Appendix 4.xlsx

Summary

Property / Site Manager's Name Since: (Mo/Yr)

Name / Title Date Name / Title Date

Asset Manager Supervisor - Rental Compliance

Development's Description:

Non-IHDA/HUD Subsidies

Term of Subsidy Contract(s)

Addt'l IHDA Program Units

Unit Composition

Additional Addresses

Number and Type of Bldg.

Amenities

Have all findings from prior management/desk/tenant file reviews been resolved? YES

NO

N/A

Comments to Findings/Management Review Questions:

Questionnaire

Part A: Maintenance and Security

a. Are grounds and landscaping in acceptable condition?

f. Are all outdoor amenities in acceptable condition?

i. Which type of inspection was completed?

j. Capital improvements completed and/or planned for the current year?

1. General Physical Condition A C

2. Work Scheduling

2. Work Scheduling A C

3. Vacant Unit Preparation

3. Vacant Unit Preparation A C

4. Security Program

a. Is exterior lighting adequate for protection and visual security?

b. Is the development free of major security problems?

Break-ins Personal assault

Vandalism Other Auto theft

4. Security Program A C

I. Maintenance and Security Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part B: Financial Management

e. Are there adequate controls over cash/receipts accepted?

Prenumbered rent receipts Safe

Bank collections Lock box

Check scanner Online / resident portal / ACH

5. Accounting and Bookkeeping A C

6. Submission of Reports

1) Annual audited financial statement

Date last report was due / /

Date last report received / /

2) Annual operating budget Date received

6. Submission of Reports A C

7. Budget Management

a. Is an operating budget prepared annually and is it approved by the owner?

7. Budget Management A C

8. Financial Compliance

a. Has owner corrected all findings on IHDA financial submission?

20 DCR

20 DCR

20 DCR

Cash $ Accounts receivable $

Accounts payable $

8. Financial Compliance A C

9. Rent Schedule Compliance

Identify any discrepancies below:

Rent Used Approved/Maximum Rent Rent Used Approved/Maximum Rent

d. Was the annual utility allowance analysis submitted?

9. Rent Schedule Compliance A C

Late charge of $ on day.

Eviction procedures commence on day.

Referred to collection agent on day.

10. Rental Collection Practices A C

11. Accounts Receivable / Payable

If no, what is the percentage for: year % year %

d. Are bills paid in sufficient time to avoid late penalties?

11. Accounts Receivable/Payable A C

12. Reserves and Escrows a.

12. Reserves and Escrows A C

II. Financial Management Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part C: Leasing and Occupancy

d. Is rental staff familiar with AFHMP?

e. Does the site signage have logos?

f. Is the EHO poster displayed in offices and model units?

2.) was it the appropriate size?

White %

Black/African American %

American Indian/Alaska Native %

Asian %

Native Hawaiian/Pacific Islander %

Other %

Not Hispanic or Latino %

n. What staff positions are/will be responsible for affirmative marketing?

p. In accordance with the Fair Housing Act:

q. How many units are accessible?

r. FOR CDBG ONLY

If Yes, answer Question 2.; If No skip to Question 3.

If Yes, provide the person's name and telephone number below.

Name:

Telephone Number:

13. Tenant Selection and Orientation A C

14. Vacancy, Turnover and Market Conditions

a. On the day of the site visit:

b. Is the vacancy rate satisfactory and not excessive?

c. Do any of the following factors contribute to vacancy problems?

Security problem Poor maintenance

Non-competitive amenities Rents too high

Inadequate marketing Location

Development reputation Lack of demand

Bedroom mix/size ( bdrm hard to rent)

Tenant/management relations Other

e. Are damages documented and are tenants assessed the actual charges?

Date update letter was sent to applicant

Was wait list purged? When?

How many are currently on wait list?

Is the wait list currently open closed

Does the wait list include all required elements?

Were the applicants selected in proper order from the waiting list?

g. Is surrounding neighborhood market prosperous, average, or depressed?

h. Are surrounding neighborhood conditions improving, stable, or declining?

i. Are the market conditions affecting occupancy?

k. Is there saturation of affordable housing?

14. Vacancy and Turnover A C

15. Leases and Deposits

15. Leases and Deposits A C

16. Eviction Procedures

a. Does management have a written policy for handling evictions? Source?

16. Eviction Procedures A C

III. Leasing and Occupancy Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part D: Tenant/Management Relations

17. Tenant Satisfaction A C

IV. Tenant/Management Relations Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Part E: Drug-Free Housing Policy

A C

19. Evidence of Drug Activity

A C

V. Drug-Free Housing Policy Rating

Part F: General Management Practices

Name of field supervisor(s)

Freq. of visits by supervisor

20. Organization and Supervision A C

21. Staffing and On-Site Office Administration

a. List all staff billed to development account.

b. Are there signs enabling applicants/tenants to easily locate the office?

c. Is office organized and neat in appearance?

d. Are office hours posted?

e. Are office hours convenient for prospective applicants and tenants?

f. Are emergency phone numbers posted? Where?

g. Is there an acceptable key control system?

21. Staffing and On-Site Office Admin. A C

22. Operating Procedures and Manuals

a. Is there a procedures manual on-site for staff use?

22. Operating Procedures and Manuals A C

23. Training

a. Are the types of skills of staff appropriate for this development?

b. Does owner/agent have an ongoing training program for its staff?

On-site (Frequency )

IREM NCHM HUD seminars Local colleges

Fair Housing training Date

Energy conservation

Other

How are updates communicated?

23. Training A C

24. Insurance and Bonding Submit insurance certificate renewals if the insurance will expire within 90 days or less.

a. List current insurance coverage and expiration date.

Property $

Liability $

Umbrella $

Fidelity $

24. Insurance and Bonding A C

25. Management Agreement Submit updated Management Agreement if the current agreement will expire within 90 days or less.

Management fee %

25. Management Agreement A C

26. Program Compliance

a. Was the Consolidated Certificate of Compliance received?

When:

26. Program Compliance A C

VI. General Management Practices Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory

Number of program units Number of files reviewed

Name Unit Name Unit Name Unit

27. Resident File Maintenance and Security

c. Is there a file organization system?

Is it followed consistently?

27. Resident File Maintenance A C

28. Household Information

b. Does the application contain sufficient information to determine eligibility?

c. Was all move-in screening completed per the Tenant Selection Plan?

If a household was ineligible at move in, were exceptions granted?

28. Household Information A C

29. Verification

a. Have all verification items been verified and properly documented?

29. Verification A C

30. Leases

a. Were the correct program leases used?

b. Were the leases signed and dated by all parties?

c. Were all applicable addendums/attachments added to the lease?

d. Was security deposits collected in the correct amount for the program type?

e. Were pet deposits charged according to the pet policy?

30. Leases A C

31. Inspections

31. Inspections A C

32. Certification / Recertification Activities

b. Was the Tenant Income Certification form (TIC) in the tenant file?

c. Were income and assets calculated correctly?

d. Were the correct rent and income limits used?

32. Certification/Recertification Activities A C

33. Move-Out File Review

a. Did the move-out files include the required documentation?

33. Move-Out File Review A C

34. Applicant Rejection Review

a. Did the applicant rejection letter include the required criteria?

b. If appealed, were criteria met?

34. Applicant Rejection Review A C

VII. File Review Rating

Superior Above Average Satisfactory

Below Average Unsatisfactory Not Rated

Attachment A - tenant concerns

Issue/Complaint Status

Instructions

Development name & address: include addresses for all buildings. Use Development Description area of summary page if necessary for additional addresses.

If this is a scattered site, for example, use one address on the first page and list the remaining addresses in Development Description.

Owner entity: review management agreement, regulatory agreement, or audit. Use legal entity name.

Type of program: list all program types in senior loan position - i.e. HOME, Section 8 and/or Tax Credits. IHDA programs only - do not use abbreviations. Do not include LTOS, SRN or 811 here, as Rental Compliance does not monitor these programs. They are captured under Additional IHDA Program Units in the Development Description.

IHDA number: list all loan numbers by lien position (i.e. 17-2037-01), and IHDA TC number (federal & state). Use the Benedict numbering system, not the portfolio system.

Number of Program units: list for the highest IHDA position only

Date of last annual inspection: insert the date of the most recent on-site management review. This does NOT include the physical inspections. These inspections are addressed in part A.

Transferred to AM: omit MLs. Obtain from DMS, Project Dates.

Maturity date: obtain from Benedict.

Year of construction: insert year built. Refer to project summary. If construction year is not indicated, ask owner/agent.

Name / Title: type the name of the AM who completed the review; adjust title for Senior AMs.

Review Approved By: the approving Rental Compliance Supervisor will insert their digital signature into the PDF version of the final report.

Name / Title: type the name of the Rental Compliance Supervisor.

Indicate term of any subsidy contract, including expiration date. For those developments where IHDA is not the Contract Administrator, obtain HAP contract info and indicate ending date. Also, identify the contract term. If not indicated, review the notes in the audit for this information.

Amenities: do amenities match the project summary?

Work out & additional comments: refinance, loan modification, transfer of physical assets, Owner or Agent changes, market changes. Review current Loan Monitoring Agenda.

Have all findings from prior reviews been resolved: List any outstanding/unresolved findings from the prior review (limited to the prior year). If there are outstanding findings, include specific findings. Unresolved code violations, audits, TSP and AMP updates, budgets, or tenant file audits, will result in an automatic Below Average or Unsatisfactory based on the number of findings.

2. Create a “general finding” definition for each common finding throughout your file audit. List them all general findings first. The definitions are to be separate and used for a reference for the O/A on your MOR report. Example: General Finding A: 5 out of 10 files were missing income verifications; General Finding B: most files were using incorrect rent/income limits.

Finding a: The file does not contain the credit check, criminal background check, or sex offender screening for adult household member Dante, as required by the Tenant Selection Plan. Management must either complete all screening as indicated in the TSP, or revise the TSP to reflect actual practices in place. In response, certify that a credit check, criminal background, and sex offender screening will be obtain for all future adult applicants and retained in the tenant file.

h. Test all common area smoke detectors, C02 detectors, and emergency lights, if applicable. If hazards or violations exist, comment in the remarks column. Request a copy of violation and resolution to all safety issues.

i. All properties are required to have a physical inspection based on the program type. If there has been no inspection in the past three years, contact your field inspector. The appropriate inspection type should be selected based on the applicable program:

Check for pass/fail for the most recent physical inspection. Inspection date, type, and results can be reviewed in DMS under Monitoring > Project Monitoring > Program Inspection. Copies of the inspections, if needed, can be found in T:\Asset\Portfolio\Applicable Year\Inspection. If there has not been an inspection for the current year, review prior years and enter the most recent inspection date. If development failed their inspection verify current status with field inspector.

j. List improvements completed/planned for the current year.

b. Market ready is move-in ready. Inspect a sample of both market ready and non-market ready vacant units. Be sure to document any deficiencies observed in units management has indicated are market ready. Note in the comments column. Be sure to take pictures to support your observations.

Units should be move-in ready based on the timelines indicated in the management plan. In the absence of a management plan, follow the industry accepted standard, which is up to seven days. Longer make-ready time must be explained.

b. If the development is not free of major security problems, check which issues are problem areas.

b. List the liability from the rent roll or security deposit report, and the balance from the security deposit escrow account in the remarks column. If account balance does not equal or exceed liability, explain how deficit will be funded.

c. Properties in Chicago must pay interest if the deposit has been held for 6 or more months (See Chicago Residential Landlord Tenant Ordinance).

Per state law (765 ILCS 715), interest must be paid out when it accrues to $5 or at move-out, whichever is sooner. Not required to pay if property is a public housing (excluding Mod Rehab projects), if there are less than 25 units, or if the parcels are not contiguous.

Contiguous means: adjacent, physically touching or adjoining without intervening parcels or pieces of property. If they are across the street, are separated by property with a different owner or are in different geographic areas they are not contiguous. If they are not contiguous, a determination regarding interest should be made by looking at each separate parcel by itself or by looking at one contiguous set of parcels separately from other non-contiguous parcel(s). If one parcel has 25+ units, interest is required. If any single parcel has less than 25 units, but together with other contiguous parcel(s) totals 25 or more, interest is required. If one non-contiguous parcel has 25+ units but the other(s) do not, only the parcel with 25+ must comply.

Evidence of security deposit interest refunds includes a printout from the General Ledger, the tenant ledger reflecting interest credited, a letter in the tenant file acknowledging receipt of a cash interest payment, a move-out reconciliation statement, etc.

If audit is not received by deadline, FPA team will send a delinquency letter and, if necessary, a non-compliance letter. Look for any follow-up letters in the Portfolio, Audit folder. DMS will also be noted with notice dates.

a2. All budgets are due by October 1. If the Budget is not submitted on time, regardless of an extension request (enter extension expiration date in the remarks column), check no and make a comment regarding due dates. If the Budget has not been received, check no and make it a finding.

If budget is not received by deadline, FPA team will send a delinquency letter and, if necessary, a non-compliance letter. Look for any follow-up letters in the Portfolio, Budget folder. DMS will also be noted with notice dates.

b. For each of the last 3 years, enter the Debt Coverage Ratio (DCR). Obtain in DMS from Monitoring -> Project Monitoring -> AL_Audit. If the most recent year's audit has not been received/reviewed & the DCR determined, use the three most recent know years.

Example: When completing the 2022 review, enter the DCR for 2019-2021. If the DCR for 2021 has not been determined or the audit has not been received yet, enter the DCR for 2018-2020 and indicate in the comments that the 2021 audit is under review, or has not been received, as applicable.

c. Review most recent month end Balance Sheet. In general, the balance sheet should be no more than one month old. However, you may accept the month prior, if management's accounting department has not completed their month end processing.

If the balance sheet is not received, make a finding.

The balance sheet should be completed as follows:

Cash = cash - operations

Accounts receivable = Tenant Accounts Receivable + Accounts Receivable HUD (do not include allowance for doubtful accounts). Make a comment that Accounts Receivable includes Accounts Receivable-HUD and Tenant Accounts Receivable.

Accounts payable = Accounts Payable Operations

Utilize the Most Restrictive Rent Worksheets (when there are multiple IHDA programs), to determine allowable rents. Compare the rental charges and identify discrepancies between the rents charged, the approved rent schedule, and the Most Restrictive Worksheet. Make it a finding.

b. Use effective date of Owner's rent schedule. If current data is not in DMS, e-mail CA for update.

b. Percentage (%) = "Bad debt" / ("Total Rental Income" OR "Net Rental Income" + "Vacancy Loss"). Enter the year and amounts information on the far right side of this question to do the calculation of the %. The information can be taken from a DCR calculation or directly from the audit.

c. Must use Aged Payables listing. Please list amount only. If aged payable is greater than 60 days owner/agent must explain plans for reducing outstanding payables. If delinquency is for management fees due, this is not a finding.

d. If there are aged delinquencies, ask if any late fees have been charged. If Owner is delinquent with IHDA's debt service, then this would be checked No and is a finding.

b/c. If no, make a finding only if the development has not been paying into reserves or has submitted many withdrawal requests that ultimately reduced the $1,500 per unit (minimum requirement). Review Benedict/transaction history and filter to view development's activities for last 2 years. Review Portfolio/Escrow & Reserve Analysis for any forbearance letters. If this is a development with newly established reserves, make a comment: continue funding as required.

If the property is using the IHDA TSP, the initial plan must be signed by IHDA, the owner, and agent. Subsequent plans must be signed by the owner and agent.

If the property is using a TSP reviewed by HUD, the HUD approval memo/letter must be attached. The TSP must be signed by the owner and agent.

If the property is not using the IDHA TSP, the IHDA approval memo must be attached. The TSP must be signed by the owner and agent. You may see this with new deals that are Housing Authorities, RAD deals, 811 deals, etc.

Review the plan utilizing the tab TSP Checklist-Other.

For 9% credits, this is noted on the reservation letter, which should be saved in the Initial Tax Credit Documents portfolio folder. In this example, this property's allocation falls under the 2018-2019 QAP:

For 4% credits, use the the date of the 42(m) letter. The 42(m) letter should be saved in the Initial Tax Credit Documents portfolio folder. In this example, this property's allocations falls under the 2020-2021 QAP:

2. Allows a tenant to transfer to a new unit when a safe unit is immediately available and the tenant would not have to apply in order to occupy the new unit

3. Describes policies for assisting tenants to make emergency transfers when a safe unit is not immediately available, both for situations where a tenant would and would not have to apply in order to occupy the new unit.

4. Describes policies for assisting tenants who have tenant-based rental assistance to make emergency moves with that assistance.

5. May require documentation, as long as tenants can establish eligibility for an emergency transfer by submitting a written certification to their housing provider, and no other documentation is required for tenants who have established that they are victims of domestic violence, dating violence, sexual assault, or stalking to verify eligibility for a transfer.

d. Answer the question.

e. Only the fair housing logo is required.

f-g. Answer the questions.

h. Must be a finding if no outreach has been conducted within the 12 month period prior to closing the waiting list. Waiting list must be closed based on TSP requirements.

If the waiting list is managed by another agency, such as a housing authority, and 100% of applicants must come from that waiting list, mark N/A and make a comment in the remarks column indicating why outreach was not completed.

If less than 100% of units must be referred from another agency (such as SRN units), the agent must maintain a list & perform outreach for those units that do not required referral.

i. A development that provides affordable housing should keep track of race and ethnicity in their development. Tax Credit deals have to do the tracking to comply with HUD. Racial mix must equal 100%. Ethnic mix must equal 100%.

j. Detail the least likely to apply groups from the current approved AMP in the remarks section.

k. Add in remarks the successful outreach efforts such as local exhibits or other additional outreach efforts.

n. Indicate staff person/position in the remarks.

o. Prohibited discrimination means based on race, age, sex, handicap, familial status. If yes, please make a note here and describe in Attachment A.

p2. Review IHDA TSP Exhibit B. A transfer addendum is required for developments with accessible units. The addendum must be signed only by tenants who move in to accessible units but do not require the features. This requirement does not apply to developments with no accessible units or when all units are accessible.

q. Review Management Plan, or TSP. An Accessible Dwelling Unit is a unit that is approached, entered, and used by physically-challenged people.

Accessible features include: Wide doors, sufficient floor space for wheelchairs, lower countertops, lever and loop type handles hardware, seats at bathing fixtures, grab bars in bathroom, knee spaces under sinks and counters, etc. Most accessible features are permanently fixed in place.

An adaptable dwelling unit is one constructed and equipped so it can be converted with minimal structural change for the use by persons with different types and degrees of environmental limitation.

Adaptable features include: An Adaptable unit has features that are either adjustable or capable of being easily and immediately added or removed to "adapt" the unit to individual needs or preferences.

b. Formula - Total # of move outs divided by total units. If turnover rate is greater than 30% this will be a finding unless the rate is normal for this tenant population or program requirements (i.e. SLF & SRO properties). If this is typical for the tenant population, explain in the remarks column. If current occupancy is 90% or greater this will not be a finding.

c-d. Answer questions.

e. Developments may use a pricing list as a guide, however they cannot use this in calculating the actual charges. A development must, by State Statute, bill per the invoice and for labor only. A development that is overcharging is in violation of the Statute. Review move-out notice, inspection, and security deposit analysis with work order and invoice attached, if applicable. Also, review follow-up letter to former tenant (was it sent according to the timeframe stated in the lease agreement?).

g./h. Determination of neighborhood market conditions should be made through both a visual assessment of the area by the asset manager, and a conversation with site staff. If conditions are other than stable/improving, explain how.

i. Market conditions that negatively affect the property should be indicated, i.e. job loss, college town, economic depression, location, etc.

j. Answer question.

k. If there is a saturation of affordable housing, explain how, i.e. two new senior developments are being constructed in the immediate area with more amenities, etc.

19a. If there are police or arrest reports, what actions is management taking to resolve?

19b. Did the asset manager observe any paraphernalia during the property walk through? If so, include observations.