchased and rehabilitated through a City NSP program before the owner can start occupying said premises. The following are eligibility requirements that apply to both the Equity Sharing and the Down Payment Assistance Programs described above. Eligible Properties: Abandoned or foreclosed upon single family residences, townhomes, and/ or condominiums. The property must be. located within the City of Miami's Areas of Greatest Need and must meet Housing Quality Standards as per 24 CFR 982.401. If the property is not meeting such standards, the property must undergo rehabilitation under the NSP -funded program. Eligible Buyers: The household income must be less than or equal to 120% of HUD's Area Median Income, adjusted for family size; the buyer must be able to afford a monthly payment based on income and debt; and the buyer must contribute at least $500 of personal funds toward the downpayment/ closing costs. The buyer must not hold title to another residential property at time of closing. Homebuyer Counseling: Before obtaining a mortgage loan, eligible buyers must receive and complete at least 8 hours of homebuyer counseling from a HUD -approved housing counseling agency. Sales Price: Homes must be purchased at a 1% or greater discount from the current market appraised value of the property, taking into consideration its current condition. The appraisal shall be completed within 60 days of the final offer made for the property by the homebuyer. Loan Terms: The maximum amount of assistance shall be the amount necessary to meet the lender's underwriting criteria. The loan will carry a 0% non -amortizing rate for a 30 -year deferred payment period. Payment of principal will be forgiven at the end of maturity period provided that the homeowner resided in the house as their primary residence for the full 30 years. Security: The loan will be secured by a mortgage on the properly. First Mortoaae Restrictions: Term of the loan must be 30 years. fixed interest rate & cannot exceed more than 150 basis points over Freddie Mac's weekly average 30 -year rate, as published in the Primary Mortgage Market Survey ("PMMS"); no prepayment penalties; total percentage charged for Discount, Origination & Broker fees must not exceed 2 points; all other lending fees must be reasonable and cannot exceed $500 or 0.5% of the loan amount, whichever is less. Resale Restrictions: If the owner sells and/ or transfer the house prior to the end of the City's mortgage term, the following provisions will apply: The sale of the property must be pre -approved by the City, and the new buyers must meet the program's income limits in effect at the time AND the sales price must not exceed the maximum affordable sales price in effect at the time. 2. Applicable to Down Payment Assistance Program Only: For any "early" sale or transfer', the City shall share in any gain realized, based on its pro -rated share of participation in the original purchase. Furthermore, if the sale occurs within the first 3 years, the City shall keep 100% of its pro -rated share of the "gain", from year 3 up to year 20, the City's 22 share of its pro -rated "gain" shall decrease by 5% every year, while in turn, the owner's share shall increase by 5% each year. At year 20 up to the City's loan maturity, the owner shall retain 500% of the City's gain. 3. Applicable to the Equity Sharing Program Only. For any "early" sale or transfer, the City shall share in any gain realized, based on its pro -rated share of participation in the original purchase. A 30 year affordability period will be applicable under this strategy. 4. The above shared gain proposal terminates in the event of a foreclosure, with the lender required to provide the City the right of first refusal to purchase the loan at a negotiated price. In the case of a foreclosure, the City will recapture any amount of net proceeds available from the sale of the property. These same restrictions apply to the Equity Sharing Program. ---------------------------------------------------------------------------------- ----------------------------- j Formatted: Font: 10 pt, Bold ,NSP -Funded Rehabilitation Program ------------------` Formatted: Normal, justified, Indent The objective of this grogram is to prevent moderately declining neighborhoods in the 0.25', No bullets or numbering, Adjus between Latin and Asian text, Adjust s Citv from further deterieratino by su000rtino the orinciples by which the NSP oroara-n 1 between Asian text and numbers was created and by proyidino an avenue to achieve decent. safes and sanitary Conditions. "i Formatted: Font: (Default) Arial, 10 F Eligible rehabilitations j Formatted: Font: (Default) AnaMT, 7 ------------------ ----------------------------------------------------- All repairs necessary to brino the house to a decent, sate. and sanitary condition. `. `, l Formatted: Font: (Default) AriaIM r, ] Eligible Drgpettie5 Formatted: Font: (Default) Ariallsr, ] -------------------------------------------------------------------------------------- 's .' Abandoned or foreclosed upon single familv residences, townhomes, and/ or Formatted: Font: (Default) AnalMT, 1 Condominiums with a buver 2Dolvino through Strategv A.1 or A.2 as exolained above. The Formatted: Font: (Default) ArialMT, ] ropety must be Jocated within the City of Miami Formatted: Font: (Default) AraiNfr, 7 (9) Total Budget: $2:4Q0, 9 $750.000 I Formatted: Font (Default) ArialMT, 1 Underline (10) Performance Measures: 24 8 Housing units l Formatted: Font: (Default) ArialMi, 1 The following are projected numbers. The City will try to target this program to the Areas ci Formatted: Font: (Default) AriaLMT, 1 Greatest Needs and to all income levels with the understanding that will be extremely challenging Underline to have a low- income (or below) household, under current financial conditions, qualify for a Formatted: Front (Default) ArialMT, 1 mortgage loan. Formatted: Font: (Default) AriaIP1T, 1 i Formatted: Font: (Default) ArialNT, 1 Income Level Projected Estimated ;:j Formatted. Font: (Default) MaIMT, 1 Housing Units Amount Formatted: Font: (Default) ArialNT, 1 LESShaTl50perCBRAM1 _ _ �ODDDD,D© -" -- Formatted: Font: 10 t Bold Between 51-80 percent AMI 511 4 : nn firm nn p - �50.OG0 Beivreen-8 f -i20 percentAlllll e 98 TOTAL: $750.000 23 Strategy "S' Purchase and rehabilitate homes and multi -family rasidep a,' properties that have been abandoned or foreclosed upon, in order to sell, rent, or redevelop such homes and properties. (2) Activity Type: Providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income. (3) National Obiective: LMMH (Low-,Mioderate-,Middle-Housing) (4) Proiected Start Date: February 2009 (4.1) Projected Commitment Date: August 2010 (5) Proiected End Date: February 2013 (6) Responsible Organization: City of Miami Department of Community Development 444 SW 2"O Avenue, 2!0 Floor, Miami, FL 33130 Contact Information: Alfredo Duran, Deputy Director Phone,': 305-416-2080, email: aduran@miamigov.com (7) Location Description: Areas of Greatest Needs. (8) Activity Description: Purchase and Rehabilitation Proaram of Multi -Family Units or Single-famihl Units This program allows for the City or Developers to purchase' or provide assistance fully or in partially for the purchase of abandoned and/or foreclosed upon multi -family or single family structures and rehabilitate them, if necessary, to meet the requirements of the South Florida Building Code. This activity may be designated as a rental activity, homeownership activity or a combination of both. All units, or a pro -rata share of them, shall be rented to low-income families whose income does not exceed 50% of HUD's Area Median Income adjusted for family size. (9) Total Budget: $5,500,000 (10) Fer`ormance Measures: 90 Housing units The following are projected numbers. The City will target this program to the Areas of Greatest Needs and to low-, moderate-, and middle-income households. Income Level Projected Estimated Housing Units Amount Loss 'than 50 percent Ahdl 30: _ a4-000I)DO.OD , Between 51-80 percent AMI 0 5 0 Between 87-120 pe. cent ANTI 10 51;500,000.00 TOTAL: 90 $5,500,660.00- 24 1 Strategy "C" Land Banking (2) Activity Type: Area Benefit. Benefits all residents of a primarily residential area in which at least 51 percent of the residents have incomes at or below 120% of area median income; OR providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income. (3) National Obiective: LMMA (Low-, Moderate -,Middle -Income Area) (4) Proiected Start Date: February 2009 (4.1) Projected Commitment Date: August 2010 (5) Proiected End Date: February 2013 (6) Responsible Organization: City of Miami Department of Community Development 444 SW 2nd Avenue, 2"d Floor, Miami, FL 33130 Contact Information: Alfredo Duran, Deputy Director Phone *: 305-416-2080; email: aduran@miamigov.com (7) Location Description: Areas of Greatest Needs (8) Activity Description: The City will purchase? properties that have been foreclosed upon and will provide the proper maintenance to such property/ land in an effort to protect the surrounding property values from devaluating. This strategy shall be utilized whenever applicable with Strategy "D". (9) Total Budget; $851,000 (10) Performance Measures: 24 Housing units The following are projected numbers. The City will target this program to the Areas of Greatest Needs and to low-, moderate- and middle-income households. Income Level Projected Estimated Housing Units Amount Lesshan,"50 percent AM 6; .48275D OD - Between 51-80 percent AMI 6 $130,000.00 Betvreen 8'E=120 percen AIVII 12 2 8 250.00 TOTAL: 24 $851,000.00 Strategy "D" Demolition (2) Activity Type: Area Benefit. Benefits all residents of a primarily residential area in which at (east 51 percent of the residents have incomes at or below 120% of area median income; OR providing or improving permanent residential structures that will be occupied by a household whose income is at or below 120% of area median income. (3) National Objective: LMMA or LMMH (Low-, Moderate-, Middle -Area or Household) (4) Proiected Start Date: February 2009 (4.1) Projected Commitment Date: August 2010 (5) Projected End Date: February 2013 (6) Responsible Organization: City of Miami Department of Community Development 444 SW 2nd Avenue, 2nd Floor, Miami, FL 33130 Contact Information: Alfredo Duran, Deputy Director Phone #: 305-416-2080; emai(: aduran@miamigov.com (7) Location Description: Areas of Greatest Needs (8) Activity Description: The City of Miami will utilize NSP funding to demolish "blighted structures" within City limits. (9) Total Budget: $700,000 (10) Performance Measures: 24 Housing units (included in Strategy C) The following are projected numbers. The City will target this program to the Areas of Greatest Needs and to low-, moderate- and middle-income households. Income Level Projected Estimated Housing Units Amount Less than 50 �ercentAMl „. 6.17;00© 00 Between 51-80 percent AMI 6 $175,000.00 t3et teen 81-1 0 percent AM! 12 S350 000 00 TOTAL: 24 $700,000.00 26 Strate-gy "E" Redevelopment of Demolished or Vacant Properties (2) Activity Type: Providing or improving permanent residential structures that will be occupied by a household whose income is at or below 1201/o of area median income. (3) National Objective: LMMH (Low-, Moderate-, Middle- Households) (4) Proiected Start Date: February 2009 (4,1) Projected Commitment Date: August 2010 (5) Projected End Date: February 2013 (6) Responsible Organization: City of Miami Department of Community Development 444 SW 2nd Avenue, 2"d Floor, Miami, FL 33130 Contact Information: Alfredo Duran, Deputy Director Phone #: 305-416-208D; email: aduran@miamigov.com (7) Location Description: Areas of Greatest Needs (8) Activity Description: The City of Miami will acquire8 abandoned properties or properties that have been foreclosed upon and demolish the sub -standard unit, if applicable, and reconstruct a new housing unit on the same lot. Under this program, the City will purchase or provide assistance for the purchase of the property to be reconstructed, demolish the structure, and build a brand new unit to be sold to a low-, moderate- or middle-income household. The City will also be able to provide financing for the construction of new housing on vacant lots in the Areas of Greatest Need. The buyer utilizes one of the participating lenders to be pre -qualified for a mortgage loan. The City of Miami allows a Strategy A like subsidy to stay in the property, the amount of the City's loan will be based on the first mortgage lender's commitment or the City can finance the complete transaction, The City will also be able to provide financing to qualified developers for redevelopment of vacant or demolished properties into multi -family affordable rental properties. Eligible tenants' income must be less than or equal to 120% of HUD's Area Median Income, adjusted for family size. Eli-gible Buyers: The household income must be less than or equal to 120% of HUD's Area Median Income, adjusted for family size; the buyer must be able to afford a monthly payment based on income and debt; and the buyer must contribute at least $500 of personal funds toward the downpayment/ closing costs. The buyer must not hold title to another residential property at time of closing. Sales Price: The City of Miami shall sell the home in an amount not to exceed the total cost of the combined purchase and redevelopment of the property. The City will purchase abandoned or foreclosed upon properties at a discount of at least 1% from the current market appraised 27 value, taking into consideration the home's current condition and work with the buyer to find the home that best fits the buyer's needs. Loan Terms: If lender financed, the maximum amount of City NSP assistance shall be the amount necessary to meet the lender's underwriting criteria. The loan will carry a 0% non -amortizing rate for a 30 -year deferred payment period. If the City finances the total cost, payments could be dependent upon the buyer's ability to repay. Payment of principal will be forgiven at the end of maturity period provided that the homeowner resided in the house as their primary residence. Security: The loan will be secured by a mortgage on the property. First Mortoage Restrictions: Term of the loan must be 30 years. fixed interest rate & cannot exceed more than 150 basis points over Freddie Mac's weekly average 30 -year rate, as published in the Primary Mortgage Market Survey ("PMMS"); no prepayment penalties; Total percentage charged for Discount, Origination & Broker fees must not exceed 2 points; all other lending fees must be reasonable and cannot exceed 5500 or 0.5% of the loan amount, whichever is less. Resale Restrictions: If the owner sells and/ or transfer the house prior to the end of the City's mortgage term, the following provisions will apply: The sale of the property must be pre -approved by the City, and the new buyers must meet the program's income limits in effect at the time AND the sales price must not exceed the maximum affordable sales price in effect at the time. For any "early" sale or transfer , the City shall share in any gain realized, based on its pro -rated share of participation in the original purchase. Furthermore, if the sale occurs within the first 3 years, the City shall keep 1QD% of its pro -rated share of the "gain", from year 3 up to year 20, the City's share of its pro -rated "gain" shall decrease by 5% every year, while in turn, the owner's share shall increase by 51/1c, each year. At year 20 up to the City's loan maturity, the owner shall retain 100% of the City's gain. 3. The above shared gain proposal terminates in the event of a foreclosure, with the lender required to provide the City the right of first refusal to purchase the loan at a negotiated price. In the case of a foreclosure, the City will recapture any amount of net proceeds available for the sale of the property3. (9) Total Budget: $1,706,332 1 (10) Performance Measures: ' 25 Housing units The following are projected numbers. The City will target this program to the Areas of Greatest Needs and to middle-income households. Income Level Projected Estimated Housing Units Amount Between 51-80 percent AMI - Q 5400.000 TOTAL: 4-92-25 $i,7055332.0-9 $$3,056.332 NSP Substantia{ Amendment Checklist For the purposes of expediting review, HUD asks that applicants submit the following checklist along with the NSP Substantial Amendment and SF -424. Contents of an NSP Action Plan Substantial Amendment Jurisdiction(s): City of Miami NSP Contact Person: George Mensah Address: 444 SW 2 Avenue, 2 Floor Jurisdiction Web Address: Miami, FL 33130 www.miamLgov.com/Communitydeveloi)menf/ Telephone: 305-416-1978 paaes/reports Fax: 305-416-2090 Email: gmensah a-miamigov.com The elements in the substantial amendment required for the Neighborhood Stabilization Program are: A. AREAS OF GREATEST !HEED Does the submission include summary needs data identifying the geographic areas of greatest need in the grantee's jurisdiction? Yes® No[]. Verification found on page 2,3,11,12,13,14, B, Dts7wiaUTIONAND USES OF FUNDS . Does the submission contain a narrative describing how the distribution and uses of the grantee's NSP funds will meet the requirements of Section 2301(c)(2) of HERA that funds be distributed to the areas of greatest need, including those with the greatest percentage of home foreclosures, with the highest percentage of homes financed by a subprime mortgage related loan, and identified by the grantee as likely to face a significant rise in the rate of home foreclosures? Yes® No([. Verification found on page 2.3.15.16. Mote: The grantee's narrative must address the three stipulated need categories in the NSP statute, but the grantee may also consider other need categories. C. DEFINITIONS AND DESCRIPTIONS For the purposes of the NSP, do the narratives include: • a definition of "blighted structure" in the context of state or local law, Yes® No[ -1. Verification found on page 16 . • a definition of "affordable rents," Yes® No7. Verification found on page 17 . • a description of how the grantee will ensure continued affordability for NSP assisted housing, Yes® No[]. Verification found on page 18 . • a description of housing rehabilitation standards that will apply to NSP assisted activities? Yes® No([. Verification found on page 18. D. INFORMATI oN B y ACT(vlTy Does the submission contain information by activity describing how the grantee will use the funds, identifying: eligible use of funds under NSP, Yes® NoF7. Verification found on page 21-29 . • correlated eligible activity under CDBG, Yes[7 NoF7. Verification found on page 21-29 . • the areas of greatest need addressed by the activity or activities, Yes® No7. Verification found on page 21-29 . • expected benefit to income -qualified persons or households or areas, Yes® NoI7. Verification found on page 21-29. • appropriate performance measures for the activity, Yes® No7. Verification found on page 21-29 . • amount of funds budgeted for the activity, Yes® No7. Verification found on page 21-29 . • the name, location and contact information for the entity that will carry out the activity, Yes® No7. Verification found on page 21-29 . • expected start and and dates of the activity? Yes® NoF]. Verification found on page 21-29 . E. SPECIFIC AC71VITY REQUIREMENTS Does each activity narrative describe the general terms under which assistance will be provided, including: If the activity includes acquisition of real property, • the discount required for acquisition of foreclosed upon properties, Yes® NoF. Verification found on page 22.27. If the activity provides financing, • the range of interest rates (if any), Yes® No7. Verification found on page 21-28. If the activity provides housing, • duration or term of assistance, Yes® No7. Verification found on page _21-28 • tenure of beneficiaries (e.g., rental or homeownership), Yes® No7. Verification found on page 21-28. • does it ensure continued affordability? Yes® No7. Verification found on page 21-28. • does the applicant indicate which activities will count toward the statutory requirement that at least 25% of funds must be used to purchase and redevelop abandoned or foreclosed upon homes or residential properties for housing individuals and families whose incomes do not exceed 50% of area median income? • Yes® NoF7. Verification found on page _21-27 F. Low INCOME TARGETING • Has the grantee described how it will meet the statutory requirement that at least 25% of funds must be used to purchase and redevelop abandoned or foreclosed upon homes or residential properties for housing individuals and families whose incomes do not exceed 50% of area median income? Yes® No[]. Verification found on page 19 . • Has the grantee identified how the estimated amount of funds appropriated or otherwise made available will be used to purchase and redevelop abandoned or foreclosed upon homes or residential properties for housing individuals or families whose incomes do not exceed 50% of area median income? Yes® No7. Verification found on page 19 . Amount budgeted = $4.737,750 G. DEMOLISHMENT OR CONVERSION OF Low- AND MODERATE -INCOME UNITS Does grantee plan to demolish or convert any low- and moderate -income dwelling units? Yes® No7. (if no, continue to next heading) Verification found on page 26 . Does the substantial amendment include: • The number of low- and moderate -income dwelling units—i.e,, _< 80% of area median income—reasonably expected to be demolished or converted as a direct result of NSP - assisted activities? Yes® No17. Verification found on page 26 . • The number of NSP affordable housing units made available to low- , moderate-, and middle-income households—i.e., s 120% of area median income—reasonably expected to be produced by activity and income level as provided for in DRGR, by each NSP activity providing such housing (including a proposed time schedule for commencement and completion)? Yes® NoO. Verification found on page 16.19.23.24.25.26.29 . • The number of dwelling units reasonably expected to be made available for households whose income does not exceed 50 percent of area median income? Yes® No7. Verification found on page 19.23.24.25.26. H. PUBLIC COMMENT PERIOD Was the proposed action plan amendment published via the grantee jurisdiction's usual methods and on the Internet for no less than 15 calendar days of public comment? Yes® NoO. Verification found on page 20 . Is there a summary of citizen comments included in the final amendment? Yes No❑ Verification found on page None . 1. WEBSITE PUBLICATION The following Documents are available on the grantee's website: • SF 424 Yes® No❑ • Proposed NSP Substantial Amendment Yes No❑ • Final NSP Substantial Amendment Yes® No❑ • Subsequent NSP Amendments YesZ No[] Website URL: www.miamioov.com/communitvdevelot)ment/r)aaes/Reports/ K. CERTIFICATIONS The following certifications are complete and accurate: (1) Affirmatively furthering fair housing Yes® No❑ (2) Anti -lobbying Yes® No❑ (3) Authority of Jurisdiction Yes® No❑ (4) Consistency with Pian Yes® No❑ (5) Acquisition and relocation Yes® No❑ (6) Section 3 Yes® No❑ (7) Citizen Participation Yesz No❑ (8) Following Plan Yes® No❑ (9) Use of funds in 18 months Yes® No❑ (10) Use NSP funds < 120 of AW Yes® No❑ (11) No recovery of capital costs thru special assessments Yes® No❑ (12) Excessive Force Yes® No❑ (13) Compliance with anti -discrimination laws Yes® No❑ (14) Compliance with lead-based paint procedures Yes® No❑ (15) Compliance with laws Yes® No❑