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Tuesday, August 4, 2015

Staying on Top of HOME Deadlines

HUD's HOME Investment Partnerships Program enforces strict deadlines for committing funds, expending funds, starting project construction, and closing out a project. A Participating Jurisdiction (PJ) that receives an annual entitlement HOME grant (also called a Formula Allocation) may lose its funds if it does not meet these deadlines. It can be a challenge to keep track of these deadlines because the clock re-starts every year that the PJ receives a new Formula Allocation. A PJ usually has multiple deadlines for different years of Formula Allocation that have not been entirely committed or spent.

The HOME deadlines became more stringent a few years ago when the legislature sought to improve the timely use of funds, resulting in the 2013 HOME Rule. Below is a summary of HOME Deadlines.
  • Expenditure— PJ’s must spend HOME funds within five years of receiving their Formula Allocation.
  • Commitment— PJ’s must commit HOME funds to a specific project with a binding legal agreement within 24 months of receiving their Formula Allocation.
  • Project Commencement— HOME-funded projects must begin construction within 12 months of receiving a HOME commitment, as documented with building permits.
  • Project Completion— HOME-funded projects must be completed within four years of commitment, as documented with certificates of occupancy. Any project that is not completed in this timeframe will be terminated and PJs will be required to repay HOME funds drawn.
  • Lease-up— HOME-assisted rental units must be occupied by income-eligible households within 18 months of project completion. If this requirement is not met, PJs must repay HOME funds for the vacant units. For units that remain vacant six months following completion, the PJ must develop an enhanced marketing plan and report this information to HUD.
  • Home purchase— A HOME-assisted homebuyer unit must have a ratified sales contract within nine months of construction completion.
HUD does provide a 120-day notice when a deadline is approaching that has not yet been met. Deadlines are also tracked on HUD's HOME Deadline Compliance Status Reports online. However, it may often be too late for a PJ to line up or complete a project by the time the 120-day notice has arrived. Real estate projects often require long timelines and a more proactive approach.

To initiate a planning process to meet deadlines, it is a good idea to set up a timeline for each year's HOME allocation and each HOME-funded project. Housing Tools uses Smartsheet cloud-based project management software to make these timelines available to all team members on the Internet, allowing them to access and update timelines at any time. This software also offers tools to make assignments, notify team members when tasks are completed, and send automated reminders via email. This helps PJs stay on top of HOME deadlines. Let me know if you would like to find out more about these systems.