Research based learning
"Providing resource supported answers."
Comment: Insurance will be needed or you will get nothing. But even then you will need to know how to navigate a system that the states create to make it impossible for them to navigate. Insurance required to cover federal assistance received.
Financial disaster recovery planning team within the Administration grant funding.
OCD-DRU trainer for all county, parish, city, town planning and zoning departments for HUD compliance training.
Resource: HUD OIG Report 2013-FW-0001
>> Start snip of report page 19,20 <<
Some States Did Not Take Sufficient Steps To Protect the Invested Federal Funds
Some States did not require adequate homeowners' insurance for the homes built or rehabilitated with Disaster Recovery funds. Texas initially did not require insurance. It modified its program for the Katrina, Rita, and Wilma second allocation and, along with Louisiana and Florida, required insurance for 3 years. Alabama adopted a deed restriction that "strongly encouraged" insurance. For the Gustav, Ike, and Dolly allocation, Texas again modified its program and stated insurance was required, but its policy, like Alabama's deed restriction, stated only that failure to maintain insurance "may" impact future disaster assistance. However, Mississippi took an aggressive stance by requiring a transferable covenant that required insurance at all times. These variations occurred because HUD allowed the States maximum feasible deference in the implementation of their Disaster Recovery programs as allowed by the State CDBG program.
HUD needs to adopt a best practice to address the issue of insurance to ensure that the Federal funds invested in the assisted homes are protected in the event of future hurricanes or disasters. Since Hurricane Katrina in 2005, an additional 10 hurricanes and other storms have hit the States and caused damage. Further, our audit of Texas13 found that Hurricane Ike had damaged homes repaired or replaced by Katrina, Rita, and Wilma grant funds, which lacked insurance. In one extreme case shown in figures 10 and 11, an uninsured home suffered significant structural damage, and the homeowner inquired about additional disaster assistance for his recently replaced home.
The Texas audit also found that of a sample of 59 Katrina-, Rita-, and Wilma funded homes tested, 38 homes were later damaged by another hurricane or storm. Of the 38 homes, 23 did not have insurance. Based on a projection of the sample results, at least 133 of 453 reconstructed or rehabilitated homes or homes awaiting reconstruction lacked insurance and were damaged or are at risk of being damaged by another storm. The report concluded that if Texas changed and improved its action plan and policies, an estimated $60.2 million in program funds could be saved.
For Hurricane Isaac, which struck in August 2012, initial reports estimated damage to 13,000 homes in Louisiana located in the same areas previously affected by Katrina. Since Louisiana required insurance for only 3 years, there is the potential that damage had occurred to Disaster Recovery-assisted homes completed before 2009 that may lack insurance, as the State's required insurance period had expired and nothing would prevent homeowners from seeking additional Federal assistance.
>> End snip of report page 19,20 <<
Date: 12-30-2018 Updated: 12-30-2018 Subject: Transparency
State of Louisiana HUD CDBG-DR AMI (%) Percentage.
Need more information? Here's your jump board.
If your AMI changed from below 80% to over 80% and under 120% you can appeal that your increase has not be for two consecutive years. Over 120% AMI you can argue the on the same grounds if your increase has not been for 2 consecutive years. (Based on light Sunday reading)
Those of you that are over HUD's income limits (120%) and would like to understand more about how HUD determines over income limits this link is for you.
Resource link: FR-2018-07-26
Very Low Income * 2.4 = 120% AMI.
Very Low Income is 50% AMI.
Example: State wide VLI family of 2 = $24,850
$24,850 * 2.4 = $59,640 120% or HUD Income Limit.
So be sure the state doesn't use the math I just showed you. Some areas are much higher while others are lower. The state really likes to put everyone in one box, so look out for a spreadsheet with the above calculations in VLI for your areas.
Example: Louisiana State Wide 120% AMI.
- CDBG Income Limits
- HUD Notice Sets HOTMA Over-Income Limit
National Low Income Housing Coalition (NLIHC)
Date: 6-16-2019 Updated: 6-16-2019 Subject: AMI
34. Rental assistance to displaced homeowners. The requirement of 42 U.S.C. 5305(a)(8) are modified to authorize grantees to extend rental assistance payments on behalf of qualified homeowners for up to 24 months. After a disaster, many homeowners encounter unanticipated delays and scarcity of available construction and/or elevation contractors in their area. While undergoing rehabilitation of their homes, most of these homeowners are forced to pay not only a mortgage, but a rental payment as well since their homes are not inhabitable. In other cases, homeowners who have paid off their mortgages must accommodate this additional rental expense into their budgets. In order to provide temporary financial assistance to these families, many of whom are low- or moderateincome households, HUD is modifying the requirements at 42 U.S.C. 5305(a)(8) to the extent necessary to allow grantees to provide up to 24 months of homeowner rental assistance to eligible applicants within the grantee's singlefamily rehabilitation/reconstruction programs. In the case of rehabilitation programs in which the homeowner is responsible for construction oversight, the grantee must establish performance milestones for the rehabilitation that are to be met by the homeowner in order to receive such payments. A grantee using this alternative requirement must document, in its policies and procedures, how it will determine the amount of assistance to be provided is necessary and reasonable. Homeowners receiving interim mortgage assistance are not eligible for rental assistance.
Date: 6-15-2019 Updated: 6-15-2019 Subject: Allocations
33. Limitation on emergency grant payments - interim mortgage assistance. 42 U.S.C. 5305(a)(8) is modified to extend interim mortgage assistance to qualified individuals from 3 months to up to 20 months. Interim mortgage assistance is typically used in conjunction with a buyout program, or the rehabilitation or reconstruction of single-family housing, during which mortgage payments may be due but the home is uninhabitable. The time required for a household to complete the rebuilding process may often extend beyond 3 months, during which mortgage payments may be due but the home is inhabitable. Thus, this interim assistance will be critical for many households facing financial hardship during this period. Grantees may use interim housing rehabilitation payments to expedite recovery assistance to homeowners, but must establish performance milestones for the rehabilitation that are to be met by the homeowner in order to receive such payments. A grantee using this alternative requirement must document, in its policies and procedures, how it will determine the amount of assistance to be provided is necessary and reasonable.
Date: 6-15-2019 Updated: 6-15-2019 Subject: Allocations
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. "
According to reports filed for April and May the state of Louisiana Office of Community Development Disaster Recovery Unit working under the name of Restore Louisiana Homeowners Program has increased it's speed of processing grant awards by increasing the number of rescinded grants offered to homeowners.
April of 2019, 30 homeowners have had their HUD CDBG-DR grant awards rescinded by the state for state created policy reasons.
May of 2019 278 homeowners have had their HUD CDBG-DR grant awards rescinded by the state for state created policy reasons.
The state of Louisiana's timing will match the 3rd year since the flood and fall on or close to the anniversary date of the August 12th 2016 floods.
It appears the state has not formally offered homeowners with alternatives to their recovery. With over 2,000 homeowners at risk of losing everything from the flood to include all additional grant funds for unmet needs the state will face additional homelessness and blight as a result of meeting goals and deadline.
HUD officially allows the state to run the distribution of funds up and to the Sept. 2022. The state of Louisiana OCD-DRU has announced several times the closing dates of programs in 2018 and continues by rewording the closing of programs to the rescinding of grant awards.
"Elsewhere, this notice describes the extension of the expenditure deadline that the Department is authorized to provide to all CDBG-NDR (NDR = National Disaster Resilience) grantees, allowing them to expend funds until September 30, 2022. "
Grantee Name: Louisiana
Grant Number: B-16-DL-22_0001
Grant Award: $1,708,407,000
Average of March, April, May Spending: $23,334,110
Grantee Spending Status: On Pace
NOTE: On Pace = Spending greater than the monthly pace required to fully use the grant by target closeout date.
- Monthly CDBG-DR Grant Financial Report May 31, 2019
- CDBG-DR Reports Posted: Monthly Reports
- Feb. 19th 2019 waivers Public Laws 114-223, 114-254 and 115-31.
Public Laws 114-223, 114-254 and 115-31.
Public Laws 114-223 (Approved September 29, 2016)
Public Laws 114-254 (Approved December 10, 2016)
Public Laws 115-31 (Approved May 5, 2017):
Waivers and Alternative Requirements for CDBG-DR Funds Appropriated by Public Law 114-223, 114-254 and 115-31 (Applicable only to the State of Louisiana)
Pursuant to the Prior Notice, each grantee is required to expend 100 percent of its allocation of CDBG-DR funds on eligible activities within 6 years of HUD's execution of the grant agreement.
Date: 6-13-2019 Updated: 6-13-2019 Subject: State Contractors
Do you have copies of the discussions and first drafts?
"WHEREAS, Louisiana has invested and is continuing to invest significant resources toward creating organizations such as The Water Institute of the Gulf and university centers that build the state's strength as a unique, global leader in water management; and
Have you participated with the collection of data related to Mississippi River Basin Wide Modeling in the past decade with a group called "The Water Institute of the Gulf?"
Several Not For Profits, For Profits, and University Science Research groups may have been purposely excluded from grant awards published in Public Law 115-123.
Editors Note: Has the state of Louisiana and it's capital region taken economic development over collaborated scientific research between Not for Profits, Universities and For Profit organizations?
Modeling software developed by one university may share the same data as another and provides slightly different results. Modeling software such as Hurricane Tracking software often produces different results. They may be similar but no two data calculating applications seem to produce the same results. Many factors are included but are not important for this report. What is important is knowing that non technical, non science community individuals have lobbied for specific modeling software provided by a group that is located in a part of the state of Louisiana that is only interested in economic growth from the grant awards related to Public Law 115-123.
Date: 6-13-2019 Updated: 6-13-2019 Subject: Watershed
Let's first start off with some resources to bring you up to speed.
Then, in a article we'll share what one homeowner is doing in the southern state of Louisiana to fight against rusty ducts, dirt, moisture in the air and just plan cool sticky inside the home. Enough, we're not from the stone age, let's work the science of building.
Resources to read:
- BSD-102: Understanding Attic Ventilation by Joseph Lstiburek Oct. 26, 2006
- Info-015: Top Ten Dumb Things To Do In the South by Joseph Lstiburek Feb. 5, 2009
- Attic Ventilation Florida Homes Parker FSEC-CR-1496-05 linked from Inspectapedia.com
- Minimizing Water Intrusion Through Roof Vents in High-Wind Regions FEMA publication
- Roof & Attic Water Intrusion Division of Emergency Management Bureau of Mitigation Tallahassee, Florida 32399-2100
- 2015 International Residential Code
Date: 6-9-2019 Updated: 6-9-2019 Subject: Construction
You will find a time you need to question those who claim to know their processes. You will need to be able to research those inspecting and offering you information to make sure you are given the best most accurate information. It is your duty to verify everything that is said to you verbally, cross reference everything that is in writing and be sure you know you have the right to ask questions until you have a full understanding of your FEMA sponsored recovery.
Your family, your home, your property is and should be the most important thing in your life during a disaster and during the disaster recovery period. It may take you months or years to recover, you are the only one that will protect your rights to federal assistance. Don't sit back thinking someone is going to do it all for you. Get active and become pro-active with your Federal Disaster Assistance. It's not a handout, you have paid into the system since the first day you paid federal taxes.
- FEMA issued Bulletins to the NFIP Clearinghouse Community
- More information for Claims & Adjuster Community
- More information for the community regarding Policy
- Links to various Flood Insurance Manuals
- NFIP Training
- Links to NFIP Training Courses for Agents and Adjusters.
- BureauNet Reporting
- The place to go for reporting and community related documentation.
Date: 6-4-2019 Updated: 6-4-2019 Subject:
In fact, the Morganza Spillway actually flows into a Floodway then that spills over into the "Spillway" which causes the flooding.
The 30 day waiting period does not apply to secured loans using your home as security such as a mortgage. Also, you can insure your home for up to $250,000 for the structure and up to $100,000.
You would have to have all of your contents placed inside the NFIP insured structure before the flood event.
This memorandum was in reference to the Morganza Spillway opening May 17, 2011. Once the Spillway is open it is a flood, a flood in progress and it is too late to insure your home at that point.
Please read this document if you do not have flood insurance and own a home in the spillway.
- Morganza Spillway (Wikipedia.Org)
- FEMA Flood Smart exceptions "Is their a 30 day wait period?"
- If you purchase flood insurance in connection with making, increasing, extending or renewing your mortgage loan, there is no waiting period.
- FEMA MEMO: Guidance Related to Flood-in-Progress Exclusion and New Policy Applications June 30, 2011
- "Property owners in the path of Mississippi River flooding are taking out mortgages to beat the 30-day waiting period on insurance" NOLA.Com article AP article.
- Insurance to pay for preparations/damages in spillway flooding, 2011 Morganza Spillway Louisiana Insurance Director realated article. Please be sure to check with your bank for more details.
Date: 6-3-2019 Updated: 6-3-2019 Subject:
- Report published by the State of Louisiana Department of Community Development - Disaster Recovery Unit director Patrick Forbes and funded by HUD titled, Our Land and Water A Regional Approach to Adaptation. Published April 2019
HUD Sponsored the report that the State of Louisiana OCD-DRU created and presented. It was part of the National Disaster Resilience Competition HUD sponsored with $1 billion in grants. The competition is designed to provide a national model for adaptation. Louisiana wasn't first in prize money but it did earn it's spot amongst 13 other states.
The report is intended to serve as a national model for adaptation. The Department of Housing and Urban Development funded the $40 million project in 2016 through its National Disaster Resilience Competition, which allocated $1 billion to 13 states and cities, from California to Minot, N.D., to develop responses to climate change.
Date: 6-2-2019 Updated: 6-2-2019 Subject:
From 2017 Research into SBA Loans Declined by Households that were below 80% AMI and did not sign the closing documents.
June 6, 2017 Third Appropriation Funding Recommendation - Conference Calls between Restore Louisiana Task Force Members:
"HUD allows the state to provide assistance to LMI homeowners who were approved an SBA loan, but declined it and never entered into a loan agreement with SBA. The cost of providing assistance to these homeowners is approximately an additional $5,152,000."
Additional research showed that in 2016 the state anticipated only 109 households would be in this category.
Follow up research first quarter of 2018 showed that the state did not have a process in place to notify homeowners that matched the "HUD" Nov. 16, 2011 Hardship Guidance and appeared to simply ignore the topic and allow the homeowners to think they had to wait for the Congressional SBA fix.
Follow up research 2nd quarter of 2018 an Advocate Reporter messaged me telling me the state closed the "Loophole" (His word) and no other hardships were being processed. This was the same time they changed Homeowners Assistance Director from a state employee to a temporary hire from CSRS Inc. by the name of Stacy Bonnaffons. As you all are aware, Stacy was the topic of a contract that did not get renewed because of a conflict of interest within the program and possible bid rigging. She has been cleared by the state ethics board but only for what was published. Could this actually be the person that denied Low to Moderate Income families their Recovery funds by not declaring hardships in accordance with HUD Guidance of Nov. 16, 2011?
Conclusion: Since management change that included temporary hires from CSRS Inc. no additional homeowners that qualified for a hardship waiver have reached out to me to report their status.
Fall of 2018, document requests identified what could be a minimum of 1,158 homeowners incorrectly classified under the Duplication of Benefits calculation for SBA loans. The states legal department headed up by Dan Rees by not responded to my request to research this issue has in my opinion allowed HUD Core Objectives to be ignored and has penalized Moderate to Low income families by not researching the 1,158 homeowners which the numbers (not names) were given to me by the same legal department in which Dan Rees works.
News media was informed about this issue and felt it was not "News Worthy" .
I would like to find ONE family, one family that applied for the SBA loan, then declined to accept the loan, did not sign the closing paperwork and is below the 80% AMI household income.
Help me find just one household that matches the Guidance from Nov. 16, 2011 and you may have just helped one thousands households recover after the flood.
I'm posting this because a law firm stated if you can prove damages they would represent the 1,158 in a class action. The damages are in the email, estimated $5,152,000 that may or may not have been allocated to low to moderate income families by the state during the time of CSRS Inc management.
- Emails Lori Dupont to Louisiana Task Force Members.
- HUD Allocations discussion and conference calls.
- Various state sources under the FOIA.
Date: 5-30-2019 Updated: 5-30-2019 Subject:
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