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Under
24 CFR 990.260(b), PHAs with fewer than 250 public housing units are exempt from
asset management. Section 225 of the Consolidated Appropriations Act, 2008, increases,
for Calendar Year 2008, the threshold to 400 units, except for PHAs eligible for
stop-loss, who must implement asset management.
There are at least two
financial implications for PHAs with 250 – 400 units that elect not to implement
asset management: (1) a PHA will lose the $4 per unit month (PUM) asset management
fee and (2) a PHA may experience a change in its Project Expense Level (PEL) if
it currently has more than one Asset Management Project (AMP). By electing not
to implement asset management, all units will be combined into one AMP. The PEL
for these new, consolidated AMPs will be reduced, on average, by about $4.25 PUM
(due to impact of formula coefficients when multiple projects are combined).
The
attached table lists each PHA with between 250-400 units.
(MS-Excel, 112 KB) Shown are both the current weighted-average
PELs (WAPELs) and the new WAPELs if the PHA elects not to implement asset management.
Also shown is the estimated annual fiscal impact from (1) the change in WAPEL,
(2) the loss in asset management fee, and (3) the combination of the two. |