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Update on the FY 2012 CoC Registration Process
August 21, 2012
On July 14, 2012, HUD published the interim rule for the CoC Program on the HUD Homelessness Resource Exchange (HRE). Two weeks later, during the week of July 23, HUD released the Grant Inventory Worksheets (GIW) to Continuums of Care (CoCs), commencing the FY 2012 CoC Program Registration process. CoCs that have not received their GIW should contact their local HUD CPD Field Office immediately to inquire about the status of the worksheet.

The purpose of this message is to provide CoCs and grantees with new information about the CoC Program Registration Process, including the GIW process.
Leasing versus Rental Assistance
Since the release of Grant Inventory Worksheets, many complex questions have been submitted to the HUD HRE Virtual Help Desk (VHD) about transitioning from leasing to rental assistance. Again, HUD expects that the majority of leasing projects will renew without changing to rental assistance. In order to address these detailed questions, HUD is in the process of developing more detailed guidance on the characteristics of the project to help grantees determine whether current SHP projects should renew for leasing funds or rental assistance funds in the FY 2012 CoC Program Competition. This includes reviewing characteristics including whether the client is the tenant on the lease instead of the grantee, whether rent is charged, whether rent is capped at 30% of the family’s adjusted gross income for transitional housing and permanent supportive housing projects, and whether the grantee has a written agreement with the landlord under which the grantee agrees to pay a portion of rent on behalf of the tenant. HUD anticipates this guidance being available by the end of the week. 
In the meantime, below are some points that grantees should consider:
  • Grantees are reminded that the HEARTH Act requires adjustments based on Fair Market Rent (FMR) to rental assistance projects awarded under the CoC Program (as has been the case for Shelter Plus Care projects in the past) as well as for leasing and operating line items. The availability of adjustments should not be a factor when considering whether to apply for leasing or rental assistance.
  • Rental assistance and operating costs cannot be used in the same structure or unit.  See 24 CFR 578.87(c)(5). A grantee that transitions its project’s budget from leasing to rental assistance may not also request operating costs for the project in the FY 2012 CoC Competition.  Grantees should carefully consider this when determining whether to transition from leasing to rental assistance.
  • Transitional and permanent supportive housing projects that request rental assistance must charge rent based on the income of the tenants as set forth in § 578.77.  Leasing projects that do not charge rent in accordance with these standards must remain leasing projects.
  • The CoC regulations, at 24 CFR 578.51(b) require rental assistance to be administered by a State, unit of general purpose local government, or public housing agency.  Nonprofits may not administer rental assistance. Grantees of projects that are transitioning from leasing to rental assistance and that are currently operated by a nonprofit will need to contract with a state, unit of general local government or public housing agency as part of their transition process.
  • The CoC Program requires funds awarded for rental assistance be matched with no less than 25 percent cash or in-kind match by the recipient. Funds awarded for leasing are not required to be matched.
As you consider the clarifications above, it is important to remember, the type of assistance requested on the GIW must reflect the design of the project in place TODAY, as the project is currently operating. This is not an opportunity for grantees to change their program design to request rental assistance funds under the CoC Program. Also, HUD will provide guidance and technical assistance to assist grantees to become fully compliant with the new regulations for leasing and rental assistance.
Clarification on Unified Funding Agencies (UFAs)
In order to be compliant with the McKinney-Vento Act as amended by the HEARTH Act as well as the CoC Program interim rule, the FY 2012 CoC Registration process will include an opportunity for collaborative applicants to submit a request to be designated as a Unified Funding Agency (UFA). The regulatory standards to be designated by HUD as a UFA are necessarily high, and HUD does not expect most communities to be able to meet these standards in FY 2012 - in part because communities have not had sufficient time to implement the new CoC Program Rule. However, HUD strongly encourages communities that intend to seek UFA designation in the future to review the questions included in the 2012 Registration process in order to guide local capacity building activities to prepare for future competitions.
HUD strongly encourages CoCs and grantees to visit the HRE regularly, as new resources are being added often. HUD asks grantees and CoCs to carefully read the materials posted on the HRE for an answer to your question before submitting a question on the VHD to help ease the already high volume of questions in the VHD.
On the HUD HRE, please visit the: Still have a question? Submit policy questions about implementing the CoC Program to the CoC Program Virtual Help Desk. Technical questions about the CoC Competition in e-snaps should be submitted to the e-snaps CoC Competition Virtual Help Desk.

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