Affordable Housing Procedures, Reporting, & Project Implementation

Orange County

Since 2015, RSG has provided on-call housing consulting services to Orange County Community Resources for a wide variety of housing programs and projects. Our services have included:

Policies and Procedures Manuals

RSG prepared policy and procedure manuals for the County’s CDBG, HOME CoC, and ESG programs as well as for their Affordable Housing Compliance Monitoring at properties assisted by the County. The manuals were written broadly enough to ensure compliance with federal requirements while giving staff flexibility to change internal procedures without a need to constantly revise their policies and procedures. RSG continues to work with the City to routinely update the manuals in order to ensure compliance.

SB 341 Reporting

RSG prepares the annual Housing Successor Agency expenditure report for the County (as well as several other RSG clients). As part of this work, RSG is proactive to engage our clients in the identification of issues and opportunities for investment to maximize the use of these resources. In this capacity, we have helped the County identify additional funding that was included in their most recent Permanent Supportive Housing NOFA. We also identify and track the use of the County’s HOME funds to ensure they are leveraging funds and meeting legal requirements.

HOME Compliance

RSG routinely identifies and tracks the use of the County’s HOME funds to ensure they are leveraging funds and meeting legal requirements. Activities include conducting a Subsidy Layering Review that includes:

  • Reviewing the developer’s development pro forma to determine the reasonableness of estimated development costs, revenue assumptions and proposed financing structure, including, but not limited to, the potential for receiving HOME funds.
  • Preparing a memorandum detailing our findings and recommendations regarding the economic feasibility of the proposed development, as well as whether the total requested amount of program funding and other governmental assistance exceeds the amount necessary to make the project feasible due to the unreasonableness of the costs and/or projected rate of return.

Neighborhoods Standard Review

RSG also conducts a Neighborhoods Standard Review that includes:

  • Researching and determining if the Project site is of adequate size, exposure, and contour to the proposed development, has adequate utilities, and not in an area of minority concentration.

Agreement Preparation

The County also requested that RSG serve as a project coordinator on multiple projects wherein we were responsible for the preparation and oversight of controlling documents. We were responsible for working with legal counsel and coordinating with the entire development team to prepare project closing documents.

Legislative Monitoring

RSG provides the County with frequent legislative updates regarding matters that may affect them. It is common that we are asked to research or provide input on how legislative matters may impact the work the County does. We most recently advised them on Opportunity Zones.

Emergency Rental Assistance Program Evaluation

RSG drafted a memo detailing the evaluation of funding sources for emergency rental assistance payment programs derived by the federal Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) and from the federal Consolidated Appropriations Act of 2021 (“CAA”). Both funding sources aim to provide financial assistance to tenants who, as a result of the financial hardships caused by the coronavirus (“COVID-19”), are struggling to meet their monthly rental obligations. The memo detailed a comparative analysis of the requirements and intent of both emergency rental assistance payment programs. Specifically, RSG evaluated the allocated funding amounts, targeted population, eligibility requirements, application process and weighted in on the advantages and disadvantages for each funding program.

Compliance Monitoring

RSG partnered with the County of Orange to structure, streamline, and implement procedures for their affordable housing compliance monitoring portfolio. Services included:

  • Reviewing and summarizing each project’s controlling agreement.  
  • Detailing affordability restrictions, funding source amounts, and documentation requirements.
  • Creating a manageable database that details project information and tracks compliance data, including inspection dates, annual and quarterly compliance reporting, project contact information, and affordability requirements.
  • Training staff on policies and procedures as it relates to compliance monitoring.

In addition to setting up the compliance structure, RSG assisted with compliance monitoring coordination activities. Services included:

  • Scheduling on-site monitoring visits.
  • Conducting file audit reviews.
  • Analyzing income-restricted reporting data.
  • Reviewing certificates of compliance to confirm correct set-asides for all income level limits.
  • Collecting management plans.

Residual Receipt Analysis

RSG provided financial audit services to ensure compliance pursuant to related affordable housing agreements and loan documentation. The audits focused primarily on the review of financial statements and the creation of a cash flow analysis to determine residual receipt revenue for each project. Any variances between the property owner’s calculation and RSG’s was discussed between all relevant parties.

Relocation Oversight

RSG provided oversight on the draft Relocation Plan prepared by Overland, Pacific, and Cutler, LLC. for Jamboree Housing Corporation’s plans to rehabilitate the 60-room Tahiti Motel in Stanton, California. RSG reviewed and analyzed Notices to Vacate (“NTV”), Notices of Eviction (“NOE”), and a Notice of Ineligibility (“NOI”) to ensure they met the requirements of California Relocation Law (Government Code Section 7260 et. seq.), Relocation Guidelines (Title 25, California Code of Regulations Section 6000, et. seq), and the Federal Uniform Relocation Assistance and Real Property Acquisition Policies Act (“URA”). RSG also verified Rental Assistance Payment (“RAP”) calculations and identified areas in the plan that required follow up.

Finally, RSG was tasked with training staff to take on all monitoring activities and ensure they were properly qualified in the field of compliance review and residual receipts, all while formulating knowledge of policy and procedures with a monitoring manual, previously authored by RSG.