HOME FACTS - Vol. 1 No. 3, September 2008

Topic
This issue of HOME FACTS explains how to use the Integrated Disbursement and Information System (IDIS) PR 27 Status of HOME Grants report to compute a participating jurisdiction's (PJ's) commitment requirement and total commitments; CHDO reservation requirement and total CHDO reservations; and expenditure requirement and total expenditures for the HOME Program.

The HOME Deadline Compliance Status Report is the official tool used to track PJ compliance with HOME's commitment, CHDO reservation, and expenditure requirements. The report can be found on the HOME reports website
(www.hud.gov/offices/cpd/affordablehousing/reports/). Since the HOME Deadline Compliance Status Report is based on a monthly download of IDIS data, the PR27 report must be run on the first day of the month in order for the figures on the two reports to match. However, the PR27 report can be used to track, on a day by day basis, a PJ's status in relation to its commitment, CHDO reservation, and expenditure requirements.

Commitment Requirement

A HOME PJ is required to commit its HOME funds within 24 months after the last day of the month in which HUD notifies the PJ of HUD's execution of the HOME grant agreement. The entire grant amount must be committed. HUD measures compliance with this requirement cumulatively. In other words, funds that are committed as of the PJ's deadline are counted towards the PJ's commitment requirement regardless of the year of the grants used to make the commitments. For more information on HOME commitments, see 24 CFR 92.2 and HUD Notice CPD 07-06, Commitment, CHDO Reservation, and Expenditure Deadline Requirements for the HOME Program.

The commitment requirement can be calculated using the PR27 by adding the "Total Authorization" amounts (page 1, column B) through the requirement year. For example, the commitment requirement for a PJ's 2008 deadline would be the sum of its total authorizations through 2006. The Total Authorization amount includes HOME and ADDI funds and takes into account any deobligations that have occurred.

To calculate the amount of total commitments using the PR27, add the sum of "Total Authorized Commitments" (page 1, column I) to the sum of "Admin/Op Reservation" (page 1, column C). The "Total Authorized Commitments" (page 1, column I) is the sum of a PJ's CHDO reservations, "Amount Reserved to CHDOs + CC" (page 2, column E); SU funds, "Reservations to Other Entities" (page 2, column G); and EN funded activities, "PJ Commitments to Activities" (page 2, column H). The formula for this calculation is as follows:

NOTE: The amount of total commitments does not include activities explicitly funded with program income (PI) nor does it include PI disbursed. Drawing down PI for EN funded activities results in a reduction to the EN funding amount, which will lower a PJ's total commitments by the amount of PI drawn in place of EN.

If the amount of total commitments is greater than the commitment requirement, the PJ currently meets its commitment requirement.

CHDO Reservation Requirement

A HOME PJ is required to reserve not less than 15 percent of its HOME allocation for investment only in housing to be developed, sponsored, or owned by CHDOs within 24 months after the last day of the month in which HUD notifies the PJ of HUD's execution of the HOME grant agreement. The CHDO reservation requirement is 15 percent of the PJ's HOME grant amount minus the PJ's ADDI grant, if any. Like the commitment requirement, HUD also measures compliance with the CHDO reservation requirement cumulatively. In other words, funds that are reserved to CHDOs as of the PJ's deadline are counted towards the PJ's CHDO reservation requirement regardless of the year of the grants used to make the CHDO reservations. 24 CFR 92.300 and HUD Notice CPD 07-06, Commitment, CHDO Reservation, and Expenditure Deadline Requirements for the HOME Program contain more information regarding the CHDO reservation requirement.

The CHDO reservation requirement can be calculated using the PR27 by adding the "Total Authorization" amounts (page 1, column B) through the requirement year. ADDI funds received through the requirement year must be subtracted from this total. The ADDI allocations received each year are on the ADDI Accomplishment Report found on the HOME Reports webpage (www.hud.gov/offices/cpd/affordablehousing/reports/).

Previous deobligations for failure to meet commitment or expenditure requirements must be added back into the "Total Authorization" amount since these deobligations do not affect the PJ's CHDO reservation requirement. However, previous deobligations for failure to meet a CHDO reservation requirement are subtracted from a PJ's CHDO reservation requirement. The formula for this calculation is as follows:

Total Authorizations through requirement year (page 1 column B)
-    ADDI allocations through requirement year (from ADDI Accomplishment Report)
+    Commitment or expenditure deobligations (HUD or PJ records)
x    15 percent
-    CHDO deobligations (HUD or PJ records)

The amount of total CHDO reservations is the sum of "Amount reserved to CHDOs + CC" found on page 2, column E of the IDIS PR 27 report.

If the amount of total CHDO reservations is greater than the CHDO reservation requirement, the PJ currently meets its CHDO reservation requirement

Expenditure Requirement

A HOME PJ is required to expend its HOME funds within five years after the last day of the month in which HUD notifies the PJ of HUD's execution of the HOME grant agreement. The expenditure requirement is based on the PJ's entire grant amount and like the commitment and CHDO reservation requirement compliance with the expenditure requirement is also measured cumulatively. All expenditures made by the time of the PJ's deadline are counted towards the PJ's expenditure requirement regardless of the year of the grant from which the expenditures were made. More information on the expenditure requirement can be found at See 24 CFR 92.500(d)(1)(C) and HUD Notice CPD 07-06, Commitment, CHDO Reservation, and Expenditure Deadline Requirements for the HOME Program.

The expenditure requirement can be calculated using the PR27 by adding the 'Total Authorization" amounts (column B on page 1) through the requirement year. For example, the expenditure requirement for a PJ’s 2008 deadline would be the sum of its total authorizations through 2003. The Total Authorization amount takes into account any previous deobligations.

The amount of total expenditures is the sum of 'Total Disbursed" found on page 4, column G of the IDIS PR 27 report. This amount does not include program income disbursed.

If the amount of total expenditures is greater than the expenditure requirement, the PJ currently meets its expenditure requirement.

Do you have questions?
Questions or correspondence regarding HOME deadline compliance should be directed to Evelyn Rumph, Financial and Information Services Division, Office of Affordable Housing Programs at 202-402-4071 or Evelyn.Rumph@hud.gov.