What WtW PHAs are subject to de-reservation?
Those PHAs that were NOT renewed as of December 31, 2001 and that
have leasing rates of less than 95 percent of their allocation are
subject to de-reservation. To determine the leasing rate, HUD is
using the data contained in the December
Leasing Report and has included in the leasing total the number
of Requests for Tenancy Approvals (RTAs) in process.
How will HUD calculate the number of units to
To determine the number of units to be de-reserved, HUD will subtract
the greater of the following two numbers, i.e. the number that is
more favorable to the PHA, from the PHA's WtW award figure:
Number of units that were under lease as of December 1, 2001,
including the number of RTAs that were in process at that time,
as reflected in the December
Leasing Report ; or
Number of units that were currently under lease as of February
28, 2002, as reflected in the March
HUD has identified the WtW voucher units to be de-reserved. PHAs
subject to de-reservation will receive a letter from HUD's Financial
Management Center (FMC) that confirms the exact number of units
de-reserved and the amount of the ACC renewal. Once de-reservation
occurs, future WtW Leasing Reports will be updated to reflect the
new baseline unit allocation for those PHAs that had units de-reserved.
PHAs that are subject to de-reservation eligible to apply for additional
that are subject to de-reservation are NOT eligible to apply for
will HUD determine eligibility to apply for additional, reallocated
determine eligibility to apply for additional vouchers (97 percent
or higher leasing rate), HUD will use the leasing data (percentage
of units currently under lease) shown on the March
Leasing Report posted on the WtW Web site. HUD will NOT use
earlier leasing data, i.e. December, January, or February Leasing
Reports. In other words, eligibility will be based on a "point
in time" measurement reflecting the most current leasing rate.
For example, if a PHA achieved 97 percent or greater lease up in
a previous month but reported to be less than 97 percent leased
as of February 28, 2002, it is not eligible to apply.
did HUD consider RTAs in process when determining leasing rates
for the de-reservation process but did not consider RTAs in process
for determining eligibility for applying for additional WtW vouchers?
being sensitive to the fact that RTAs in process represented real
commitments on behalf of the PHA to house a family, counted RTAs
in process for determining the number of units to be de-reserved.
It used the actual number leased, based on the most up-to-date leasing
data, for determining eligibility to apply for additional vouchers.
the application to apply for reallocated WtW vouchers include the
full narrative explanation generally required under other NOFAs?
PHAs are only required to complete form HUD-52515 and a leasing
HUD give any special consideration to WtW PHAs with small WtW programs,
where the loss of just a few units could take them below the eligibility
threshold of 97 percent for applying for additional vouchers?
an effort to be as fair, objective, and consistent as possible,
HUD made the decision to measure lease-up at a point in time and
to use the most up-to-date leasing data available. HUD does not
plan to change its procedure for determining eligibility to apply
for additional vouchers and will not be giving special consideration
to PHAs with small WtW voucher programs where the loss of a few
units affects the PHA's eligibility to apply for additional vouchers.
PHAs that find themselves in this situation meet the 97 percent
leasing requirement under HUD's Fair Share NOFA and can apply for
additional vouchers through the Fair Share NOFA process. If such
a PHA receives Fair Share funding, it can dedicate a portion of
the slots to its WtW voucher program, if it wishes to do so.
there any special application procedures for sites that originally
submitted joint applications? Do these sites need to apply together
for the reallocated WtW units, or do they apply separately?
or more PHAs that originally submitted joint applications for WtW
vouchers should apply separately for additional WtW vouchers. There
are no special application procedures. Likewise, when determining
eligibility to apply, HUD will be looking at individual PHA leasing
a PHA that has expended more than 97 percent of its funds but less
than 97 percent of its vouchers eligible to apply for reallocated
baseline WtW vouchers?
Eligibility to apply for additional vouchers is based on the percentage
of units leased, not funds expended. A PHA that finds itself in
this situation must look at its WtW voucher costs within the context
of all funds available. If it finds it is short due to extraordinary
circumstances, it should request a cost amendment.
a PHA discovers errors in the data contained in the March Leasing
Report and believes it is eligible to apply for reallocated vouchers,
can it correct the error and apply for more vouchers?
If a PHA believes that the March
Leasing Report incorrectly shows its leasing to be below 97
percent, HUD will consider the PHA's application if the PHA submits
with its application the following documentation that verifies that
the PHA has met the leasing requirement: a complete listing of families
under lease in the PHA's WtW voucher program as of February 28,
2002, including the name and Social Security number of the head
of the household, the address of the assisted unit, and the effective
date of the Housing Assistance Payments contract.
a PHA apply for vouchers to cover the over-leasing it has already
assumed, or must re-allocated vouchers go to new program participants?
WtW PHA may apply for additional vouchers to support/absorb over-leasing
that has already occurred in its WtW program. In fact, a PHA that
is over-leased in its WtW voucher program must first use any reallocated
WtW vouchers that it receives to correct over-leasing. Once the
PHA's WtW leasing rate has been normalized, any remaining reallocated
WtW vouchers that the PHA receives may be used to bring new families
onto the program.