Florida Housing is developing a Multifamily Portfolio Preservation Plan. We have acknowledged that we do not have enough finite resources (9% Housing Credits, SAIL or HOME) to assist in preserving every property, and yet most properties will require some level of rehabilitation and recapitalization to ensure they reach their full 50-year affordability period in good condition.

One of the strategies in the draft plan calls for Florida Housing to allow a portion of set-aside units to be increased from 60% of area median income to 80% of AMI at Year 30 to provide property owners with increased income that can then attract private financing for recapitalization.

Before Florida Housing finalizes this strategy, we are seeking information from property owners of 9% Housing Credit developments to help us build an understanding of what the financial situation is likely to be as these properties reach Year 30. As we see it, when these properties approach Year 30, there should be a good amount of accumulated equity that could be paired with 4% Housing Credits and Bonds to provide for a sufficient amount of rehabilitation and recapitalization. We would like to understand why this type of transaction will not work.

To assist us, we request interested owners to provide us with conceptual developments’ cost or rehab proforma, anticipated sources and uses of funds (general) and proforma operating budget with a detailed rent roll, using the following assumptions:

A 6.5%, 35-year amortization;
A 15-year term if need be;
92 cent pricing on the Housing Credits;
A 3.3% rate on the 4% Housing Credits;
$20,000-$25,000 in hard rehabilitation costs;
A 1.20 debt service coverage ratio; and
The estimated fees listed below.

If these assumptions do not make sense in your situation, let us know what you are assuming and why. In order for Florida Housing to review information submitted, ask questions and use these findings to make decisions about this preservation strategy as we head into our late October board meeting, we ask you to submit your information to us no later than Wednesday, October 3rd.

Please submit your information to Laura Cox at laura.cox@floridahousing.org. If you have questions, please submit them to Laura via email. Thank you.

Fees
The following fees are not the fees that will be charged, but are listed below for estimation purposes of completing your pro-forma in the Application. The actual fees will be determined based on the current contract, including any addendum, for services between Florida Housing Finance Corporation and the Credit Underwriter(s) in effect at the time underwriting begins. All Credit Underwriting fees shall be paid by the Applicant prior to the performance of any work by the Credit Underwriter.

a. Initial fee:
(1) Non-Competitive HC only……………. $12,468
(2) MMRB only………………………………… $14,835
(3) MMRB and Non-Competitive HC…. $19,464 *
*The MMRB fee plus the multiple program fee of $4,629 for the Non-Competitive HC.
(4) MMRB Subsidy Layering Review:
(a) If previously underwritten …………. $2,387
(b) If not previously underwritten …… $4,192

b. Re-underwriting fee: $177 per hour, not to exceed $7,841 for MMRB and/or HC.
If a Housing Credit Development involves Scattered Sites of units within a single market area, a single Credit Underwriting fee shall be charged. Any Housing Credit Development requiring further analysis by the Credit Underwriter pursuant to Section 42(m)(2) of the IRC will be subject to an hourly fee of $177.

Administrative Fees:
With respect to the HC Program, each for-profit Applicant shall submit to the Corporation a non-refundable administrative fee in the amount of 9 percent of the annual Housing Credit Allocation amount stated in the Preliminary Determination. The administrative fee shall be 5.5 percent of the stated annual Housing Credit Allocation for Non-Profit Applicants. The administrative fee must be received by the Corporation as stated in the Preliminary Determination. In the event the Final Housing Credit Allocation amount exceeds the annual Housing Credit Allocation amount stated in the Preliminary Determination, the Applicant is responsible for paying the applicable administrative fee on the excess amount before IRS Forms 8609 are issued for the Development.

Compliance Monitoring Fees:
The following fees are not the fees that will be charged, but are listed below for estimation purposes of completing your pro-forma in the Application. The actual fees and percentage increases will be determined based on the current contract, including any addendum, for services between Florida Housing Finance Corporation and the Compliance Monitor(s). Based on the services contract, all compliance monitoring fees (other than those collected for RD Developments) include an automatic annual increase of 3 percent of the prior year’s fee, as described below.
a. HC:
Compliance Monitoring Fee –
All Developments other than RD – The annual fee to be comprised of a base fee of $165 per month + an additional fee per set-aside unit of $10.11 per year, subject to a minimum of $258 per month, and includes an automatic annual increase of 3 percent of the prior year’s fee. Since fees for the full Housing Credit Extended Use Period will be collected at final allocation, the fee amount is discounted at a rate of 2 percent and based upon the payment stream from the Corporation to the monitoring agent.

(2) RD Developments – The annual fee is $450 per year. Since fees for the full Housing Credit Extended Use Period will be collected at final allocation, the fee amount is discounted at a rate of 2 percent and based upon the payment stream from the Corporation to the monitoring agent.
NOTE: Upon prepayment or repayment of the RD loan, the previously identified RD Development will be identified as a non-RD Development and the annual compliance monitoring fee will be adjusted accordingly. The compliance monitoring fee as described in (1) above for the remaining Housing Credit Extended Use Period will be due and payable in full upon billing sent directly to the Development.

b. MMRB (with or without HC) – Annual fee is comprised of a base fee of $165 per month + an additional fee per set-aside unit of $10.11 per year, subject to a minimum of $258 per month, and includes an automatic annual increase of 3 percent of the prior year’s fee. Where a difference exists between set-aside requirements for MMRB and HC, the fees collected will be based upon the higher number of set-aside units.
c. Follow-up Review – $177 per hour.

Tax-Exempt Mortgage Loan Servicing Fees:
a. Annual Permanent Loan Servicing Fees:

The following fee is listed for estimation purposes only; the actual fees will be determined based on the current contract, including any addendum, for services between Florida Housing Finance Corporation and Servicer(s) in effect at the time of loan closing.

• 2.3 bps of the outstanding bond balance annually, subject to a minimum of $212 per month.

b. Construction Loan Servicing Fees:

The following fees are listed for estimation purposes only; the actual fees will be determined based on the current contract, including any addendum, for services between Florida Housing Finance Corporation and Servicer(s) in effect at the time of loan closing.

• $177 per hour for an in-house review of a draw request.
• $177 per hour for on-site inspection fees, up to a maximum of $1,759 per inspection.

Additional legal, cost of issuance, bond underwriting, credit enhancement, liquidity facility and servicing fees associated with the financing shall also be paid by the Applicant.

Additional MMRB Fees:

MMRB Applicants shall be responsible for all MMRB fees as outlined in the loan documents signed by the Applicant and Florida Housing Finance Corporation.

Additional HC Fees:

HC Applicants shall be responsible for all processing fees related to the HC Program