‘Form 2, Form 3 & Attachments’ Questions

Form 2 Question:
I have a question about “Recap of Funding Sources” on Form 2. One of the sources listed on this table is “owner equity”. I thought that our SHIP office was supposed to report any money an applicant contributes to pay for his or her overall housing assistance. But my co-worker has told me that we are supposed to calculate the amount of equity that a rehabilitation applicant owns in a house to be repaired. Please provide guidance.

Answer:
You are correct. On the “Recap of Funding Sources”, record only the amounts that an applicant pays to purchase a house, to repair a dwelling, or to in some other way pay for a portion of the housing assistance provided.


Form 2 Question:
I have a question about “Recap of Funding Sources” on Form 2. Our jurisdiction provided SHIP funds to the local Housing Authority to build 30 of the 171 units in a new rental project. By the end of the fiscal year, 30 units were built and occupied. We are assigning 15 of them the close-out distribution, and we will report the SHIP assistance for construction of the other 15 on the annual report for the next distribution. We have split them up in this way to help meet very-low-income set-aside requirements.

When I add up the public and private contributions to the “Recap of Funding Sources”, how much should I attribute to each batch of units on the two separate reports? Should I divide the amount of those funds in half, or should I count them all on both reports?

Answer:
Assign the amount of public and private funds based on the proportion of total units that appear on an annual report. It this case it is simple: each report contains half of the total units, so equally split the public and private funds between the reports. If 10 units were assigned to the close out distribution and 20 to the next distribution, then one third of public and private funds would be added to the former report with the other two thirds on the latter report.




Question:
I have a question on Form 2 about “Project Funding: Expended Funds”
Sometimes our jurisdiction provides SHIP assistance as a loan and grant to the same household. The majority of assistance is a forgivable loan, although a small portion is granted. How would I count this on Form 2, which asks for numbers of Loans and Grants?

Answer:
Since the majority of assistance was a loan, count the full amount of assistance as a loan on the annual report. The reverse would be true if a household received assistance mostly as a grant.

Question:
On the "Regulatory Reform Certification" page that accompanies the Annual Report, how do we calculate the dollar amounts for Sections 3 and 4?

Answer:
Section 67-37.019 (5) of the SHIP Rule outlines the following “Incentive Strategy” requirements for all SHIP jurisdictions:
The local government staff or entity with administrative authority for a local housing assistance plan shall provide documented evidence to the Corporation or its designated monitoring agent, that:
(a) Permits, as defined in Sections 163.3164(7) and (8), F.S., for affordable housing projects are expedited to a greater degree than other projects; and
(b) There is an ongoing process for review of local policies, ordinances, regulations, and plan provisions that increase the cost of housing prior to their adoption.

The “Certification for Implementation of Regulatory Reform Activities Required by SHIP” is one main method that the Florida Housing Finance Corporation uses to document a jurisdiction’s compliance with this SHIP requirement.

Sections 1 and 2: These are simply statements to evidence that the jurisdiction has implemented the incentive Strategies (a) and (b) that are referenced in the SHIP Rule.

Section 3: First, enter the Fiscal Year that is ending this June 30.
Talk with the group or individual in your jurisdiction that performs the “Ongoing Review” SHIP incentive strategy and ask them about their review process during the 12 months of this fiscal year. Include in Section 3 the group’s per unit estimate of housing cost increases for new construction that have resulted from new local policies, ordinances, regulations, and more that were considered during the state fiscal year. If there have been no new policies to increase costs, enter $0.

Section 4: Similar to Section 3, provide in Section 4 the group’s per unit estimate of housing cost increases for rehabilitation activities that have resulted from new local policies, ordinances, regulations and more that were considered during the state fiscal year. If there have been no new policies to increase costs, enter $0.


NOTE: The SHIP Statute and Rule provide no guidance or method by which a local jurisdiction must determine the cost increase that will result from a new rule, ordinance, fee, etc. Such estimates are a local determination, and the jurisdiction should retain back up material to justify the dollar amounts reported on this certification form, which is signed by the jurisdiction’s chief elected official.