By Murray Wennerlund published 7-27-2019 updated 1-15-2022
All comments need to address HUD about the state of Louisiana OCD-DRU Action Plan Amendments 10, 11 and 12 and all SBA Loan issues covering all income brackets.
How to send your comment to the state of Louisiana OCD-DRU for Action Plan Amendment 12 and the SBA DOB fix issues.
Email to: email@example.com
SUBJECT: Public Comment APA 12 by [ENTER NAME First, Last]
Copy between the "Start Comment and End Comment" then send.
You can send as often and as many different comments as you would like.
You can send multiple comments in one email.
All comments will be addressed by the states Communications Press Media persons.
Comments are in no specific order and address all concerns in APA 12 published here.
Start Comment 1.
Please force the State of Louisiana OCD-DRU to return the $171 million identified in APA 11 to the Homeowners Assistance Program grant fund for homeowners. It is clear the State OCD-DRU and grantee for the 2016 floods did not follow its public statements made in July 2018 and in Sept. 2018 stating &ldquoThe OCD-DRU would wait for the HUD guidance to be published&rdquo. At that time the State OCD-DRU indicated there was a total of $ 683 million, which would cover the cost of EVERY SBA loan. Today, the State OCD-DRU has now said they do not have enough money to cover all SBA loans, as publicly stated in July and September 2018.
I am requesting that you investigate the issue and please force the State of Louisiana OCD-DRU to return $171 million to the Homeowner&rsquos Assistance Program which would then be balanced to provide relief for all of those that have and were forced to take SBA loans to cover the cost of this tragedy that befell us here in Louisiana in the year of 2016. The State of Louisiana acted prematurely in diverting funds out of this program, forming and funding additional programs before all LMI, unmet needs and urgent needs were addressed.
End Comment 1.
Start Comment 2.
Comment on APA 12
From July 2018 budget of $683 million to Oct 2018 budget of $245.5 million. There was a decrease in funds, in Oct. 2018, to $245.5 million. Where did this money go? Even after removing the funds for Comite project, there is $427 million left, however the Oct. 2018 budget shows there is $128 million unaccounted for, according to the State of Louisiana public press releases. Will anyone make this state accountable for the missing dollars?
End Comment 2.
Start Comment 3.
Solution 3 100% Reimbursement program was closed Dec. 31, 2018 which means they wouldn't have known the full amounts of actual distributed money. Keeping the budgets talked about in the Management meeting Oct. 10, 2018 and closing the Governors Reimbursement programs there is a shortage of funds once promised in July 2018 in the amount of $128 million. To reduce further issues the state now is blaming HUD's 55% goes to LMI as the excuse the program is short by $124 to $128 million, according to the state&rsquos pipeline reports of 2019. The need for > 120% is $129,074,719 The Budget for > 120% is now cut in half to fit at $64,537,360. The numbers reference come from the $309 million the Congressman asked for in July 2018.
Taking the $309 million and apply the $5 million from APA 10 and the $171 million from APA 11 there is roughly $133 million which is close enough to say it's the $129,074,719 that was budgeted. With basic data factored in, the state had budgeted for 100% of the SBA loans to be paid off, however they 100% forgot that a balance between LMI and >120% was not factored into the budget the full year of 2018. That is the same year the State OCD-DRU began dropping LMI households for any possible reason but not with SBA interests in mind, no way, it was Comite, Watershed, Economic Development, and Infrastructure. It is documented that the Director of OCD, Patrick Forbes, in Dec. 2017 was asked if he felt the Stafford Act Amendment by Graves would have any help to SBA loans. His reply was "No", from that moment on every politician and task force member was looking for and using their words, "Creative ways" to use HUD CDBG-DR funds for other projects. The 18 months of researching and following this program proves that budget and management issues were not followed correctly.
End Comment 3.
Start Comment 4.
In 6 days, the state will terminate grants allocated to homeowners of all income ranges, however those homeowners aren&rsquot able to come up with the recapture amounts the state is asking for. Instead of helping homeowners&rsquo budget and save over the next 2 years they are simply terminating their grants. The unallocated grants then become property of the state and are not used in the same program to which they were first allocated. This means more to Watershed, Infrastructure, Economic Development and more Louisianans homeless. This is a massive budgeting mistake on the part of the state of Louisiana and they are covering it up by blaming the homeowners, which in this case are mostly all Low to Moderate Income. There is more than 1 year for the SBA Loans to the > 120% but less than one week for 1,565 homeowners that could be part of $58 million in repair money.
End Comment 4.
Start Comment 5.
APA 12 Page 2: "This APA 12 is considered substantial per guidance issued in 84 FR 28836. However, APA 12 proposes no programmatic budget changes nor does it propose new eligible activities within programs established in previous action plan amendments. This APA 12 does not propose additional applicants as a result of the DRRA. Regarding the programs referenced expected to be impacted by the DRRA, all intake periods have closed and will not be extended as a result of the DRRA."
"However, APA 12 proposes no programmatic budget changes nor does it propose new eligible activities within programs established in previous action plan amendments."
Note: APA 12 in it's current form shows no program budget changes which is true, but, because it shows no program budget changes the current program is not funded enough to cover all the eligible applicants. This is evident in APA 12 on page 18 "LMI Phase II Adjustments (>120% LMI)"
"...APA 12 proposes disbursing funds to populations with incomes in excess of 120% AMI using a multiplier of 0.50"
The 50% reimbursement instead of 100% reimbursement appears to be related to an over spending in the Solution 3 Reimbursements program when it changed from 50% to 100% July 2018 under Governor Edwards request. The Task Force questioned the state about SBA DOB funding and the state assured the task force that all SBA DOB will be covered. The task force voted unanimously for the Solution 3 Reimbursements increase from 50% to 100%.
The program was correct, it did have the budget balanced up and to APA 10 for $5 million and APA 11 for $171 million. Taking the figures provided by the states policy makers in APA 12, it is clear that the state of Louisiana required $129,074,719 at a minimum to cover all income groups under the SBA DOB changes in both Public Law 115-123 and 115-254. To balance the budget, the state reduced SBA DOB offerings that impacted a single income group, the >120% AMI households which is shown in APA 12 on page 18. The state did not restrict Solution 3 Reimbursement homeowners to a multiplier of 0.50 as it is doing in APA 12. This type of housing discrimination has been addressed in other storms and other programs when one group or class of citizen is given a higher award amount based income or geographical location. In this case it appears the discriminating factor is those accepting a federal disaster loan from SBA compared to those that accepted traditional lenders and bank loans in Solution 3 Reimbursements program which closed Dec. 31, 2018.
End Comment 5.
START COMMENT 6.
Grant Closing Deadline July 31, 2019
State of Louisiana OCD-DRU sent out a RLHAP email asking select applicants awarded grants but have not closed on the grant award a survey to complete in June 2019.
June 12, 2019 a policy notice to select grant recipients was emailed notifying the applicant of a July 31, 2019 deadline. I believe an estimated 1,565 homeowners granted nearly $58 million were put on notice by the state of Louisiana OCD-DRU.
The email notice dated June 12, 2019 read as follows:
You are receiving this notification because you have not closed on your grant award offered by Restore Louisiana.
Please note that you MUST execute your grant agreement by Wednesday, July 31, 2019 or the grant offered will be rescinded and you will no longer be able to participate in the Restore Louisiana Homeowner Assistance Program.
Please reach out to your assigned Case Manager as soon as possible to schedule your closing:
Case Manager Name: Name
Case Manager Email: case manager restore-la.org
Case Manager Phone: 225-555-xxxx
The Restore Louisiana Homeowner Assistance Program "
End Email Notice June 12, 2019
No additional information was offered in this email
Applicants were not aware nor were they informed of any right to appeal or how to request additional time.
When OCD-DRU Director Patrick Forbes was asked why homeowners were not given more information on asking for an exceptions board review he stated that all case managers were made aware of the process to request additional time. Homeowners found no information like this was offered in writing or by case managers.
This notice caused panic among homeowners still working on satisfying recapture amounts and other requirements the grantee has put in place over the last couple of years in several versions of documents and action plans.
Many of these homeowners are LMI households and many of them come from condemned and substantially damaged homes. These homes uninhabitable or demolished will never be rebuilt or repaired for the original families. These families will be forever homeless especially those below 50% AMI that were sons and daugthers of parents that saved their money and paid off the home so their children would not be homeless. In a day, they lost their home to floods. With a 45 day notice they lost their dreams of returning home.
In APA 12 the state of Louisiana identifies a group of grant recipients that have not closed on their grant awards. The state made no public statement about the July 31, 2019 grant closing deadline that was clear and without doubt not related to hundreds of homeowners. Even on the states official Restore.LA.Gov website the bottom line: "This deadline may not apply if you have SBA DOB. Please reach out to your assigned case manager for any questions." This was ambiguous to hundreds of homeowners that called and emailed case managers. Those that received the letter from June about the deadline of July 31, 2019 recieved information from case managers that they could not ask for additioanl time while others were simply told it doesn't apply. This type of communications has happened often in the program and without policy published in a scheduled and with advanced notice and given reasonable time for homeowners to comply with the new policy many simply feel the state has all the control over their grants awards and they can't say or do anything to secure their recovery.
The deadline for new applicants announced July 13, 2018 during the task force meeting was Dec. 31, 2018.
I ask HUD to instruct the OCD-DRU to reinstate the households who had the July 31, 2019 deadline to close on their grants and give all the homeowners in this group 180 days to make financial arrangements or construction arrangements for them homes.
END COMMENT 6.
START COMMENT 7.
RESTORE LOUISIANA TASK FORCE
July 13, 2018
Louisiana State Capitol House Committee Room 5 900 North 3rd Street Baton Rouge, Louisiana 70802
GOVERNOR JOHN BEL EDWARDS ADDRESS:
"RESTORE is mandated to operate in accordance with the guidelines set forth by the US Department of Housing and Urban Development, which provides the federal funding to operate the program. And I want to stress to everyone here today, and those watching online, again, the expansion of reimbursement funds will not jeopardize any potential grant funds available in the future to homeowners affected by Small Business Administration loan duplication of benefits. Should HUD tell us that the program no longer needs to consider declined SBA loans as a duplication of benefits, either because their interpretation of federal law changes, or because the law itself changes."
Dear HUD, Force the state of Louisiana and it's Governor to keep its promise we have waited years on and trusted our Governor to keep. Force the state to repeal the sections in APA 11 that transfer $171 million out before waiting on the guidance as promised by Governor Edwards July 13, 2019 during the public task force meeting at the state capital.
END COMMENT 7.
START COMMENT 8.
Is it possible to end the programs for hurricanes Katrina, Rita, Gustav, Ike and Isaac officially and allocate the undistributed funds to the 2016 floods Homeowners Assistance program directly assisting homeowners financially?
New programs approved by HUD such as the Cost Share payment program for homeowners elevating could be a great benefit to the Great Floods of 2016 programs. More funds to homeowners would allow more assistance and greater assistance. From cost share programs with FEMA HMGP and FMA to soft second mortgages for those in need of assistance managing their recapture payment. The hardest hit in any disaster recovery is those that have no means of financially surviving the disaster. Since the hurricanes I have listed no longer assist homeowners directly wouldn’t it be logical to move the money assigned to those programs to the most active program and most current program to assist more homeowners? Having 25% of FEMA costs paid by HUD CDBG-DR grants would impact more homeowners after the 2016 floods waiting for elevation grants than any past storms.
END COMMENT 8.
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Other Public Comments from past Action Plan Amendments
Comments from Louisiana Disaster Victim Facebook Groups and in collaboration with TruckAndTools.Com sponsor of LouisianaRecoveryAuthority.Org we offer the following prepared public comments for you and your household to use in part or whole without copyright restrictions. We also ask that you share with us your comments so we can have others supporting your cause, your household and your disaster recovery.
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Frequently Asked Question
Does the Restore Louisiana OCD-DRU HUD Grant program offer a Scheduled Draw payment?
Frequently Asked Question
What does disaster Unmet needs mean?