HUD recently announced, through Grants.gov, a formal Technical Correction to the notice of fund availability (NOFA) for the Tenant Resources Network Program (TRN). NLIHC, the National Alliance of HUD Tenants (NAHT), and other advocates expressed concerns about the original October 17 NOFA (see Memo, 11/4). HUD states that the Technical Correction addresses many of the advocates’ concerns. The application due date is now extended to January 4, 2012.
The purpose of TRN is to help preserve project-based Section 8 homes at risk of leaving the affordable housing stock. Nonprofits with a minimum of five years’ tenant outreach and organizing experience awarded TRN grants will be compensated for undertaking tenant outreach at eligible projects. TRN is designed to inform and engage tenants about their rights and options if their HUD-assisted private apartments are at risk of leaving the affordable housing stock.
Key changes to the NOFA made by the Technical Correction (TC) affect:
- The definition of “newly eligible properties.” Advocates were concerned that many properties they thought to be eligible were not on HUD’s list of eligible properties. HUD maintains that its list is accurate; therefore it will not consider adding properties to the list at this time. However, the TC intends to increase the flexibility of TRN awardees to add newly-eligible properties during the term of their grant by allowing awardees to request that HUD approve work at additional properties after the award is made. The TC clarifies that a property may be considered for addition to the list if it has a Section 8 contract expiring within 24 months, and the owner either submits a 120-day election to opt out of the contract or files a 12-month opt out notice. The TC also removes the 20% cap on the percentage of properties that may be newly eligible.
- The definition of “triggering event.” The TC clarifies that, in addition to a triggering event, all properties must have a Section 8 HAP contract with an overall expiration date of no sooner than the date of NOFA publication and no later than 24 months after the NOFA publication.
- Appendix description of eligible properties. The TC description in the Appendix gives a more precise definition of the event triggering a property’s eligibility for the list. It describes in detail four possible triggering events: a mortgage maturing within 24 months after the NOFA was published; an owner electing to opt out 12 months before the NOFA was published; the owner provides notice of prepayment 12 months before the NOFA was published; and, the property receives two consecutive REAC scores below 60, with the most recent 12 months before the NOFA was published.
- Rating factor “Achieving Results and Program Evaluation.” Grantees will now be required to inform the owner that TRN activity is taking place, and that HUD may be able to provide the owner with technical assistance related to preservation. Grantees will no longer be required to show improved awareness on behalf of owners, and the TC no longer requires grantees to track owner contract renewals.
- The number of applications and anticipated award amounts. The initial NOFA required that a distinct application be made for each state, and each application had to entail work with at least 400 units. However, some states do not have 400 eligible units. Therefore the TC will now allow two options for work in states with fewer than 400 units:
a. Small grants. An organization may submit a single-state application to work in 200 to 399 units. The maximum grant will be $100,000.
b. New multi-state application. An organization may seek to work in more than one state. The “home” state may have fewer or more than 400 eligible units, but each additional state must have fewer than 400 units. The multi-state application must cover at least 400 units among the combined states.
The Technical Correction is at: http://nlihc.org/doc/2011_NOFA_TRN_TC.pdf