City of Tulsa

Program Specific Requirements

DRAFT | Third Year Annual Action Plan |2022-2023 | DRAFT

Introduction:

The third year of the Five Year Consolidated Plan will see 31 external agencies and 2 City departments conducting 40 activities totaling $6,662,340 in grant funding, not including administration.

Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)

Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed	$1,727,900
2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan.	0
3. The amount of surplus funds from urban renewal settlements	0
4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan	0
5. The amount of income from float-funded activities	0
Total Program Income:	$1,727,900

Other CDBG Requirements

1. The amount of urgent need activities	0
2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan.	75.00%

HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)

A description of other forms of investment being used beyond those identified in Section 92.205 is as follows

The City of Tulsa does not use any form of assistance that is not described in Section 92.205(b).

The City of Tulsa homeownership program activity uses the recapture provisions of 24 CFR 92.254(a)(4)(ii). It is believed this process is the closest to normal market approaches to financing, the easiest for borrowers to understand, enables the deed restriction requirements of the alternative option to be avoided (which we believe constitutes a barrier to private financing participation), and better enables HOME funds to be marketed in coordination with other private lending. An ongoing homeownership assistance activity has been the City's goal and is in keeping with the basic HOME program descriptions.

A purchaser of a property may apply for and be provided HOME assistance subject to the property and said buyer meeting HOME program eligibility criteria, a written agreement to comply with program terms and conditions, and the availability of funds. Mortgages include the "principal residence" requirement of the program during the affordability period, failure of which will constitute a default of the second mortgage.

The recapture option is a mechanism to recapture all or a portion of the direct HOME subsidy if the HOME recipient decides to sell the house within the affordability period at whatever price the market will bear. Forgiveness will be tied to the length of time the homebuyer has occupied the home in relation to the period of affordability and the net proceeds of the sale. The affordability period is based on the amount of HOME funds provided for the property and is forgiven as designated in the DGA HOME policies and procedures. Calculations for the recapture include the HOME Investment, the Homebuyer Investment, and the Net Proceeds. These are defined as:

HOME Investment is all HOME funds contributed to the unit and any direct subsidies consisting of any financial assistance that reduces the purchase price from fair market value to an affordable price, or otherwise subsidizes the purchase;
Homebuyer Investment consists of the portion of initial down payment paid by the homebuyer combined with the value of any capital improvements made with the homebuyer funds; and
Net Proceeds are the sales price minus closing costs and any non-HOME loan repayments. To allow low-income homebuyers to retain some equity in their property should they need to sell, the City of Tulsa recaptures HOME funds using the following steps:

a) Reduction during affordability period. The HOME investment amount to be recaptured will be reduced on a prorated basis for the time the homeowner has owned and occupied the housing measured against the required affordability period;

b) Owner investment returned first. From the net proceeds of the sale, the homebuyer may recover their entire investment before the HOME investment is recaptured; and

c) Shared Net Proceeds. If the net proceeds are not sufficient to recapture the full HOME investment (or a reduced amount according to the time the homeowner occupied the home), plus enable the homeowner to recover the amount of their down payment and any capital improvement investment made since purchase, the net proceeds will be divided proportionally. The formula used will be HOME Investment multiplied by Net Proceeds divided by HOME Investment plus Homeowner Investment equals HOME Recapture.

3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows:

The administration of homebuyer programs includes thoroughly informing each potential homebuyer of all the requirements under the HOME Program. This will ensure they understand what is required through the affordability period and the recapture provisions if they sell the property prior to the expiration of the affordability period. This information is included in the Homebuyer Written Agreement and explained verbally by a housing counselor. In addition, a Second Mortgage is executed at closing and is not released until after the affordability period has expired. Provisions in these documents include the following criteria, which are verified annually until the end of the affordability period:

Principle Residence
Current on Mortgage, Taxes, and Insurance
Upkeep of Property (no code violations from the City of Tulsa)

All organizations that administer the program for the City are required to keep an inventory of all properties that remain under the affordability period. This information is submitted to Grants Administration at the end of each program year.

4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows:

The City of Tulsa does not use HOME funds to refinance existing debt.

Emergency Solutions Grant (ESG)
Reference 91.220(l)(4)

1. Include written standards for providing ESG assistance (may include as attachment)

In accordance with 24 CFR 576.400(d) the City of Tulsa has adopted written standards for the provision of ESG assistance in collaboration with the Tulsa Continuum of Care (CoC). These written standards are included in Appendix E.

2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system.

Tulsa’s Continuum of Care’s coordinated entry system is All Doors Open. This system is designed to provide each individual or family with adequate services and support to meet their housing needs, with a focus on returning them to housing as quickly as possible. The components of All Doors Open are listed below.

a. Access and Screening
b. Assessment
c. Prioritization and By-Name List(s)
d. Case Conferencing
e. Referral
f. Placement

The system operates with a decentralized “no-wrong-door” system of access, so that persons in need can enter the system at multiple participating agencies in different geographic locations. All Doors Open strives to be inclusive and continuously seeks partnerships with public service institutions (health departments, county clinics, human services), faith-based organizations, other institutions (hospitals and jails), and mainstream resources to serve as access points.

At various provider access points, individuals and families experiencing a housing crisis complete a screening tool that considers the individual or family’s need for specialized services and the ability to prevent or divert the individual or family from experiencing homelessness. Should homelessness not be avoidable, a standardized common assessment tool is used to determine the individual or family’s vulnerability. The common assessment tool is integrated into the Homeless Management Information System (HMIS) and may be conducted at partner agencies, including shelters, drop-in centers, transitional housing programs, outreach programs, telephonically, or wherever people who are experiencing homelessness first enter Tulsa’s coordinated entry system.

Housing programs, including permanent supportive housing, rapid re-housing, transitional housing and safe-haven housing fill available spaces in their programs from a By-Name-List of eligible individuals and families generated from HMIS. To ensure the most vulnerable are housed first, the By-Name-List is prioritized based on common assessment scores and length of time homeless. This coordination improves the targeting of housing resources and reduces the need for people to separately seek assistance at various partner providers.

The HMIS system is fully compliant with HUD's requirement for victim services and does not include domestic abuse service providers.

3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).

The HUD grant selections are made through a joint process adopted by the Tulsa City Council and Mayor in which applications are accepted from non-profit agencies serving within the corporate limits of the City of Tulsa. Through public meetings and surveys the HUD Community Development Committee determine the needs of the community, sets the funding priorities, and reviews the community development plan. The Continuum of Care and/or member agencies present homeless needs at the Needs Assessment Public Hearing. Applications are created based on the priority needs determined by the committee and grant guidelines. Upon review of the applications, the HUD Community Development Committee submits funding recommendations to the Mayor and City Council for approval. A member of the Continuum of Care is appointed by the Mayor to serve on the HUD Community Development Committee for the award of ESG funds as well as the other HUD funds.

4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG.

As part of the written agreement, subrecipients are required to provide for the participation of a homeless individual or formerly homeless individual in a policy-making function within the organization. This may include involvement of a homeless or formerly homeless person on the Board of Directors or similar entity that considers and sets policy or makes decisions for the organization.

5. Describe performance standards for evaluating ESG.

The City of Tulsa contractually holds subrecipients responsible for meeting the accomplishments established for each grant activity in a written agreement. Each agency is also required to report program outcomes and participant demographics into HMIS and submit quarterly reports to the City. The City works closely with subrecipients and the CoC to develop program and service outcome benchmarks. The AWH4T Outcome Standards are used as a guideline for ensuring the success and effectiveness of all homeless programs, including ESG. These standards are included in Appendix E. The 4 goals included in the standards include:

1. Stop Homelessness Before It Begins
2. Transform the Homeless System of Care to Be More Effective, Equitable, and Person-Centered
3. Increase Access to Housing
4. Partner Across Tulsa to Build Solutions and Access Resources

APPENDICES