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Post Approval Documentation Requirements

Summary

Upon approval of a CFFP proposal, HUD will issue an approval letter, with an attached estimated debt service schedule which is the last debt service schedule submitted by the PHA prior to approval. Additionally, the CFFP ACC amendments will be included for counter execution by the PHA.

As stipulated in the HUD approval letter, all post approval documentation should be submitted within 60 days of the date of the letter. One hardcopy (with original signatures) in three ring binders and two electronic copies on CD of closing binders and other post approval documentation should be sent to HUD and should include the following:

  1. Copies of all loan/bond documents executed at closing
  2. Certifications from the Authority and its counsel attesting that the changes requested by HUD have been made and that no other substantive changes to the submissions have been made since they were last provided to HUD.
  3. Fully executed, dated, original Capital Fund Financing Amendment to the Consolidated Annual Contributions Contract (with original signatures from HUD and the Authority).
  4. Cover letter from the Authority transmitting the final debt service schedule and attesting that the payments do not exceed the estimated debt service schedule approved by HUD in any year by more than 10%.
  5. Final Debt Service Schedule in HUD format.
  6. Complete and fully executed Direct Deposit Sign-Up Form (with original signatures from the Authority and the Lender) (1199 and Tab delimted File Instructions)
  7. Tab Delimited file in the format required for uploading into LOCCS (see instructions in Item 6)
  8. Executed copy (s) of all HUD General Depository Agreement (s) (form HUD-51999 (2/2018)) entered into between the Authority and the Depository (including the Lender or other Depository authorized by the Loan/Bond Documents.

Changes to the Use of Proceeds Budget Post Approval

  1. Changes in the scope of work for which the proceeds are being used that are below the Additional HUD Approval Threshold are addressed via the normal PHA Plan process (according to the same requirements as CFP grants), whereby PHAs revise existing Plans or submit new Plans to the Field Office.
     
  2. Additional HUD Approval Threshold - if the changes made by the PHA fall into any of the categories listed below, the PHA must obtain additional written approval from the Field Office, which must be separate from the Field Office's review and approval of the PHA Plan. The field office should send a copy of the approval letter and PHA request of changes above the threshold to the Office of Capital Improvements.
  • A change in the type of activity being financed (e.g. if the approved CFFP Proposal contemplated the proceeds being used for modernization, but after approval the PHA decides to pursue development instead),
  • A change in the Project being modernized/developed with the proceeds,
  • A reduction of 20% or more in the number of public housing units being modernized/developed (PHAs must at all times comply with TDC requirements),
  • An increase of 20% or more of the cost of non-dwelling space.

Please submit all post approval documentation to:

Martina Arias
U.S. Department of Housing and Urban Development
Office of Capital Improvements
451 7th Street, SW, Room 4130
Washington, DC 20410

If you have any questions regarding CFFP Post Approval Documentation Requirements, please contact Tom Shelton at (202) 402-4799 or by email Thomas.Shelton@hud.gov

 

Updated 3/10/2020