Open Letter to Congressman Graves posted on Facebook.com Congressman Garret Graves comment by Murray Wennerlund.
The language sounds like you're talking HUD but you start with the federal management agency.
This would really work better if you could get the Administrator of the Emergency Management (FEMA) to address the disaster assistance delivery. If we could add to H.R. 1311 verbiage making FEMA refer disaster victims to either HUD or SBA based on FEMA's financial controls which would need to be modified from their current method of identifying if a household has at least one income maker.
If we had FEMA refer the Low to Moderate Income (LMI) which HUD identifies as 80% AMI or less directly to HUD CDBG-DR federal assistance and all those at 120% AMI or greater to SBA then you only have to figure out how to manage the middle income families that most likely do not have enough resources available to them to make a full recovery without adding serious debt burden on their households.
Simply by splitting LMI off in the first week we would have saved over 29,000 families from being denied assistance later with the Restore Louisiana program.
If those that had incomes at 120% or greater were advised by FEMA to seek "Other Assistance Elsewhere" which means their income and credit would have allowed them to seek conventional lenders which would not have resulted in the SBA DOB issue we face today. It would have instructed credit worthy households to take conventional loans even if the interest and terms were not as good as the SBA. The loans would have not penalized them thus making them "Reimbursements" in the HUD CDBG-DR program.
So the only demographic and the heaviest in voters is the 81% to 120% group, either directly these households typically run at 75% of their total income to reoccurring debt. To add the financial burden of a disaster to their households it normally means they seek additional income. They are below the cash in hand market standards to qualify for loans in the amounts for a Assistance Elsewhere approach with their recovery as the 120% AMI groups are. This middle class group uses more credit cards that are very high in interest rates. This short term cash advance system at 17%+ interest adds a financial risk of default on the primary mortgage not to mention the stress this type of debt causes. For these households we need a focus on local banks willing to offer lines of credit to rebuild that may have state backing but not federal taxpayer dollar backing which would make the credit line a DOB.
The hardest group to fund is also the same group suffering in the recovery process.
Recap: Between the below 80% and the above 120% comparing programs we use today both demographics would suffer ZERO in structural repairs. HUD CDBG-DR Grants for the 80%, 100% reimbursements to the 120%.
Where is the wording that focuses on the the middle class 81% to 119%?
By the way, you're doing great with pushing the Stafford Act.
Now let's push the Sequence of Delivery amendment so we can get people fixed in the first 3 months instead of the last 3 years of the HUD CDBG-DR program.
Research Resources:
