HomeMy WebLinkAboutLetter 2Cut! of iami
t CDRO G. HERNANUkL Kt.
City Manager
Septen111cr 24. 2007
Armando Fana, Director
HUD Miami Field Office
8rickell Plaza Federal Building
909 SE First Avenue,
Room 500
Miami, Ft 33131-3028
Re: Conflict of Interest Determination and Waiver
Dear Mr. Fano:
On December 8, 2004, the City of Miami ("City") provided $815,000 CDBG grant to
Ailapatah Business Development Authority ("ABDA"), a community based organization, for
the pre -development ccst of a town home development project called "Ralph Plaza II." The
project primarily serves low and moderate income families, that is, at least 51% of the units
wit be sold to low and moderate income families.
On May 15, 2007, a City employee entered into a contract with ABDA for the purchase of a
unit in this project. The employee's income Is a tittle over 80% of median income and
therefore the unit being purchased will not be one of the units at 80% of median income.
Based on the information above, the City seeks to inquire whether the conflict of interest
provision in 24 CFR 570.4B9(h) applies to all the units of the project or just to the units at
80% of median income.
If HUD determines that the conflict of Interest provision .applies to all units in the project,
then the City seeks by this letter to request a waiver of those provisions based on the
following:
(i) The employee does not work in the department charged with the administration of
CDBG funding.
(ii) The employee is in no position to exercise functions or responsibilities with respect
to CDBG activities.
((ii) The employee does not participate in a decision making process or gain inside
• information with regard to the activities of the department responsible for
administering the CDBG program.
The City believes waiving this conflict is in the best interest of the program and allows City
employees not to be prohibited from benefiting from activities meant to benefit the general
population.
DFPARb r; NT OF COMMUNITY DEVE W ✓rink N r
44d S.W. 2nd Avenue. 2 rid Fluor i Mlanll. Fldr.(ia 3311U 7 11Ui) 41 b•1 UN) f F44. 13051 116.3n90
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Armando Tana
Page 2
Wernher 24, N
The developer has kindly reserved this unit pending your response to this letter. A prompt
response to this letter will assist the City In providing guidance to the developer regarding
this unit.
Thank you for your continuing support to the City in ow effort to provide affordable housing
to residents of our city.
Sincerely,
Hector Mirablie
interim Director