Proposed Consolidated Plan and 2015 Action Plan
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1 PROGRAM SPECIFIC REQUIREMENTS This section describes specific HUD program requirements for the Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), Emergency Solutions Grant (ESG) programs. 232
2 VII. Program Specific Requirements 1. Community Development Block Grant Program (CDBG) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out. a. The following identifies program income that is available for use that is included in projects to be carried out 1. The total amount of program income that will have been received before $0 the start of the next program year and that has not yet been reprogrammed 2. The amount of proceeds from section 108 loan guarantees that will be $0 used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan 3. The amount of surplus funds from urban renewal settlements $0 4. The amount of any grant funds returned to the line of credit for which the $0 planned use has not been included in a prior statement or plan. 5. The amount of income from float-funded activities $0 Total Program Income $0 Other CDBG Requirements 1. The amount of urgent need activities $0 2. HOME Investment Partnership (HOME) a. A description of other forms of investment being used beyond those identified in Section is as follows: DuPage County does not utilize forms of investment beyond those identified in 24 CFR (b). 233
3 b. A description of the guidelines that will be used for the resale or recapture of HOME funds when used for homebuyer activities as required in , is as follows: The only homebuyer activity anticipated under this Action Plan is the first time homebuyer program administered through the DuPage Homeownership Center. This activity will provide down payment assistance for acquisition of existing housing. This activity will utilize recapture, with a pro-rata reduction for the time the homebuyer has owned and occupied the housing, measured against the required affordability period. The maximum HOME funds available to the homebuyer are $14,999, so the affordability period is five years. (HOME regulations require the following minimum periods of affordability in relation to the HOME dollars invested per unit: Under $15,000 five years; $15,000 to $40,000 ten years; over $40, years.) These funds are direct subsidy; there are no development costs involved in this activity. (Development subsidy is not subject to recapture.) The HOME funded homebuyer assistance will be secured by a zero-interest, deferred payment mortgage on the property. When the property is sold or the title transfers, the pro rata balance will be due. If the property is no longer occupied by the HOME-eligible household that originally purchased the property during the period of affordability, entire amount of the HOME investment becomes due. This recapture is subject to the limitation that when the recapture requirement is triggered by a sale (voluntary or involuntary, and also including foreclosure or deed in lieu of foreclosure) of the housing unit, and there are no net proceeds or the net proceeds are insufficient to repay the HOME investment due, DuPage County can only recapture the net proceeds, if any. Recaptured funds will be deposited in the HOME account and used for other HOME-eligible activities. DuPage County will not be undertaking any other homebuyer activities under this Action Plan, nor will it be undertaking any homebuyer activities using resale under this Action Plan. c. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR (a) (4) are as follows: As stated above, the only homebuyer activity anticipated under this Action Plan is the first time homebuyer program administered through the DuPage Homeownership Center. This activity will provide down payment assistance for acquisition of existing housing. This activity will utilize recapture, with a pro-rata reduction for the time the homebuyer has owned and occupied the housing, measured against the required affordability period. The maximum HOME funds available 234
4 to the homebuyer are $14,999, so the affordability period is five years. (HOME regulations require the following minimum periods of affordability in relation to the HOME dollars invested per unit: Under $15,000 five years; $15,000 to $40,000 ten years; over $40, years.) These funds are direct subsidy; there are no development costs involved in this activity. (Development subsidy is not subject to recapture.) The HOME funded homebuyer assistance will be secured by a zerointerest, deferred payment mortgage on the property. When the property is sold or the title transfers, the pro rata balance will be due. If the property is no longer occupied by the HOMEeligible household that originally purchased the property during the period of affordability, entire amount of the HOME investment becomes due. This recapture is subject to the limitation that when the recapture requirement is triggered by a sale (voluntary or involuntary, and also including foreclosure or deed in lieu of foreclosure) of the housing unit, and there are no net proceeds or the net proceeds are insufficient to repay the HOME investment due, DuPage County can only recapture the net proceeds, if any. Recaptured funds will be deposited in the HOME account and used for other HOME-eligible activities. DuPage County will not be undertaking any other homebuyer activities under this Action Plan, nor will it be undertaking any homebuyer activities using resale under this Action Plan. d. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR (b), are as follows: DuPage County will not be undertaking any refinancing of existing debt secured by multifamily housing that is rehabilitated with HOME funds. 3. Emergency Solutions Grant (ESG) a. Include written standards for providing ESG assistance (may include as an attachment) The Homelessness Prevention Providers Committee (HPP) of the CoC has written standards for providing assistance under the Emergency Solutions Grant. They are provided as an attachment in Appendix H. 235
5 b. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system. The CoC is working to implement a coordinated assessment system and centralized waiting list. The Needs Assessment Committee of the CoC appointed a subcommittee to undertake this project. Representatives from the DuPage County Health Department, DuPage PADS, Catholic Charities, People s Resource Center, Family Shelter Service, the DuPage Housing Authority, and DuPage County Community Services sit on the committee. By May, 2014, the subcommittee had instituted a pilot program whereby the Vulnerability Index-Service Prioritization and Decision Assistance Tool (VI-SPDAT) was being utilized in client interviews with existing clients on the waiting list to determine if the tool was accurately identifying the housing needs of the clients versus case management identified needs. Subsequent to that time, other tools have been discussed and HMIS staff has been working to see how HMIS can incorporate the coordinated assessment tool. The next meeting of the subcommittee will be January 9, 2015, and the information in this paragraph will be updated after that meeting. c. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations). The Administration funds will be utilized by DuPage County, the recipient of the ESG funds; no sub-award of Administration funds will be made. The HMIS funds will be utilized by DuPage County as the lead agency of the CoC and entity responsible for the HMIS; no sub-award of HMIS funds will be made. The remainder of the ESG allocation is available to organizations that are members of the CoC and which are undertaking projects that advance the strategic plans of the CoC. The CoC determined that Homelessness Prevention and Rapid Re-Housing funds will be made available for sub-recipients that previously received sub-awards under HPRP, as a pool of funds. The CoC also determined that the subawards to DuPage PADS, Catholic Charities, and Bridge Communities would continue in accordance with the forward commitment of funding approved through the CoC during the 2013 and 2014 program years. The award to Prairie State Legal Services was approved through the CoC to replace funding lost under the HUD Super-NOFA process, as CoC agencies regard the legal assistance provided by Prairie State to be an essential component of the collaborative effort to resolve issues that prevent homeless persons from obtaining and sustaining housing stability. 236
6 d. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR (a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG. Because the County Board is an elective body, it is not possible to provide for the participation of a homeless individual or formerly homeless individual on the board. A formerly homeless individual sits on the Leadership Committee of the CoC. We will further implement the following consultation plan: (1) survey of persons existing an ESG funded program or shelter to determine what needs were met by the program and what needs are unmet; (2) focus group of homeless individuals. e. Describe performance standards for evaluating ESG The application process and selection criteria for ESG funding has been developed in conjunction with and approved by the Leadership Committee and Grants Funding Committee of the CoC. Outcome measures (performance standards) are then developed for each subrecipient, based on their application, and reported through HMIS. Targeting those who need assistance most is accomplished at the application review, as needs with higher priority in the Consolidated Plan are assigned a higher multiplier so that applications addressing those needs receive a higher score. We continue our efforts to better identify best practices for reducing the number of people living on the streets or in emergency shelters and for shortening the time people spend homeless by continuous data quality analysis of data being entered into HMIS. Current case management practices are aimed at reducing each program participant s housing barriers or housing stability risks and are quantified and captured as needs identified and needs met in HMIS. The written standards are attached as Appendix H. 237
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