Important Information About HTF Project Commitment and Completion Requirements
HUD’s Office of Affordable Housing Programs (OAHP) is reminding Housing Trust Fund (HTF) grantees about important requirements applicable to the HTF program.
Upcoming Commitment Requirement Deadlines
HUD obligated the first HTF grants in September 2016. The statutory 24-month commitment deadlines for FY 2016 grants are rapidly approaching for most grantees. OAHP recommends that every HTF grantee closely monitor its progress toward its 24-month deadline for committing HTF funds. HUD will use the HTF data in its Integrated Disbursement and Information System (IDIS) to make an initial determination whether a grantee has met its 24-month commitment deadline.
Commitment, as defined in the regulations at 24 CFR 93.2, means the grantee has executed a legally binding written agreement with a recipient under which HTF assistance is to be provided for an identifiable project. Commitments may be entered into IDIS after the grantee executes a legally binging agreement with a recipient for a project. If a grantee fails to meet the commitment requirement by its deadline date, HUD is required by statute to de-obligate the amount of uncommitted funds from the grantee’s HTF Treasury account.
Grantees can use the HTF Deadline Compliance Status Report posted monthly by HUD to determine their deadline date and track progress toward compliance. In addition, authorized IDIS users can run a PR 108 report at any time to ascertain the grantee’s progress toward meeting the deadline for committing its HTF grant.
Project Completion Responsibilities
OAHP also reminds grantees of the importance of timely reporting project completions in IDIS. Once a grantee completes an HTF project, and the project meets the definition of project completion at § 93.2, the grantee must change the status of the activity to “completed” in IDIS. The HTF regulation at § 93.402(d)(1) requires the grantee to complete projects in IDIS within 120 days of the final drawdown of HTF funds for the project. By regulation, an HTF project’s required affordability period does not commence until it is completed in IDIS. Consequently, HTF completion information should be reported as soon a project meets the project completion definition at § 93.2. For HTF rental projects, the grantee may mark the project completed in IDIS before all units are occupied.