FORM 4 Questions

Question about ‘Expended Funds’:
On Form 4, I added an amount of expended funds per strategy that exactly matches the figures reported on Form 1. Yet the Review Tab still shows an error. Specifically, it indicates:
“There are no "Expended Funds" records for the "Homebuyer Assistance" strategy listed under the Distributed Funds' "Home Ownership" section on Form 1.”
Please provide guidance.

Answer:
This is a result of an update Florida Housing has made to the web annual report. Florida Housing has now programmed the web system to total up the expended funds for each strategy. Now, a “Summary by Strategy” total appears at the end of the list of expended funds you have added to Form 4.

The error in this case is caused by the fact that this jurisdiction labeled a strategy “Homebuyer Assistance” on Form 1, but called it “Purchase Assistance” next to the name of each buyer listed on Form 4. In order for Florida Housing’s new programming to work properly, the name of each strategy must be identical on Forms 1 and 4. Pay attention to capitalization, since this also makes a difference. In this case, the jurisdiction decided to change the strategy name on Form 1 to “Purchase Assistance” and the error message disappeared.


Question about ‘Administrative Expenses’:
For this Form 4 question, do you count all of a jurisdiction’s expenses paid for administration and program implementation? In other words, should I include the administrative expenses that our jurisdiction paid with the five percent of our program income, as allowed by the SHIP Statute?

Answer:
No. You must count only the administrative expenses paid with the 10 percent administrative budget. Do not include administrative expenses paid with program income. You should also not count any program dollars that paid for ‘service delivery fees’ when a sub recipient implemented one or more of your SHIP strategies.


Question about ‘Administrative Expenses’:
Form 4 asks for a breakdown of Administrative expenses by the Local Government and by its Sub Recipients. Our city hires an individual to teach our homebuyer classes. We also contract with a housing inspector who handles our rehabilitation inspections on a fee for service basis. Are these individuals considered Sub Recipients?

Answer:
Florida Housing’s staff has provided this answer:
This term was added to identify those organizations or individuals that are contracted by the local government to administer a portion of the SHIP program and are compensated by SHIP “Administrative Expenditures” funds. The list of Sub Recipients will be reported on the annual report to allow Florida Housing to know where all Administrative Expenditure funds are being spent. This requirement is not intended to require you to list your lenders, inspectors or other vendors that are involved in the SHIP process that are compensated through program funds. Here is the simple way to view this: if they are paid by your traditional ten percent administrative budget, then they should be listed.





Question about Incentive Strategies:
In filling out Form 4 of the annual report, I checked our jurisdiction’s old reports, which referenced the Local Housing Assistance Plan (LHAP). Should I reference the LHAP that was in effect for the close out distribution, or the current LHAP which just went into effect?

Answer:
Reference your most recent LHAP for purposes of the question about incentive strategies. You must provide the most updated information about how these incentive strategies are implemented. Commonly, jurisdictions write very little here beyond “strategy is fully implemented.”


Question:
Do I have to complete Form 4 for each of the three distributions reported this September?

Answer:
No, the online reporting system only requires a jurisdiction to complete the data for Form 4 once, when creating the close-out annual report. In the past, jurisdictions were required to answer several Form 4 questions with data specific to each of three distributions. Now Florida Housing will only collect data specific to the closeout distribution for the Form 4 questions about average strategy production costs, administrative expenditures for sub recipients, and sources of recaptured funds and program income.

There is now only one Form 4 question that requires data specific to each of three distributions. As required by SHIP reporting instructions, each local government must provide a list of recipients for whom assistance is complete and funds are fully expended. This data must be provided for each strategy, including names, addresses, zip codes and amounts expended for each fiscal year reporting to Florida Housing.


Question about Defaults and Foreclosures:
Form 4 asks about mortgage foreclosures and mortgage defaults. Please help me understand how to track and report this information.

Answer:
This question only requests information about defaults of the first mortgage on the home of a household that has received SHIP purchase assistance. Do not collect information about defaults of SHIP liens. A default occurs when a homeowner falls behind on paying the first mortgage. By contrast, a foreclosure occurs when a homeowner goes through the legal process and loses his or her house to foreclosure. Not all of those who are in default will eventually foreclose.

You can track this information by maintaining a list whenever you hear that a former SHIP homebuyer has fallen late in payments for the first mortgage on the unit. The recipient may call you to request help. Your county's legal department may receive a “lis pendens” notification. Later on, you should check back to learn if any recipients actually lost their homes to foreclosure. This is all that is required by way of tracking this data.

It is possible that a person may fall into default more than once in the 12 month period on which you are reporting—this household should only be counted as one default during the 12 month period. It is also possible that this household might also default at some time in the next 12 months. In this case, you will count and report this household’s default in the next Annual Report you submit a year from now. Similarly, a household might count as a default in one 12 month period and count as a foreclosure in the next 12 month period.