unit per year requirements should not be raised with CPI in future years. AH We oppose an inflation factor and propose HCD lowers the See response to similar comments above. replacement reserve deposit requirement to match the TCAC standard at $300 per unit per year. SF Please modify the language to clarify that replacement reserves The first sentence has been revised to reflect this possibility. could be funded purely with development sources. NPH HCD should not preclude the possibility that replacement Agree, the revised draft makes it clear that development reserves could be funded from a capitalized replacement source funding alone is a possibility. reserve only. The language should be changed accordingly to allow development sources to fully fund the reserve. Clarify that the difference between the required annual As noted above, HCD believes the calculation should be done deposit and a proposed lesser annual deposit for the first 15 on a case-by-case basis. Since it is basing reserve years may be funded as a capitalized reserve. requirements on a 20-year look, the analysis period should generally be at least this long. Remove the CPI inflator as this strains feasibility. 3) and 4) See responses to similar BH comments, above. For rehabs, base replacement reserve deposit amounts on as-renovated PNA, set prior to the renovation. CE See comment one in above comment. Same response as NPH. NPH’s CHW Same as comment three in above comment. See responses to similar comments above. NPH’s A replacement reserve of $600 per unit is very high and not standard industry practice. Abode The $600 per unit requirement is very high, should match the See responses to similar comments above. CalHFA requirement. Additionally, multiple replacement reserve rules create uncertainty; HCD should delete the .6% formula and the reserve study options. SCANPH
unit per year requirements should not be raised with CPI in future years. AH We oppose an inflation factor and propose HCD lowers the replacement reserve deposit requirement to match the TCAC standard at $300 per unit per year. See response to similar comments above. SF Please modify the language to clarify that replacement reserves could be funded purely with development sources. The first sentence has been revised to reflect this possibility. NPH HCD should not preclude the possibility that replacement reserves could be funded from a capitalized replacement reserve only. The language should be changed accordingly to allow development sources to fully fund the reserve. Clarify that the difference between the required annual deposit and a proposed lesser annual deposit for the first 15 years may be funded as a capitalized reserve. Remove the CPI inflator as this strains feasibility. For rehabs, base replacement reserve deposit amounts on as-renovated PNA, set prior to the renovation. Agree, the revised draft makes it clear that development source funding alone is a possibility. As noted above, HCD believes the calculation should be done on a case-by-case basis. Since it is basing reserve requirements on a 20-year look, the analysis period should generally be at least this long. 3) and 4) See responses to similar BH comments, above. CE See comment one in NPH’s above comment. Same response as NPH. CHW Same as comment three in NPH’s above comment. A replacement reserve of $600 per unit is very high and not standard industry practice. See responses to similar comments above. Abode The $600 per unit requirement is very high, should match the CalHFA requirement. Additionally, multiple replacement reserve rules create uncertainty; HCD should delete the .6% formula and the reserve study options. See responses to similar comments above. SCANPH
summary-and-response-to-comments.docx