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HOME monitoring staff must ensure that the PJ, CHDOs, and sub recipients are complying with both minimum and maximum per-unit HOME requirements.
Minimum Expenditures
The minimum amount of HOME funds that must be invested in any project is $1,000 times the number of HOME-assisted units in the project. The minimum only relates to HOME funds, not to any other funds that might be used for project costs, including match.
Maximum Expenditures
The maximum per-unit HOME subsidy varies by metropolitan area and is based on Section 221(d)(3) limits (with some exceptions). Eachyear HUD calculates these maximum amounts by area. Project files should be spot-checked to ensure that HOME limits have been accurately calculated and applied.
- The maximum limit only relates to HOME funds and is applied only to HOME- assisted units within a project.
- The maximum HOME limits also relate to the total HOME dollars invested, not amounts invested at any one time in a project.
Layering Analysis Before committing HOME funds, a PJ must also evaluate a project in accordance with written guidelines stipulating that it not invest any more HOME funds, in combination with other governmental funds, than necessary to provide affordable housing. This provision is generally referred to as "layering." PJs must adopt written layering guidelines and evaluate each project in accordance with them. Monitoring staff should review the effectiveness of the PJ's written guidelines and review project files to ensure that proper layering analysis was completed for relevant projects.
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