Public Housing Repositioning

Public Housing

Recap brings deep familiarity with public housing authority (PHA) challenges, having worked with more than 45 PHAs in 24 states across the country on a variety of tasks including Strategic Planning, Portfolio Feasibility Analyses, Rental Assistance Demonstration (RAD) conversions, Section 18 Demolition/Disposition, and implementing a Project-Based Voucher (PBV) Program.

Rental Assistance Demonstration (RAD), Component I

Recap is a leader in HUD’s Rental Assistance Demonstration (RAD) program. We have represented more than 30 Public Housing Authorities as a consultant in various stages of the program. Recap has extensive experience with RAD as both a RAD Consultant and a RAD Readiness Transaction Manger and can assist a PHA with the following:

Strategic Planning

Prior to moving forward with a RAD transaction, Recap will take into consideration the long term goals and mission of the PHA. A RAD conversion must be viewed holistically at the agency level because it will impact not only the residents, but the staff, the Board of Directors and the entire organization on many levels.

The strategic planning process will also produce the transaction sequencing and time lines. Some RAD transactions may require the use of low-income housing tax credits (LIHTC) and some transactions may produces excess proceeds. Both will impact the sequencing and time line. If the feasibility analysis suggests the use of LIHTC and the PHA does not have development experience, we can help the PHA decide whether hiring a Development Partner would benefit the PHA and understand what that relationship would look like.

Feasibility Analysis

Recap will collect all financial data and physical needs information from the PHA to determine the feasibility of converting a single project or a portfolio of projects under RAD. The analysis will consider all of the HUD tools available to PHAs to improve the viability of the transaction, such as rent bundling, Section 18/RAD combo, utility allowance reductions, and more.

Resident Rights and Consultation

Resident Rights are at the forefront of the RAD program. As part of a RAD conversion, the PHA must meet with the residents prior to submitting the RAD application. We strongly encourage the PHA to meet with the residents as often as possible during the conversion process, because the key to a successful RAD conversion is frequent and effective communication with all stakeholders. The Recap Team has a wealth of experience conducting resident meetings and answering questions related to RAD conversions and Resident Rights.

The Recap Team is also experienced with nonprofit Board Training and can serve as a liaison between the Board, the PHA, and government officials.

RAD Applications

Recap has assisted PHAs with the submission of over 80 RAD applications including Portfolio, Multiphase and Many-to-One. A revised and streamlined RAD Application is now available on the RAD Resource Desk which must be submitted electronically

RAD Financing Plan

In our role as RAD Transaction Manager on behalf of HUD, Recap is keenly familiar with Financing Plan submission requirements determined by the type of financing. We can assist the PHA with the following elements of a Financing Plan:

  • Procure third-party vendors to provide required reports including physical needs assessments and environmental reviews;
  • Review the CNA E-Tool for accuracy;
  • Weigh the pros and cons of converting to long-term Section 8 via a project-based voucher (PBV) contract or a project-based rental assistance (PBRA) contract;
  • Secure Fair Housing and Equal Opportunity approval when the review is triggered by a component of the financing plan;
  • Payoff or subordinate any existing debt such as Energy Performance Contract (EPC) or Capital Fund Financing Program (CFFP);
  • Negotiate lender and equity terms and produce a financial model;
  • Cut expenses and produce a viable 20-year operating proforma;
  • Complete loan, soft financing and LIHTC applications; and
  • Navigate the RAD Resource Desk and upload Financing Plan items.

RAD Transaction Closing

The Recap Team has collectively closed over 50 RAD Transactions ranging from no-debt conversions to scrape and rebuild with 9% LIHTC as well as Mixed-Finance Transactions and FHA. We have a deep knowledge of the HUD Closing Requirements, including managing the timelines, familiarity with the closing documents and a solid relationship with the HUD Closing Attorneys and Closing Coordinators.

Relocation

The Recap Team works closely with PHAs to make sure they follow the relocation guidance outlined in PIH Notice 2016-17, RAD Notice Regarding Relocation Requirements. Depending on the scope of rehab, residents 1) may not need to relocate at all 2) may need to move out of their units for a short time period, but not off site. These residents can be accommodated in vacant units accrued prior to closing until their unit is rehabbed 3) may need to move off site. Several of the transactions we consulted on required residents to move off-site for more than 12 months, triggering the Uniform Relocation Act. There are special provisions related to moving residents prior to closing and to other public housing units which we convey to the PHA. We strongly encourage PHAs to hire Relocation Consultants when URA is triggered.

Transition from Public Housing to Section 8

Before a PHA completes a RAD conversion, there are several organizational changes that should be anticipated when transitioning to long-term Section 8:

  • Post Conversion Staffing
  • Financial Operations and Budgets
  • Occupancy Requirements
  • Funding
  • Software platform
  • Replacement Reserve Requirements
  • Rent adjustments

Recap can help the PHA anticipate the changes prior to them becoming problematic.


Section 18 Demolition/Disposition

The Recap Team has experience with the demolition/disposition of public housing property through Section 18 of the U.S. Housing Act of 1937. Recap has an established relationship with the Special Applications Center (SAC) and has a full understanding of the current regulations at 24 CFR Part 970 and guidance in newly released PIH Notice 2018-04. Some of the highlights for PHAs include:

  • PHAs that own 50 or fewer public housing units under its ACC and has determine that it is in the best interest of the residents and PHA to close out its Section 9 public housing program may dispose of their units and receive Tenant Protection Voucher (TPV) funding;
  • PHAs converting at least 75 percent of the public housing units within a project under RAD and meets the requirements of the RAD Notice and is doing substantial rehabilitation without 9% LIHTC, can receive project-based vouchers for the remaining 25% of the units in the project. The rent will equal the payment standard for the 25% Section 18 PBVs.
  • PHAs with Scattered Site units who demonstrate they are unsustainable to operate and maintain, may dispose of the public housing units and the residents will PHA will receive TPV funding.

Recap can assist a PHA with a Section 18 application submission in full or in part.


Section 8 Housing Choice Voucher Program

 

Recap’s work with the Section 8 Housing Choice Voucher program has focused primarily on project based vouchers (PBVs). We offer an analysis of the differences between Project Based Rental Assistance and Project Based Vouchers to PHAs which is key to guiding clients in the RAD context. We consult with PHAs on project-basing of Housing Choice Vouchers and on the administration of project-based Housing Choice Voucher contracts. Most recently we worked with the Independence Housing Authority of Missouri to implement a PBV program to be used at Heritage House.