BRP Program Compliance and Reporting November 18, 2015.

BRP Program Compliance and Reporting

November 18, 2015

Agenda

• Part 1 - Compliance– Program Guide: Compliance and Reporting section– Quarterly Status Report walkthrough– Compliance Reminders– Compliance Questions

• Part 2 – Program Information– Programmatic Reporting– Program Guide Updates– Questions

Compliance and Reporting Components

• Compliance Monitoring– Site Visits– File Audit– Financial Audit– Corrective Actions

• Quarterly Status Report

• Document Retention

• Suspected Fraud and Resources

Authority

• Control and compliance measures may be set forth by:– IHDA’s HHF Compliance team– U.S. Treasury– Special Investor General for the Troubled Asset Relief Program

(SIGTARP)

Compliance Monitoring

Site Visits

• Site visit locations:– Closed Units– Partner’s offices– Other relevant locations

• Components of a site visit– Record reviews– Staff interviews– Unit inspections– Anything else deemed necessary

• Scheduling

Compliance Monitoring Continued

Documentation Requests

• IHDA will provide reasonable notice for record reviews

• Records may include:– Laborer contracts– Paystubs– Receipts

Compliance Monitoring Continued

Financial Audit

• Both the ULG and NFP partner shall provide the A-133 compliance audit 90-days after the end of fiscal year.

• If an A-133 is not required please submit what is required by law such as:

– Annual audited financial statements – Financial statements reviewed by third party.

• An extension can be granted

• Submit financial audit or extension request to: [email protected] 

Compliance Monitoring Continued

Corrective Actions

• IHDA may issue a review report at the conclusion of all monitoring activities, site visits, or desktop reviews.

• Areas of potential non-compliance will be highlighted and IHDA will require a Correction Plan.

Document Retention

• The ULG and NFP shall retain all records

• NFP shall retain their respective Records for a period beginning on the Initial Closing Date and expiring five (5) years from the last Unit Closing Date.

– Upon expiration of the Retention Period, ULG or NFP may dispose of its Records, provided that, it has electronically submitted all Records to the Authority and has received confirmation by the Authority of the receipt of said Records.

Suspected Fraud

• Resources for reporting fraud are available to partners and the public on the IHDA BRP Website

– Reporting to IHDA: [email protected]– All reports of suspected fraud will be investigated

• Escalation

• Cooperation

• May result in:– Full review– Site visit– Suspension of future funding– Recapture

Quarterly Status Report

• NFP shall provide status reports to IHDA on a quarterly basis.

• The due date for each report will be the 15th day following the end of the quarter. If the 15th falls on a non-business day, the report will be due the first business day following the 15th.

– Due January 15th

– Due April 15th

– Due July 15th

– Due October 15th

• The first of these reports will be due January 15th, 2016

Quarterly Status Report

• Reporting Expectations for all Units:– Estimated greening and demolition dates– Maintenance completed for the quarter– Citations or violations received on the property– End use plan– Post-closing income– Staffing changes– Marketing plan– Key successes and challenges

Quarterly Status Report Demo

Compliance Reminders

• Benchmarks Reminder– Date to complete all demolition and greening: May 31, 2017

• Dependent on effective date of CCL– Minimum 3 unit closings 6 months after signing Tri-Party Agreement – Date to complete at least half of the Unit closings: May 31, 2016

• Dependent on effective date of CCL

• Submit the following to [email protected]– Annual financial audit 90 days after end of fiscal year– First Quarterly Status Report January 15, 2016

Compliance Contacts

Rosanne Sepka, HHF Compliance Supervisor

[email protected] ● 312-338-0540

Melinda Koenig, HHF Compliance Analyst

[email protected] ● 312-338-0522

George Kanoon, HHF Compliance Analyst:

[email protected] ● 312-338-0528

• For any programmatic related questions please contact your Program Coordinator @ [email protected].

COMPLIANCE QUESTIONS

Reporting Guidelines

• Quarterly Reimbursement Requests will be due on the provided due dates (quarterly from the date the tri-party agreement is signed)

Reimbursement Request Due Closing with Legal (expected)

9/30/2015 10/30/2015

12/30/2015 1/29/2016

3/30/2016 4/29/2016

6/30/2016 7/29/2016

9/30/2016 10/30/2016

12/30/2016 1/30/2017

3/30/2017 4/30/2017

5/30/2017 6/30/2017

Reporting Guidelines

• A reimbursement request will include:– One Reimbursement Request Summary Sheet of all properties (Excel

coversheet)– One package per property (PDF):

• A completed BRP Individual Unit Report (individual tabs in Excel sheet)• A completed Reimbursement Checklist• All items on the Checklist

Reporting Tips

• All reports must be completed based on checklist guidelines

• Complete one Excel tab per unit (BRP Individual Unit Report) itemizing all expenses for that unit

• One PDF per unit – labeled as the property address – First page should be the Excel tab corresponding to that unit– Include all items on the checklist

• Complete the Reimbursement Request Summary Sheet to match all items reported in the individual Unit reports

• Be sure to submit the Excel sheet with all tabs completed – If there is a tab in the Excel sheet for a unit, be sure there is a PDF for that unit– If there is a PDF for a unit, be sure there is a tab in the Excel sheet for that unit

Reporting Tips, cont.

• If one invoice covers more than one unit – include the invoice in each unit’s packet

• Label all invoices and items on invoice with the corresponding line items– Write on the receipts and invoice to clarify individual items, partial expenses,

etc.

• All reports can have lines added for more itemizations and more tabs for more units

• The more organized the report is when it comes to IHDA – the more promptly funds can be approved for payment

Program Guide Updates and Reminders

• Section 6.2 BRP Lien reads in part,– In certain cases, IHDA may allow early release of lien prior to

expiration date based on merit of request and proposed positive impact to the community

– NFP and ULG required to submit Early Lien Release Request Form– Funds for maintenance may be required to be repaid (with forgiveness

calculated at 1/36 per month)– Administrative fees will not required to be repaid

Program Guide Updates and Reminders

• Section 9.13 Program Income reads in part,– Program Income is any money received by a ULG and/or NFP relating

to a Unit under the Program– Begins to accrue at signing of CCL and includes any reclamation or

recycling income from the sale of a deconstructed Unit– Receipts must be supplied with the Request for Reimbursement at the

time of Unit Closing– Can be used as offset towards additional Eligible Uses under the

Program– Program Income that may occur during the 3-year period includes but

not limited to leases, rental income, etc. must be tracked and available for review if necessary

Program Guide Updates and Reminders

• Davis Bacon– Partners required to pay prevailing wage and may be subject to review

• Touch bases with IHDA prior to any marketing or press release – Classified ad copy for bidding requirements excluded

• Refer to your executed Tri-Party Agreement and the Program Guide regularly

QUESTIONS?