1. Low-Income Housing Tax Credit Section 221(d)(4) Sub Rehab AKA “The Pilot Outside the Pilot” A LOOK TOWARDS THE FUTURE… Prepared by Larry Fergison, Chief of Insured Production Office of Multifamily Development – San Francisco Hub

2. Low-Income Housing Tax Credit Section 221(d)(4) Sub Rehab AKA “The Pilot Outside the Pilot” Key Characteristics: LIHTC Pilot expansion to Sub-Rehabs (over $40K repairs/unit) of existing HUD California properties Project-based rental subsidy/20-yr HAP for initial case(s), with rents approved by HUD AM prior to submission. Open to non-subsidized IF clear advantage vs. market. “Clean” proposals with no/v. minor nuances = “Light Touch” Solid, HUD-experienced Developer, GC, Architect and Relocation consultant for occupied sub-rehab Expedited S. 221d4 SR processing by HUD

3. A New Processing Platform Initially involving multiple HUD disciplines for first few projects, with continual feedback with HUD Mgt and MAP Lender SUW (Val, MC, Rep); Architect (Plans/Specs/Access); AM; Relocation; and OGC Initially use MAP checklists for d4s, with SUW completed Valuation, MC, Rep.

4. Key Processing Considerations All Hands Concept Meeting and Early HUD Asset Mgt Liaison (e.g. 20-yr HAP with apprvd rents and prepay by HUD) is KEY. Direct-to-Firm, with allowance for pre-submittal consultation of certain items such as Historic Preservation (anticipate HUD Val for SHPO in California). Davis-Bacon will apply Intrusive testing a MUST (pest reports, sewer lines, etc) Relocation Consultant and Plan will be needed. HUD Relo Specialist review when Section 8 and/or sensitive nature of relocation (e.g. Seniors/Disabled/Families). Resident perspective. HUD to use highest capacity staff and “hand carry” Get “In Synch”: Lender/Borrower/HUD Production/HUD AM First projects should not have 11 waivers Vet any intergovernmental issues (subordination) early

5. Pathway to New Delivery System Emphasis on testing SUW Model with 221(d)(4) and areas of risk for occupied sub-rehabs initially, possibly NC later Internal HUD Design Council to assess on-going progress and determine which MAP checklist items/application exhibits may be streamlined when risk not adversely impacted and how assignments made Development of HUD Standard Work through Final Endorsement Recommendation to Headquarters after several projects Initially Endorsed, then Finally Endorsed Feedback from clients/partners will inform recommendations

6. A Live Case Study So Far… Old Section 202 for elderly, with some disabled, in Los Angeles Work Share from LA to SF SF Responsibility: SUW(Val, MC, Rep) LA Responsibility: AEC (including const. inspections), Val (as needed, such as SHPO), AM, OGC, Relocation, FHEO AFHMP Hybrid: SUW, with certain HUD Techs