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SNAPS Program Responsibility to Comply with the URA Policies Act of 1970Information Bulletin MEMORANDUM FOR: Supportive Housing Program (SHP) and Shelter Plus Care (SPC) Applicants FROM: Robert G. Ilumin, Deputy Director, Office of Community Planning and Development SUBJECT: Reminder of SNAPS Program Responsibility to Comply with the Uniform Relocation and Real Property Acquisition Policies Act of 1970 (URA) Now that the SuperNOFA is upon us it is important to remember that the SHP and SPC grantees must comply with the URA at 49 CFR Part 24. Please review SHP regulations at 24 CFR 583.310, SPC regulations at 24 CFR 582.335 and your application certification. Specifically, the URA applies when an SHP or SPC project involves acquisition, rehabilitation, demolition, project based leasing and/or displacement occurs. If CDBG or HOME funds are used in the project to demolish or convert low income dwellings, compliance with Section 104(d) of the Housing and Community Development Act of 1974 is required. Please review the following URA requirements as they apply during and after the SuperNofa application. The URA has two requirements, one for property acquisition and one for relocation. All property acquisitions must comply with the URA. Relocation is triggered when occupants are displaced. Most McKinney Act projects cause permanent displacement because existing occupants do not meet the McKinney Act homeless definition and are not at risk of being homeless because of their URA protections. A few projects that have other funds to house non homeless persons may cause temporary displacement during rehabilitation. I. Super NOFA Application A. Acquisition Review these two URA acquisition requirements before submitting your application:
B. Relocation For new projects the application requires that, if any of the buildings are occupied, you describe the planned relocation effort including the role of the applicant, sponsor and other project partners in the relocation and the estimated timeframe for completing development.
II. Technical Submission The following information will be required at the technical submission phase, either for the original location or an alternate location if there has been a change. A new location will necessitate a whole new review of acquisition and relocation requirements. A. Acquisition Be prepared to submit a copy of voluntary letter to the seller, proof of the property's value, the purchase agreement and proof of the purchase. The purchase price, as evidenced by a purchase agreement, must be consistent with the amount on the voluntary letter and the evidence of value. B. Relocation
III. Implementation A. Track Occupants Track the status of all persons on the site at the time of application, at contract execution and upon project completion. Document notices they received and the reason they left; otherwise re-contact may be necessary and relocation liability may increase. B. Notices By implementation all notices should have already been sent. If the HUD contract has already been signed do not send out a General Information Notice. Send either a Notice of Eligibility or a Non Displacement, whichever fits the situation. See Section II (B) (3) on the previous page. C. Comparable Housing Displaced persons must move into comparable housing that is documented to be decent, safe and sanitary that is housing that meets local housing and occupancy codes. Comparable housing must have features similar to the displacement housing. Comparable replacement housing for transitional housing is similar housing (apartment, group home, dormitory). It may or may not require cash payments. See 24 CFR 24.2 (a) (6) and (8). C. Required Relocation Assistance Provide all required relocation assistance (i.e., advisory assistance, moving assistance, residential and business relocation payments). Certification of legal residency in the U.S. is required for URA assistance. There are exceptions for health, safety and family unity. See 49 CFR 24.208. D. Documentation Document the acquisition with offer letters, purchase agreements, the escrow settlement, title transfer, proof of payment and proof of property value. Document relocation with: copies of all notices and proof of receipt, a record of advisory services, claims for moving and relocation assistance, proof of payments, support for claims (rent, utilities, income), proof of comparable housing, decent, safe and sanitary inspections, special determinations, etc. E. Management Oversight You are responsible for overseeing the relocation at all stages of the project i.e., planning, noticing, implementation, claims, payments, close-out etc. A relocation consultant may carry out the relocation but you should supervise it. If HOME or CDBG funds are involved coordinate the relocation with the HUD grantee, Participating City (PJ) or Public Housing Authority. If you have questions about this information bulletin please contact Ms. Jana Bickel, HUD Relocation Specialist at (213) 534-2581. Please note that requirements have been summarized. Always review the regulations in detail to ensure compliance. ### |
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Content Archived: January 27, 2015 | |
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