Deferment Calculations were not always based on square footage of home.

If you have requested a deferment to reduce your Grant Recapture, Homeowner Responsibility or Escrow amount your deferment may have been calculated incorrectly according to Scope Deferment Policy updates June 6, 2019.

If you are in Reconstruction your sqft of your old home will be used with 8' ceilings if your old home was not inspected and documented by FEMA, HUD or NFIP Insurance adjusters.

Spreadsheet Tool: If you can use a XSLX spreadsheet a download link will be available in a few days to check the calculations of your states HUD CDBG-DR programs.

Web App: Online app will be available to check calculations for your deferments soon.

Deferments are approved and supported by many states and allowed by HUD for CDBG-DR program managers to reduce the upfront costs to participate in the federal disaster recovery grant programs. Deferments assist homeowners with other agencies grant "Recapture" requirements when their is a duplication of grant money issued (Duplication of Benefits or DOB). State agencies will attempt to reduce to Zero the Recapture amount also known as Homeowners Responsibility and Escrow if possible.

FAQ No. 162    

Date: 9-13-2019 Updated: 9-13-2019 Subject: Deferment

Resources:

• https://watershed.la.gov/action-plan
• https://www.doa.la.gov/Pages/ocd-dru/Index.aspx
• https://www.watershed.la.gov/news/press-releases/hud-officials-issue-guidance-for-louisianas-1-2-billion-flood-mitigation-allocation
• CDBG-MIT Action Plan Public Comments 9-12-2019
• Docket No. FR-6109-N-02

More updates and a new section covering CDBG-MIT for your community coming online here at Truck And Tools soon.

FAQ No. 161    

Date: 9-12-2019 Updated: 9-12-2019 Subject:

This grant calculator applies public law 115-123 and 115-254 for disaster victims. It will calculate and check your states Grantee numbers. Reimbursements to Elevation based on Louisiana costs. Share results an state data for updates.

This Grant Calculator provided is designed to calculate HUD CDBG-DR Grants based on Reimbursements, Repairs and Duplication of Benefits. I added the calculation rules from Public Laws 115-123 and 115-254. I also added HUD Guidance that was published June 14, 2019. HUD Guidance released June 14, 2019 covering disasters between January 1, 2015 and December 31, 2017.

Follow the link to Murray's CDBG-DR Grant Calculator with updated Reconstruction and Elevation for Louisiana.

If you would like a grant calculator for your state please send a note using the contact page. I will need your states reconstruction and elevation procedural manual as well as your grant award to match formatting order.

FAQ No. 160    

Date: 9-3-2019 Updated: 9-3-2019 Subject: Grant

• How To Calculate your Households AMI percentage.
• What steps do you take if you are in Louisiana on how to correct your AMI percentage that is listed in your grant award.
• What factors change AMI percentages.

• Person One Adjusted Gross Income: $105,000
• Person Two Adjusted Gross Income: $20,000
• Total household income: $125,000

You should be able to contact your states HUD office or the state agency of Community Development and request the most up to date data sheets for AMI. Below you'll find links to 2019 AMI for over 120 percent and 2017 80 percent AMI.

• 120% AMI Data sheet download
• 80% AMI Data sheet download

Using the columns select the number of persons living in your home.

"Family sizes in excess of 8 persons are calculated by adding 8% of the four-person income limit for each additional family member. That is, a 9-person limit should be 140% of the 4-person limit, the 10-person limit should be 148%."

Once you have your family income limit, match that number with your total households tax returns.

If your calculated AMI is different from your grant award AMI send an email to your assigned case worker or case manager.

SUBJECT: Account ID: 123456, Last Name AMI Percentage Correction.

Message Body:

I have calculated my AMI percentage using data provided by our state and found the AMI percentage listed in my grant award is not correct. My grant shows 150 percnet and my calculation shows 79 percent. I would like to request that you forward my grant to Quality Assurance (QA) and Quality Control (QC) for AMI percentage corrections. Attached you will find the tax returns used to calculate my correct AMI percentage. I have also uploaded the attached documents to my eGrants file folder.

Thank you,
[First Name, Last Name]
[Full Address]
[Grant Account Number]

Depending if you are in Louisiana, Texas, North Carolina Peruto Rico or Florida just to mention a few that will be using this same email your contact will be different except for the IEM Project Manager which most of you have the same person to report to.

You will need to be persistant with your request. You are going to be told to wait, then you will be told that everyone is going to be calculated at the same time. This is an issue the state needs to address and it needs not to provide excuses to why your AMI percentage changes when your records and their records are identical. Many errors are manual input errors and we have seen months even years pass before they are corrected. Allow the state directors to explain why you can not have an accurate grant award with correct information.

If your Case Worker or Case Manager refuses to submit your request to have your grant award information corrected you'll need to go to the project managers level. Most of the disasters in 2016 and 2017 in the southeastern US are managed by IEM Inc. so your contact would be Ted.Lemcke@iem.com or if in the state of Louisiana it would be Ted.Lemcke@Restore-LA.Org . You will need to look up your specific program manager to be sure. Most times it will be the Homeowners Manager or Director from your states Community Development department (HUD).

Case Workers and Case Manager are not overwhelmed with work so allow one full business day for them to reply. If it takes longer than one full day skip them and go to the program manager.

The program manager will take about 3 business days or less. Once you get word back from the program manager you will either be in the system to correct the issue or you will be escalading the AMI percentage calculation to your states legal department and your project managers legal department. For Louisiana this is legal@iem.com for the project manager and dan.rees@la.gov for the state.

If legal departments after 3 days do not have the issue corrected or refuse to correct your federal grant award AMI percentage you will then need to forward all emails to your states housing manager. For Louisiana this is Spring.Garcia@LA.Gov .

It takes time to process this information and AMI percentage seems to be a manual calculation based on the number of reported areas in what should be a scripted formula.

The QA/QC process typically takes 30 days. You'll know it's being processed when you see your grant page locked. Check it daily after you start.

FAQ No. 159    

Date: 8-22-2019 Updated: 8-22-2019 Subject: AMI

State of Louisiana OCD-DRU Action Plan Amendment 12 asks HUD for approval to change SBA Loan repayment multiplier based on hardship matches.

APA 12, Page 19 the State of Louisiana Office of Community Development spells out hardships only after it spells out the option to change the repayment multiplier from 0.50 to anything between 0.0 and 100.

"Dependent on the proportion of applicants with incomes in excess of 120% AMI who also meet one or more of the approved hardship criteria, the state reserves the right to adjust this multiplier accordingly if it can do so and remain within required overall LMI benefit parameters."

Hardship Criteria for Homeowner Populations with Incomes Exceeding 120% AMI.

• Hardship due to housing cost burden. Individuals who spend more than 30% of their monthly gross income on housing costs are expected to experience hardship in recovery due to having limited financial resources
• Hardship due to SBA loan repayment. Individuals who spend more than 15% of their monthly discretionary income on SBA loan repayment are expected to experience hardship in recovery due to having limited financial resources
• Hardship due to advanced age. Individuals who are of an advanced age and are retired or for whom retirement is expected during the repayment period of the SBA loan. The reduced income or anticipated reduction of income that comes with retirement is likely to cause a hardship during the loan repayment period
• Hardship due to cost of caring for dependents. Homeowners responsible for providing care to parents, children, grandchildren, and other dependents have long-term financial commitments to consider when contemplating incurring additional debt. Additional debt would be a burden and limit available resources needed to provide for dependents
• Hardship due to major illness and/or death of wage earner. Households that have experienced a major illness or death of a household wage earner are anticipated to experience hardship in repaying SBA loans and completing recovery
• Hardship due to costs associated with higher education for self or dependents. Tuition and living expenses for dependents in higher education present significant financial needs to homeowners. Household resources are strained to accommodate education-related expenses and homeowners may not have adequate monthly cash flow to support an additional note
• Hardship due to loss of employment or reduction in income. A loss of income or job following the qualifying disaster event can impact the ability to repay a loan
• Hardship due to costs associated with disability and/or special needs. Additional costs related to evacuation, relocation, and rebuilding for a disabled/special needs household puts an increased burden on financial resources that might otherwise be contributed to recovery
• Hardship due to depletion of retirement account. Households who withdraw funds from their retirement account(s) after the qualifying disaster are anticipated to experience hardship during the repayment period of their SBA loan due to the loss of future retirement income.

The information provided on page 19 of the Restore Louisiana Homeowners Program Action Plan Amendment 12 appears to not include young, healthy singles, couples in the >120% AMI income bracket. This could be offset by repealing some programs for Economic Development and Infrastructure not targeted to the below 80% AMI Community.

Research Resource:

• Restore Louisiana Homeowners Program Action Plan Amendment 12

FAQ No. 158    

Date: 8-15-2019 Updated: 8-15-2019 Subject: SBALoans

We need people to help spread the word and assist us in our public public awareness campaign this weekend and all into next week.

The Campaign is to share with the public the promise Governor John Bel Edwards made to the people of Louisiana and to the Task Force as well as to his appointed head of OCD-DRU who controls the Restore Program Patrick Forbes.

The Governor said one thing July 13, 2018 that was later put into print by Director Forbes group and sent to HUD by Lori Dupont who is the Executive Assistant to Patrick Forbes. All was in balance with the world, $683 million was to be held, less $110 million for the 50% to 100% increase in reimbursements.

It was working smoothly, just needed to wait for HUD Guidance which we received June 12, 2019.
But it wasn't smooth, it wasn't public, it was a backroom rewrite of the promise made by Governor Edwards in his opening address. His executive agency Office of Community Development - DRU made a big mistake with numbers and it was Kim Jupiter who sent to HUD an updated version of Action Plan Amendment 9 that removed the promise to hold money until HUD Guidance was issued.

It's not a surprise to many the state has a difficult time budgeting money. Simple math could have had the LSU professors of economics running up the red flag. But the day (July 12, 2018) before the public dog and pony show no one was checking the numbers. It all sounded good.

• Limit total disaster victims to under 16,000, Check!
• Keep the total payout of grants under $580 million, Check!
• Promise the people $683 will be held until HUD Guidance is released, Check!
• Put the the plan to hold $683 million in the Action Plan 9 and send it to HUD, OOPS!

So they lied to you, it wasn't possible, you think the budget of the 55% is off by $64 million today could you imagine if $683 million of $1.7 million was promised to the people and 55% of that had to go to low- to moderate-income people?
It's all speculation to why the Governor promised to hold the money, the director of OCD-DRU promised to hold the money and then they changed their minds 2 days later.
Could it be from the emails sent wanting to close the program that fall?

This is your fight, this is the peoples fight. If you ever have paid a penny in federal taxes this is your fight.
The State of Louisiana promised to wait for HUD Guidance, they published APA 9 with the promise then they changed the plan and didn't inform you the public.

Is this the new politics we are going to except for the rest of our lives? $55 million here, $700 million there, $64 million SBA gone without a trace between July and Dec. 2018. Why do we not have government accountability when it comes to the people?

Governor Edwards and his agency OCD-DRU didn't keep the promise made to you last July, 2018.
Can someone in the Governors Office address this issue and explain why that promise made in APA 9 was changed?

Action Plan Amendment 9 Changed without public notice.

Editors Note: I'll need to work with those that feel up to cross posting in all state representatives state government Facebook pages. I'll be pushing toward news and national. I do want feed back on how it reads. If you are a SBA person this is most likely the most important information of your 2016 flood recovery. Please, if you do not understand ask for clarification. You have to understand, everyone recovering from a disaster has to understand this issue on all levels.

Thanks

FAQ No. 157    

Date: 8-9-2019 Updated: 8-9-2019 Subject: Transparency

HUD CDBG-DR offers a program called, "Interim Mortgage Assistance."

Your state Grantee can at anytime after the declared disaster request this program be activated by HUD.

The Interim Mortgage Assistance is designed to help you save money for your repairs by paying for your mortgage during the period of time you can not inhabit your home.

HUD offers up to $3,000 per month for 20 months with a total payout capped at $60,000.

Many state grantees like here in Louisiana will not offer this early in the program from what looks like a fear to pay too much to homeowners assistance. This type of thinking by elected and appointed persons isn't placing the homeowner first in their disaster recovery process.

I am collecting information to present to HUD the issue we face with state grantees not providing this assistance early on in the recovery processes.

I am also collecting this information to present to Louisiana Governor the reason current policy should be at a minimum uncapped and retro to the date the restore program informed the homeowner if any additional repairs are made they will not be eligible for reimbursement. This clearly ended work for many homeowners with mortgage payments.

Policy also doesn't address those that lived with friends and family. Lived on their property in their personal RV's, campers, tents and their vehicles while paying a mortgage payment monthly on a home they could not safely live in.

The documents that I am in search of may have the following:

"By signing below, I/we acknowledge, and certify that I/we have been informed by a representative(s) of the Restore Louisiana Homeowners Assistance Program, that I/we may continue to make repairs to my/our home after the date of this Damage Assessment Inspection; however, any such repairs made after the date of this Damage Assessment Inspection are NOT eligible for reimbursement pursuant to the rules and regulations promulgated by the United States Department of Housing and Urban Development with respect for CDBG-DR grants. I/we acknowledge that, unless and until, any rules that establish the last date, after which, repairs made by me/us to our house ceases to be eligible for reimbursement as set forth in HUD Notice CPD-15-07, Dated 09/15/15, are extended by HUD, any repairs made by me/us after the date hereof will not be eligible for reimbursement under the Restore Louisiana Homeowners Assistance Program."

If you or someone you know was told to stop repairs and could not re-enter their home to live and continued to pay a mortgage please have them contact me using our contact page.

This applies to all states with a federal declared disaster currently working the HUD CDBG-DR grant program.

Research Resource:

• Grantee Damage Assistance and Determination Inspection.
  

FAQ No. 156    

Date: 8-9-2019 Updated: 8-9-2019 Subject: Questions

FAQ No. 155    

Date: 8-6-2019 Updated: 8-6-2019 Subject: RestoreLA

Louisiana Governor Edwards has limited space for Disaster Victims in his political agenda.

July 2018 Edwards increases reimbursement from 50% to 100%, takes little into consideration about homeowners.

Report: "Homeowner Program Reimbursement Expansion Recommendation Conference Call "

Governors Office: We've been running updates on our current numbers and projections regularly in the recent weeks, attempting to project based on historical responses to surveys and new survey respondents leading up to the deadline. We were able to update the numbers today and wanted to provide you with those figures.

We are projecting 10,230 will receive an additional grant through this program change, which will result in around $110 million in additional awards.

This accounts for around 64% of the projected total population (just under 16,000) assisted through this program and around 20% of the total projected dollar value of the awards ($537.2 million) that will be made to homeowners.

Task Force Member: My final question before tomorrows meeting; What encouraged the Governor's team to put the $110 million into additional awards for homeowners as opposed to infrastructure or economic development? I know you may not be able to answer, but I think someone from the Governor's team should be clear in their thinking.

Task Force Member: We know now that we have $1.2 billion coming for flood Risk Reduction Infrastructure Investments, so our need there at this point is less.

I am trying to visualize how well we have done in restoring homes in the state. I live in an area that was not flooded so I have no visual evidence that the storm even occurred based on what I see every day. If I went to the Central area, or to Livingston Parish, or to certain areas in other parishes, would I see evidence of homes that are still in great need of assistance? Are we going to spend all the money we have allocated to homeowners?

State: You would see lots of fully recovered homes, not all of them with our help, and you would also see some homes still not habitable, but not that many, I don't think.

To your second question, we are certainly going to spend it. Whether we spend it on the homeowner program depends in large part on whether we get relief from the SBA DOB problem. If we don't, we'll look to other recovery investments opportunities, likely in infrastructure, rental housing and economic development.

Task Force Member: It does not seem we have spent a lot of the money on homeowners at this time if I am reading the numbers right. Do we have a time table and we have not heard from HUD about the SBA DOB issue? How long do we wait before we start spending on rental housing? It seems that after a number of years, housing needs will not e as crucial, we could reimburse but that is about all.

State: I really appreciate your comments and questions. They're really getting at some of the issues we're struggling with. On the SBA issue, the Governor has said that we have to set a deadline after which work has to move on. That will be likely this fall. (2018)
As for the rental housing, that need is critical and will continue to be so regardless of our efforts, so that is never a bad investment.

NNNNN END REPORT

Resources available:

FAQ No. 154    

Date: 8-5-2019 Updated: 8-5-2019 Subject: Transparency

Town Hall Meeting 6:30 pm Monday 8-5-2019 Public Questions

@ Jones Creek Regional Branch Library
6222 Jones Creek Road, Baton Rouge, Louisiana 70817

1. Can Restore Louisiana hold things you say in a public forum or in a social media group against you and your household?
2. Can the program collect information about you from social media posts and use this information within the program against you or to single you out?
3. OCD-DRU Legal and Management says if they determine you are not cooperative with them, their procedures, policy, or methods they can rescind your grant. So if a homeowner questions authority, the same authority can say the homeowner is not cooperating and terminate the grant, is this correct?
4. Why are the >120 percent AMI groups being penalized and only being offered half of what others are being offered?
5. Why are the >120 percent AMI groups made to wait longer for repayment?
6. Can the >120 percent AMI groups reasonably expect to receive checks to repay SBA Loans?
7. Why don't we go ahead and handle those who took less than offered by the SBA, regardless of AMI?
8. What time period or tax year is the Restore program using to calculation AMI?
9. We have had a loss of income because of the flood and have not returned to our previous adjusted gross income levels. Why is the state using 2015 tax returns instead of our actual tax returns for the 2016 year to calculate AMI?
10. I'm on a fixed income, over 60 years of age and was told to apply for an SBA. Our home was paid off, FEMA promised $33k but only delivered $15k. We had no flood insurance and were basically forced to take the SBA loan. None of this makes sense to me and the Restore Program people are not answer my questions.
    1. What is the actual timelines we should expect to see for SBA repayment checks to arrive?
    2. When will the Restore Program review for additional unmet needs and possible reimbursement for repairs we made out of pocket after the SBA loans are paid in full?
11. The first allocations of CDBG-DR grant funding was focused on homeowners living outside the flood zone, had no flood insurance, over 60 or disabled. Using this same methodology we could say all homeowners who did not live in a flood zone would have SBA repayment 100%. Those who had no flood insurance and lived outside of a flood zone would have 100% repayment. Those over 60 or on fixed incomes or disabled would have their SBA loans paid in full. Then those below 80% would be handled and after that all other groups.
    1. What would keep the state from distributing HUD Grant funds using this method?
    2. If the program funding is the question we can ask the governor to repeal Action Plan Amendment 11 for the $172 million to fund the original SBA issue before funding other programs as the governor promised at the task force meeting in July 2018.
12. Many households who did not take SBA Loans received grant money regardless of AMI. Why is AMI now a factor in Action Plan Amendment 12 when it didn't apply to the households that declined the SBA loans?
13. Can you show us an example on how AMI is calculated?
14. When applying for the hardships, how many of the listed criteria in Action Plan Amendment 12 do you have to meet in order to be eligible for a hardship?
15. Why is AMI even a factor? The flood didn't discriminate.("Repeal and Replace APA 11.")
16. Why did the Restore Program re-open the application process when Governor Edwards increased reimbursements from 50% to 100% adding an estimated 1,200 additional households to the program if he knew the program would be short nearly $110 million to repay SBA loans?
17. Why did the Governor say at the Task Force Meeting in July 2018 that the state would do nothing before HUD Guidance was issued and then have his appointed director and task force say they were looking at closing the program for all solutions in the fall of 2018?
18. If I sell my home today, am I still eligible to receive Restore Funds for my SBA Loan as Solution 3 homeowners who sold their homes and were reimbursed for their repairs?
19. Do I have to stay in my home and wait for the state and HUD to decide if they will offer any SBA repayment money to me or can I sell my home, move on with my life and see a reimbursement check later if the state and HUD rule in my favor?
20. We are below 80% AMI, SBA approved us for $80,000 and we drew down only $50,000 and paid it back already, would the Restore program reimburse us for our $50,000 SBA Loan that we paid off?
    
    Same question but for 80% to 120% AMI using current HUD Guidance as our rule.
    1. We are between 80% and 120% AMI, SBA approved us for $80,000 and we drew down only $50,000 and paid it back already would the Restore program reimburse us for our $50,000 SBA Loan that we paid off?
    2. We are greater than >120% AMI, we only drew down part of our total approved SBA Loan and we paid it off in full. Public Law 115-123 shows we are not to be penalized the difference between what was approved and what we drew down from the SBA ($30k). Will our grant be recalculated to show only the $50k in SBA DOB and will Restore then reimburse us the money we paid out of pocket for all the unmet needs that was over our drawn SBA loan amount?
21. We took only a portion of our SBA loan, $50,000 of the $80,000 approved and since paid back the loan in full with interest from our savings. Under the new Guidance from HUD when we sign the agreement to not draw SBA funds again will the Restore program reimburse us for our personal funds used as repayment to the SBA? Will the Restore program then recalculate additional repairs paid out of pocket and additional unmet needs?
22. If they already have guidelines and approved guidance for SBA, when will disbursements start for people less than 120% AMI and only drew some of the approved loan amount from SBA?
23. Would you explain in detail but also in simple terms why the >120 percent AMI community is last to be reviewed for HUD repayments?
24. Can you also explain in detail but in simple terms why the >120 percent community is only eligible for 50% of their SBA loans?

FAQ No. 153    

Date: 8-5-2019 Updated: 8-5-2019 Subject: Questions