RD’s CNA Process - taah.org · • A snapshot in time useful for estimating reserves and a tool...
Transcript of RD’s CNA Process - taah.org · • A snapshot in time useful for estimating reserves and a tool...
RD’s CNA Process
Brian Sutherland Tennessee RD State Engineer \
State Architect\State Environmental Coordinator
CNA Process 2
PLEASE NOTE:
• Outlines current policies and procedures for CNAs in RD’s MFH programs.
• Does not address policies and procedures for the
future HUD/RD CNA e-Tool. We’ll come back to this.
CNA =Capital Needs Assessment
CNA Process 3
WHAT ARE THEY ?
• A snapshot in time useful for estimating reserves and a tool for financial planning.
• A written report that identifies the major repair, replacement, and improvement needs of a
MFH property over a 20-year period.
Capital Needs Assessment
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WHAT ARE THEY NOT : 1. An assessment of ALL costs of ownership over the economic life of the material or system. Doesn’t consider operating costs(Life Cycle Cost Analysis).
2. A comprehensive report on work items and their related costs for a proposed / potential rehabilitation project. (Unit by Unit Inspection)
3. A repair/rehab list
Capital Needs Assessment
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WHEN ARE THEY REQUIRED ?
1. New Construction Loan. 2. Rehabilitation (loan or tax credit funds) 3. Requested Changes to Reserve Requirements 3. Transfer of project ownership. 4. Loan Servicing: a. Loan Re-amortization. b. Loan Write-down. 5. Preservation and Revitalization Program.
Capital Needs Assessment
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WHAT DO THEY INCLUDE ? 1. Description of the property, materials, and
systems. 2. Condition of materials and systems. 3. Accessibility Compliance/Issues. 4. Environmental Compliance/Issues. 5. Repair / Replacement / Improvement Costs. 6. Repair / Replacement / Improvement
Schedule. (IMMEDIATE & LONG TERM)
Capital Needs Assessment
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WHAT IS THEIR PRIMARY PURPOSE ?
• Provide important data for the Underwriting Process
• Useful tool for determining financial needs (reserve analysis)
Capital Needs Assessment
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Step 1: The CNA Contract
(and Addendum) Step 2: The Draft Report Step 3: The Final ( Revised ) Report
The CNA Process – 3 Steps
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1. Owner selects qualified CNA Provider
• Owner may consult with RD
• RD does not maintain a directory of CNA Providers. RD can provide a short list of CNA Providers that have worked in Tennessee.
• RD can provide a copy of the current Unnumbered Letter and Exhibits
The CNA Process – Step 1
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Owner selects a Qualified CNA Provider
• No Identity of Interest w/Owner, Management, Architect, or Contractor. • Trained in Evaluating MFH Properties and Estimating Costs. • Experience w/ RD MFH CNAs. • Knowledgeable of building and codes and accessibility standards and guidelines. • Not debarred or suspended. • Self Certification (part of contract)
The CNA Process – Step 1 Issues
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2. Owner and CNA Provider write agreement. (Usually CNA Provider’s standard contract form.)
3. Contract should include RD CNA
Contract Addendum and RD CNA Statement of Work.
4. Owner sends agreement to
RD . . .
The CNA Process – Step 1
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Contracts w/o the RD Contract Addendum and RD SOW:
• Won’t be accepted because…
• Time always an issue – if Contract Addendum and SOW not provided, then will slow application processing, underwriting, future rehab, etc .
The CNA Process – Step 1
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RD DESIGNATED REVIEWER ?
5. Contract documents reviewed by designated RD CNA Reviewer . . .
• RD engineer, architect or other employee
with similar training & qualifications
• RD’s Review checklist is in current UL, Attachment H
The CNA Process – Step 1
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CNA Provider Services?
Statement of Work (SOW):
•Must be attached •SOW - Latest Edition
The CNA Process – Step 1
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COST ?
A. Fee - average in TN:
• $3000-$3500 • Can sole source if cost doesn’t exceed $3,500 •Must obtain multiple quotes if >$3,500
B. Maximum Initial Payment=50% of total fee
The CNA Process – Step 1
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RD Contract Review and Concurrence:
– Owner and Provider may sign the agreement and Owner forwards by E-Mail to RD Reviewer for Concurrence
– RD concurs or requests changes by E-MAIL NOTIFICATION
– Changes made and returned by E-MAIL for RD Concurrence
– RD concurs and returns signed Agreement to Owner and RD MFH staff by E-MAIL
The CNA Process – Step 1
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A.
1. Owner should give CNA Provider:
A. Access to property and identify contact(s) B. Property information C. Existing reports and plans D. Capital expenditures over last 3-5 years E. Maintenance logs previous 12 months F. Invoices for recently completed capital
improvements G. Current Self Evaluation/Transition Plan H. USDA RD’s latest compliance review I. Scope of work and detailed cost estimate if
a rehab is planned
The CNA Process – Step 2
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2. CNA Provider inspects the property. . .
•Site and all amenities. •Building exteriors. •Interior common areas. •Dwelling units – minimum % per RD’s current UL •Existing reports and plans •Interviews •Environmental: Radon, LBP, ACM, Mold
Inspections: (NOT BY RD)
The CNA Process – Step 2
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•Directly observed or potential hazards? • Non-intrusive “observations”. •Address any EXISTING test results:
-Radon - Lead (LBP Risk Assessment)
- Mold • Make recommendations for further study, if necessary.
Environmental:
The CNA Process – Step 2
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3. CNA Provider writes the report. . .
Immediate Capital Needs:
-Critical Health & Safety items (“year 0”) -Accessibility included in Year 1 (for As-Is
CNAs)
The CNA Process – Step 2
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Immediate Capital Needs:
Critical Health & Safety items (“year 0”) Accessibility: Include in Year 1 if not rehabbing (for
As-Is CNAs)
The CNA Process – Step 2
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• Address ALL applicable codes, standards, and guidelines.
- UFAS/ADAAG/Fair Housing) • Use CURRENT Self Evaluation /
Transition Plan. -If none, use UL Exhibit F Accessibility Checklist • UL Attachment E (applicable
accessibility laws/standards) and Attachment G (accessibility FAQs) provide good information for CNA Providers.
Accessibility:
The CNA Process – Step 2
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• Major System Groups: - Site - Architectural - Mechanical and Electrical - Dwelling Units
Materials and Conditions:
The CNA Process – Step 2
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• ALL Materials:
- Expected Useful Life ( EUL ) - Age - Remaining Useful Life (RUL)
- Condition (EXC, GOOD, FAIR, POOR)
- Action (MAINT, RPR, REPL, CONST, NONE)
Materials and Conditions:
The CNA Process – Step 2
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• IF actions are needed:
- Quantities - Year (s) of Action - Action Duration (minimum 1 year duration required) (spread replacement over time) - NO EXCESSIVE DURATIONS -> 5 years -”cost leveling” - Schedule - Costs
Materials and Conditions:
The CNA Process – Step 2
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WHAT ARE CURRENT DOLLARS ?
• Dollars of purchasing power in which prices TODAY are stated. (UN-INFLATED)
WHAT ARE INFLATED DOLLARS ?
• Dollars of purchasing power in which prices tied to a FUTURE YEAR are calculated.
•Inflation rate is provided by RD – 3 % based on: CPI - Const Costs – Common Practices.
The CNA Process – Step 2
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Inflated Dollars:
$$ ( CURRENT ) x (1 + i) n-1 = $$ ( INFLATED ) i = inflation rate n = reference year
EXAMPLE: What will the inflated value of $1000 be in Year 10 with a 3% inflation rate ?
$1000 x (1 + .03) 10-1 = $1305
The CNA Process – Step 2
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Over The Term Capital Needs:
Non-immediate items:
• 20 year schedule (2015-2034)
• All Items (per annum) > $1,000 (> $250 if project 12 units or less)
• Current $$ Annual Costs (current + inflated $$) (inflation at 3% )
The CNA Process – Step 2
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Executive Summary:
• Immediate Capital Needs, (total costs in current $$) • Capital Needs Over the Term, (total costs in current
$$, CNA template will inflate automatically) • All Capital Needs, total & per unit costs in current
and inflated $$
The CNA Process – Step 2
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Cost Estimates:
• Source of cost data must be identified. (typically RS Means, could be actual costs from property data or rehab contractor)
• Include hard (materials) and soft (labor, overhead, and profit) costs.
(should include demolition, normally does not include design fees)
• Consistent with industry standards.
The CNA Process – Step 2
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• In accordance with Fannie Mae Guidelines
• Electronic • Microsoft Excel Worksheets - RD CNA
Template
WHAT FORM or FORMAT?
The CNA Process – Step 2
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4. CNA Provider sends copy of draft report to Owner for review.
-Excel Format (RD Template) -E-mail transmittal preferred 5. Owner reviews draft CNA and discusses with
CNA Provider to address concerns. 6. CNA Provider revises Draft CNA and
resubmits to Owner for acceptance
The CNA Process – Step 3
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7. OWNER ACCEPTS DRAFT CNA -The CNA report should be accepted by
the property owner BEFORE forwarding to Rural Development.
-RD assumes scope and costs in Draft
CNA Report have been accepted by the Owner
The CNA Process – Step 3 Review
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8. Report reviewed by designated RD CNA reviewer . . .
a. Review checklist is in RD UL b. Review is based on contents of the report. RD
Reviewer visit to the property is not required. Will frequently consult with local RD Area Office MFH Specialists.
c. RD SOW is the acceptance criteria. d. Focus is on significant issues / expenses >$1,000
aggregate per line item. e. Verify adequate sampling: All H/C units, site
improvements, bldg exteriors, public and common areas and facilities, representative attics and crawlspaces, and 50% of dwelling units (45% if 50-99 units, 40% over 100 units)
The CNA Process – Step 3
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Replacement Schedule:
a. Check for obvious errors or omissions.
b. EULs are compared with Fannie Mae. (Justify if not covered by Fannie Mae EUL.)
c. Reasonable timing of multi-year items. No excessive durations or “leveling”
d. Logical grouping or sequence of items. (countertops replaced with / after
kitchen cabinets)
The CNA Process – Step 3 Review
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Costs:
a. Check for obvious errors or omissions.
b. Estimates are compared with R.S. Means.
c. Most calculations are checked.
d. Focus is on items with the largest quantities or costs, and anything that looks “odd”.
The CNA Process – Step 3 Review
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KNOW YOUR “COLORS” ?
-Anytime a cell in the RD CNA template is overwritten, it changes color, to highlight it. -The CNA Reviewer looks at colored cells to
determine “why”, and check for adequate explanation.
Red = math error / overwrite / “Commented”? Lt Blue = user created / overwrite / “Commented”?
The CNA Process – Step 3 Review
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9. RD CNA Reviewer notifies Owner and
CNA Provider of comments, by E-Mail. 10. CNA Provider makes appropriate
changes and sends one copy of revised draft report by E-Mail to RD for review.
11. RD reviews REVISED Draft CNA. . .
The CNA Process – Step 3
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ALL COMMENTS RESOLVED ? ALL issues identified by RD’s Reviewer
must be resolved or addressed and accepted by the designated RD CNA Reviewer.
The CNA Process – Step 3 Issue
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12.Reviewer sends approved As-Is CNA Report to the Owner and RD MFH staff by E-Mail
13.If 3rd-Party Funds (awarded or applied for),
then RD Requests Post-Rehab CNA to be prepared
14. CNA Provider uses approved As-Is CNA,
rehab scope of work, and rehab cost estimate to create draft Post-Rehab CNA
The CNA Process – Step 3 Review
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15.CNA Provider e-mails draft CNA, rehab scope of work, and rehab cost estimate to RD for review
16.Repeat steps 8 through 11 17. Reviewer sends approved Post-Rehab CNA Report
to the Owner and RD MFH staff by E-Mail 18. RD Underwriter transfers data to RD Underwriting
Tool Template
The CNA Process – Step 3 Review
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19. RD Underwriter completes reserve analysis and consults with the RD Reviewer to adjust the “Underwriting CNA,” if needed to cash flow over the 20-year term.
20. The “Underwriting CNA” replaces the
“approved final CNA” as the basis for establishing 20-year reserve requirements.
The CNA Process – Step 3 Review
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MFH CNA e-Tool • 2011 Interagency Rental Policy Working
Group findings and recommendations for aligning CNAs across Federal agencies (HUD, USDA, Treasury/IRS): – Approx 3,000-4,000 CNAs per year in HUD,
USDA, and LIHTC – Agencies have different CNA requirements;
duplicative, conflicting
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MFH CNA e-Tool -Most CNAs submitted as pdfs and paper reports (phone- book size for large properties) -No standard organization or format -Some programs use a spreadsheet, an electric form with limited or no system integration -CNAs are static; Updating is manual -Data storage on desktops or in file drawers -Data retrieval unreliable -No consolidated data for analysis across portfolios, agencies, programs, etc
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MFH CNA e-Tool
• Recommendation to develop a “new, single CNA tool for use by Federal and State agencies that administer housing program(s)…” – CNA to include a traditional, comprehensive
property evaluation, an assessment of green building and energy efficiency needs and opportunities, and a utility benchmarking collection component
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MFH CNA e-Tool
• HUD took the lead to develop the template tool, with significant participation from Rural Development -HUD and RD will adopt the CNA template as the standard required protocol for programs currently utilizing or requiring CNAs -Treasury/IRS will share the CNA protocols and tool as a ’best practice’
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MFH CNA e-Tool
Expected Near-Term Benefits Faster, more accurate CNA preparation and review Underwriting consistency for HUD and RD Improved Accessibility compliance Utility conservation & cost/benefit analytics National standard promotes commercial development of
tools, mobile apps, training, and certifications
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MFH CNA e-Tool
• Target Development Goals -Spreadsheet-based Assessor Tool -Spreadsheet-based Financial Analysis Tool w/ automatic calculation of Financial Schedules -Validation Engine: Automatic identification of flags (protocol violations, errors, and warnings) -Web-based agency review tool for identifying flags and approving Assessments -Standard XML output format to enable consumption by various downstream systems / resources -Interface to/from MFH AUS (CNA Submissions, Flags, Approved Financial Schedules) -Ability to import a standard format As-Is Property Assessment -Capture and retention of approved CNAs for Intelligence/Analytics and downstream systems development.
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MFH CNA e-Tool
• Near-Term Priorities -Seed CNA with interface from REAC (property details and physical inspection scores) -Interface from REAC to CNA Analytics tool -Interface from CNA to REAC -Interface from HUD’s iREMS, FASS, PIC, OAHP, and RD’s MFIS to the e-Tool -Capture and Reflect Reserve Balance from Lenders (for HUD and RD Gtd portfolios) -Extend Business Intelligence/Analytics: actual reserve balance, price trends, useful life trends -Extend Validation Engine (EUL Outliers, Cost Outliers) -Capture and Reflect reimbursements from Lenders- i.e. automate the 9250
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MFH CNA e-Tool
• Expected Long-Term Benefits Comparative analytics, indices to inform users in real
time, more speed, accuracy, consistency Automation of RfR escrow mgmt, funds disbursement,
updating of RfR schedules Risk Management indices for age & physical condition Detailed physical inventory of the portfolio Database analytics and research for policy formation Evaluation of Utility Conservation methods
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MFH CNA e-Tool • HUD Tentative Schedule -HUD going live late November 2014 -Optional use w/ six-month phase in period, and mandatory use afterward • RD Tentative Schedule -12-month development of User Manual, Underwriting Tool, coding and testing, staff training -RD going live October 2015 - Optional use w/ ????-month phase in period, and mandatory use afterward