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Summary
Some PHAs may not have enough funds in a single year to be able
to make all of the improvements necessary to adequately maintain
their public housing. As a result, PHAs may take advantage of the
financing element of the Capital Fund. Under the Capital Fund Financing
Program (CFFP), a PHA may borrow private capital to make improvements
and pledge, subject to the availability of appropriations, a portion
of its future year annual Capital Funds to make debt service payments
for either a bond or conventional bank loan transaction.
PHAs may anticipate a review time generally between 60 and 90 days.
The overall review timeline will depend upon the completeness of
the Proposal and the responsiveness of the PHA team. Generally,
PHAs should receive HUD comments on their initial submittal within
30 to 45 days. To the extent that a Proposal is approvable, approval
should occur within 30 to 45 days after HUD’s comments are provided,
depending upon the completeness of the initial submittal, and the
responsiveness of the PHA team. To the extent that the approval
of the CFFP is needed to meet deadlines associated with the use
of the CFFP proceeds (such as a mixed finance transaction that uses
LIHTCs that have carryover or PIS requirements), PHAs should be
conservative in projecting HUD review timelines. PHAs are advised
to allow for unforeseen issues that might present themselves during
the review process and challenge the PHA team’s ability to resolve
in a timely manner.
The loans or bonds are obligations of the PHA. HUD does not guarantee
or ensure these loans or bonds. The PHA obligation is subject to
the availability of appropriations by Congress and compliance with
statutory and regulatory requirements.
A PHA must obtain written HUD approval prior to executing any document
that would encumber or pledge as collateral any Public Housing assets.
This includes both physical assets and future Public Housing funding,
such as Operating Funds or Capital Funds. In order to receive HUD
approval, a PHA must submit a financing proposal that includes a
term sheet, financial documents, and a justification for the use
of Capital Funds for financing.
General guidelines for the CFFP program include:
- Approval - PHAs must request approval from the Deputy
Assistant Secretary, Office of Public Housing Investments.
- CF Pledges - Generally no more than 33% of the PHA's
current annual CF grant adjusted for any proposed or planned demolition
or disposition or other activity that would result in a reduction
of the PHA units count or otherwise reduce CFP Funds appropriated
or available to the PHA. All pledges are subject to the availability
of appropriations.
- Term - Generally, no more that 20 years.
- Public Housing Requirements - Since the proceeds from
a CFFP transaction are generated via the pledge and use of Capital
Funds, HUD considers CFFP Proceeds to be, for all intents and
purposes, Capital Funds. PHAs pursuing any type of CFFP transaction
must follow all statutory and regulatory requirements related
to the Capital Fund Program in regard to the development and implementation
of their CFFP Proposal.
Proposals Approved to Date - List
of PHAs approved to Date (alphabetical list by state) (MS-Excel)
Proposals Approved to Date -
List of Transactions Approved To Date (chronological list) (MS-Excel)
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