HomeMy WebLinkAboutR34-Economic Development
-~~
CITY OF SAN BERNARDINO
ECONOMIC DEVELOPMENT AGENCY
OR,II-- \1'\L
,.~ '\! f
\ I V I ~r
FROM: Emil A. Marzullo
Interim Executive Director
SUBJECT:
Public Hearing to Amend the Consolidated'
Annual Action Plan for Fiscal Year 2008-2009
to Effectuate a Supplemental Appropriation
under the Neighborhood Stabilization Program
Authorized under the Housing and Economic
Recovery Act of 2008
DATE: November 7, 2008
Svnopsis of Previous Commission/Council/Committee Action(s):
At a special meeting of the Redevelopment Committee on October 28, 2008, the Redevelopment committee recommended the
consideration by the Mayor and Common Council of the Substantial Amendment to the Consolidated Annual Action Plan for
Fiscal Year 2008-2009 and submittal to the U.S. Department of Housing and Urban Development by December 1,2008 for the
supplemental appropriation of Community Development Block Grant (CDBG) funds pursuant to the Neighborhood
Stabilization Program (NSP) authorized under the Housing and Economic Recovery Act of 2008.
Recommended Motion(s):
Open/Close Public Hearing
(Mavor and Common Council)
Resolution of the Mayor and Common Council of the City of San Bernardino, California, approving a
Substantial Amendment to the Consolidated Annual Action Plan for Fiscal Year 2008-2009; and authorizing the
City Manager or is designee to execute, on behalf of the City, such documents as requested by the United States
Department of Housing and Urban Development to effectuate the Supplemental Appropriation
Contact Person(s): Carey K. Jenkins Phone: (909) 663-1044
Project Area(s): N/A Ward(s): All
Supporting Data Attached:
[;'I Staff Report [;'I Resolution(s) 0 Agreement(s)/Contract(s) [;'I Map(s) 0 Letter(s)
Budget Authority:
NIA
NIA
FUNDING REQUIREMENTS:
Amount: $
-0-
Source:
Signature:
Emi
Fiscal Review:
6u Ccuc, ~--!;J$< If
Barbara Lindseth, Administrative Services Director
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P:\AgendasIComm Dev CommissionlCDC 2008\11-17-08 Neighborhood Stabilization Program SRdoc
COMMISSION MEETING AGENDA
Meeting Date: 11/17/2008
Agenda Item Number: ~ 3'1
ECONOMIC DEVELOPMENT AGENCY
STAFF REPORT
------------------------------------------------------ ---------------------------- -------------------------------- ------------------------------ ------------------------------ ----------------------
NEIGHBORHOOD STABILIZATION PROGRAM AUTHORIZED UNDER THE
HOUSING AND ECONOMIC RECOVERY ACT OF 2008
BACKGROUND:
In response to the national rise in subprime mortgage foreclosures and the significant costs that
foreclosures impose on local municipalities and their homeowners, Congress authorized $3.92 billion of
emergency assistance for the redevelopment of abandoned and foreclosed upon homes under Title III of
the Housing and Economic Recovery Act of 2008 ("HERA"). The funds are administered by the U.S.
Department of Housing and Urban Development ("HUD") under a new entitlement grant program
announced on October 6,2008, and referred to as the Neighborhood Stabilization Program ("NSP").
NSP funds are to be used specifically for the acquisition and rehabilitation of foreclosed upon and
abandoned residential properties. Allocations were made by HUD consistent with HERA, which calls for
allocating funds to states and units of general local goverrunent with the greatest need based on: (I) the
number and percentage of home foreclosures; (2) the number and percentage of homes financed by
subprime mortgage related loans; and (3) the number and percentage of homes in default and/or
delinquency. The State of California was allocated approximately $145 million under the NSP, and units
of general local government throughout the state were allocated between $2.1 million (Alameda County)
and $48.5 million (County of Riverside). Foreclosure rates in the state range from a low of 4% in the City
of San Jose and Orange County, to a high of 12.3% in the City of Stockton. As for the City of San
Bernardino ("San Bernardino" or "City"), it ranks second among municipalities with an 11.8%
foreclosure rate.
HUD treats NSP funds as a supplemental appropnatlOn of Community Development Block Grant
("CDBG") funds for fiscal year 2008-2009. Under the CDBG program, a supplemental appropriation for
activities not budgeted in the current annual action plan requires a substantial amendment to the action
plan. Therefore, to receive the funds the City is required to submit to HUD a Substantial Amendment to
the Consolidated Annual Action Plan for Fiscal Year 2008-2009 ("Substantial Amendment"). To
expedite the distribution of these funds, HUD requires that NSP grantees submit their substantial
amendments by December I, 2008, or risk the loss and reallocation of the grant. To facilitate this
requirement, HUD has provided alternative requirements to 42 U.S.C. 5304(a)(2) waiving the provisions
of Sections 91.105(k) and 91.1150), thereby condensing the citizen comment period to 15 calendar days
from the standard 30 calendar days.
For the most part, the statutory and regulatory provisions that govern the CDBG program apply to the use
of NSP funds. The most significant differences pertain to the definition of "Iow- and moderate-income"
and national objective. Under the NSP, the CDBG definition of "Iow- and moderate-income" is
superseded by provisions that allow households whose incomes do not exceed 120% of the Average
Median Income (AMI) to qualifY as if their incomes did not exceed the published low- and moderate-
income levels of the regular CDBG program. In addition, of the three national objectives authorized
under the CDBG program, only the use of the low- and moderate-income national objective is permissible
under the NSP. NSP funds may not be used to address blight or an urgent community need as regulatory
P:\Agendas\Comm Dev Commission\CDC 2008\11_17_08 Neighborhood Stabilization Program SRdoc
COMMISSION MEETING AGENDA
Meeting Date: 11/17/2008
Agenda Item Number: R ":>'f_
Economic Development Agency Staff Report
Neighborhood Stabilization Program
Page 2
provisions of the CDBO program permit. Further, NSP activities must constitute both an eligible use
under HERA and correlate with an eligible activity under CDBO as follows:
Eligible uses pursuaut to HERA iuclude: Correlated CDBG eligible activity:
(1) Establishment of financing mechanisms for the . As part of an activity delivery cost for an eligible
purchase and redevelopment of foreclosed upon activity.
homes and residential properties, including such . For eligible activities to the extent financing
mechanisms as soft-seconds, loan loss reserves, and mechanisms are used to carry them out.
shared-equity loans for low- and moderate-income
homebuyers;
(2) Purchase and rehabilitate homes and residential . Acquisition of real property.
properties that have been abandoned or foreclosed . Disposition of real property.
upon, in order to sell, rent or redevelop such homes . Relocation assistance for permanently or temporarily
and properties; relocated individuals or families.
. Direct homeownership assistance for households not
exceeding 120% of the AMI.
. Rehabilitation of residential properties.
. Housing counseling for parties taking part in
rehabilitation and oreservation activities.
(3) Establish land banks for homes that have been . Acquisition.
foreclosed upon; . Disposition.
(4) Demolish blighted structures; and . Clearance ofblil!hted structures.
(5) Redevelop demolished or vacant properties. . Acquisition.
. Disposition.
. Public facilities and improvements.
. Housing counseling for buyers ofNSP assisted
properties.
. Relocation.
Current Issue:
The City of San Bernardino was allocated $8.4 million under the NSP. On October 28, 2008, the City of
San Bernardino Redevelopment Committee authorized Agency Staff to take the necessary actions to
submit a Substantial Amendment to HUD by December 1,2008, in order to receive the funds.
Agency Staff began the IS-day citizen comment review period on the Substantial Amendment on October
31, 2008. On this date, a notice of public hearing was published in the San Bernardino County Sun
newspaper. In addition, copies of the proposed Substantial Amendment were distributed throughout the
City and posted on the City of San Bernardino Economic Development Agency website. The public
review comment period ends on November 17, 2008, with this scheduled public hearing. The current
schedule both preserves reasonable citizen participation as required by HUD and allows Agency Staff
sufficient time to finalize the Substantial Amendment with the inclusion of public comments and other
revisions as may be necessary for a timely submission.
P:\Agendas\Comm Dev Comm;ssion\CDC 2008\1 ].17-08 Neighborhood Stabilization Program SRdoc
COMMISSION MEETING AGENDA
Meeting Date: 11/17/2008
Agenda Item Number: ~ ~~
Economic Development Agency Staff Report
Neighborhood Stabilization Program
Page 3
The primary elements that make up the Substantial Amendment (attached as Exhibit I) include a needs
analysis, and the proposed distribution and use of funds. HUD's data indicates the foreclosure rate in San
Bernardino is 11.8%, the second highest rate among municipalities within California. The data is based
on the following: (I) the change in home values as of June 2008 compared to 2000; (2) the percentage of
high cost (or subprime) mortgage loans made between 2004 and 2006; and (3) the unemployment rate as
of June 2008. Additional data provided by RealtyTrac, an Irvine based company that tracks foreclosures
nationwide and which many local municipalities are using for purposes of the NSP, indicates there are
currently over 3,500 foreclosed upon homes in San Bernardino. RealtyTrac was able to provide Agency
Staff with Assessor Parcel Numbers (APNs) for 3,109 of these properties. Of this number, Agency Staff
was able to identify and plot 2,264 foreclosed upon properties within City boundaries. Based on this
more conservative figure of 2,264, the percentage of homes that have been foreclosed upon ranges from a
low of 8.1 % in Ward 3 to a high of 21.3% in Ward 2. The first column of Table 1 below and the map
designated Exhibit 2 show the distribution of foreclosures throughout the City on a ward-by-ward basis.
Further analysis of HUD's data at the tract and block group level reveals a clearer assessment of the
foreclosure crisis within the City. Table I shows the rate of subprime mortgages within the City averages
42.7%. This varies by ward from an average low of 34.1% in Ward 5 to a high of 51.6% in Ward 2.
However, the percentage of subprime mortgage loans ranges from a low of 16.8% in Ward 4 to a high of
59% in Ward I. The projected rate of foreclosures within the next 18 months averages 11.7% throughout
the City, and averages between a low of 10.4% in Ward 5 to a high of 13.2% in Ward 2. And, again, in
some areas of the City, the projection can be much higher as in Ward I where the projected foreclosure
rate is as high as 14.4%. For the City overall, HUD's foreclosure and abandonment risk is high.
Table 1
Percentage of
Forecloeed
Homes by
Ward'
Ward
13.8%
21.3%
2
8.1%
3
9.5%
4
15.7%
5
15.5%
1>
16.1%
7
Avarage
Range
Average
Range
Average
Range
Average
Range
Ave"""
Range
Average
Range
Average
Range
Average
Range
i'~ ...
\lI_.
__I
Subprlrne Mortgages
(% of Homes)'
51.3%
34.8% - 59.0%
51.6%
45.4% - 56.6%
39.9%
25% - 51.7%
34.9%
16.6%-45.9%
34.1%
22.5% - 39.2%
43.5%
22.6% . 55.1%
42.9%
35.9% - 49.4%
Foreclosure .
Abandonment Risk
(Scale 1.10,
10=worst)
10
8.10
10
9.10
9
8 -10
8
4-10
9
8-9
9
8.10
9
9 -10
18-Month Projected
F'-:lQsure Ai!te
(% of homes)
13.1%
10.5% -14.4%
13,2%
12.2% .14%
11.3%
8.9% -13.2%
10.5%
7~6%. 12.4%
10.4%
8.5% -11.2%
11.6%
8.5% -13.7%
11.8%
10.7% -12.8%
I Generated by the City of San Bernardino Geographic Information System based on 2,264 units identified by RealtyTrac as of 11/0512008.
2 HUD User Data for NSP by census tract was aggregated for each Ward.
3 Based on HUD User Data used to make NSP allocations.
------------------~------------------------------------------------------------~---------------------------------------------------------------------------------------------------------------------
P:\Agendas\CommDev Commission\CDC 2008\11-17-08 Neighborhood Stabilization Program SRdoc
COMMISSION MEETING AGENDA
Meeting Date: 11/17/2008
Agenda Item Number: f'l. 'Y-t
Economic Development Agency Staff Report
Neighborhood Stabilization Program
Page 4
Based on the data, Agency Staff concludes that the overwhelming majority of the City has been adversely
impacted by the current foreclosure crisis, and recommends that NSP funds be distributed on a citywide
basis through the following four (4) distinct programs:
1. Down Payment Assistance: This program sets aside $920,000 of NSP funds for use as a
financing mechanism to ensure affordability for individuals and households purchasing NSP
assisted residential properties. Assistance will be provided in the form of down payment
assistance to households whose incomes do not exceed 120% of the AMI. It is estimated that
structuring the use of the NSP funds in this manner will be leveraged with an additional amount
equal to approximately $4,600,000 in private first trust deed funds.
2. Housing Opportunities for Households at 50% of the AMI: This program allocates $2, I 00,000
of NSP funds to the Notice of Funding Availability ("NOF A") recently issued by the Agency for
the provision of affordable housing. This complies with the NSP requirement that at least 25% of
the grant, in this case $2, I 00,000, be allocated to address the housing needs of individuals and
households whose income does not exceed 50% of the AMI and maximizes the projected benefit
of the NOF A. It is anticipated that the NSP funds for this component will be leveraged by an
additional amount upwards of $1 0,500,000 in private capital.
3. Acquisition, Rehabilitation and Resale: This program allocates $3,700,000 of NSP funds for
the acquisition and rehabilitation of single-family homes through participating intermediaries,
such as builder/developer contractors. These intermediaries will be retained through a Request for
Production/Qualifications ("RFP") process and will be vetted by Agency Staff with
recommendations submitted to the Council. The RFP process will begin in January of 2009. It is
anticipated that the NSP funds allocated under this component will attract an additional
$18,500,000 in private first trust deed capital. Upon rehabilitation, the homes will be made
available for purchase to qualifying households whose incomes do not exceed 120% of the AMI.
4. Acquisition, Demolition and Redevelopment: This program is designed to address abandoned or
foreclosed upon residential units in physical conditions too costly for rehabilitation. With a
budget of $920,000, this program will allow for the acquisition, demolition and future
redevelopment of the site. Agency Staff anticipates these program funds will be leveraged with an
additional amount equal to approximately $4,600,000 in private development capital for future
infill developments on these various sites.
In addition to direct program activities, the NSP allows an administrative fee not to exceed 10% of the
grant. The Agency recommends allocating not to exceed $800,000 for the duration of the program to pay
staff salaries, program consultants, appraisal, environmental review, support staff, equipment and
supplies. The effectiveness for the program will extend through June 30, 2013.
Environmental Impact:
The programs and activities proposed under the NSP are not expected to constitute a significant
environmental impact.
P:\Agendas\Comm Dev Commission\CDC 2008\11-17-08 Neighborhood Stabilization Program SR. doc
COMMISSION MEETING AGENDA
Meeting Date: 11117/2008
Agenda Item Number: R:;Lt
Economic Development Agency Staff Report
Neighborhood Stabilization Program
Page 5
Fiscal Impact:
There is no adverse fiscal impact to the City General Fund or to Agency financial resources. Timely
submission of the Substantial Amendment and its subsequent approval by HUD will generate $8.4 million
in NSP CDBG program funds, and will be potentially leveraged with an additional $38,000,000 in private
capital investment.
Recommendation:
That the Mayor and Common Council adopt the attached Resolution.
12L
Emil A. Marzullo, Interim
P:\Agendas\Comm Dev Commission\CDC 2008\11-17-08 Neighborhood Stabilization Program SRdoc
COMMISSION MEETING AGENDA
Meeting Date: 11/17/2008
Agenda Item Number: (l. ~t.t
EXHIBIT 1
CITY OF SAN BERNARDINO
Neighborhood Stabilization Program
Substantial Amendment to the
Fiscal Year 2008-2009 Action Plan
November 17,2008
P:\AgendaslAgenda AttachmentslElIhibitsl20081\ 1-17-08 Neighborhood Stabilization Program (Exhibit I)_doc
EXHIBIT 1
City of San Bernardino
Neighborhood Stabilization Program
Substantial Amendment to the Fiscal Year 2008-2009 Action Plan
Table of Contents
Introduction...... ...... ...... ... ... ...... ... ...... ...... ... ... ... ...... ............... ............ ...... ...... .....3
A. Areas of Greatest Need...... ... ...... ...... ............ .................. ...... ...... ................4
B. Distribution and Uses of Funds... ... ...... ...... ...... ... ............... ...... ......... ......... ..5
C. Definitions and Descriptions............ ... ... ... ... ... ... ... ... ...... ...... ...... ......... ... .... ..7
D. Low Income Targeting............ ...... ............ ......... ... ...... ............ ...... ............ ..8
E. Acquisitions & Relocation......... ...... ...... ...... ... ......... ...... ... ......... ... ................. 8
F. Public Comment............... ...... ... ............ ...... ......... ...... ...... .................. ... ...9
Activities
(1) Down Payment Assistance ... ...... ... ...... ...... ...... ... ...... .................. ...... ... ..... 10
(2) Housing Opportunities for Households At or Below 50% AMI............... ...... ...... .12
(3) Acquisition, Rehabilitation and Resale ...... ............... ...... ...... ...... ............ ..... 13
(4) Acquisition, Demolition and Redevelopment... ...... ... ... ...... ......... ... ............... ..14
(5) Administration... ... ... ...... ............... ...... ...... ... ...... ... ...... ............ ...................15
2
P:\Agendas\Agenda AttachmentslExhibitsl2008\] 1-17-08 Neighborhood Stabilization Program (Exhibit I) doc
EXHIBIT 1
City of San Bernardino
Neighborhood Stabilization Program
Substantial Amendment to the Fiscal Year 2008-2009 Action Plan
City of San Bernardino
NSP Contact
Carey K. Jenkins, Director of Housing and Community Development
San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401
Tel: (909) 663-1044. Fax: (909) 888-9413
Email: cjenkins@sbrda.org
www.sbrda.org
INTRODUCTION
In response to the national rise in subprime mortgage foreclosures and the significant costs that
foreclosures impose on local municipalities and neighboring homeowners, Congress authorized
$3.92 billion for the redevelopment of abandoned and foreclosed homes and residential
properties under Title III of the Housing and Economic recovery Act of 2008 (HERA). The funds
are administered by the United States Department Housing and Urban Development (HUD)
under a new entitlement grant program referred to as the Neighborhood Stabilization Program
(NSP).
Under the NSP, the City of San Bernardino ("San Bernardino" or "City") was allocated $8.4
million. Allocations were made by HUD based on qualifying grantees' (1) number of and
percentage of home foreclosures, (2) number of and percentage of homes financed by a
subprime mortgage related loan, and (3) number of and percentage of homes in default or
delinquency. For San Bernardino, HUD determined the City has a local foreclosure rate of
11.8%, the second highest rate among general local governments in California. The percentage
of homeowners holding subprime mortgage loans within the city ranges between 16.8% and
59% with an overall average of 42.7%, and the percentage of homes at risk of foreclosure
ranges between 7.6% and 14.4% with an overall average for the City of 11.7%.
To receive NSP funding, San Bernardino is required to submit to HUD a Substantial
Amendment to the Consolidated Annual Action Plan for Fiscal Year 2008-2009 ("Substantial
Amendment") by December 1, 2008. This Substantial Amendment is required because NSP
grants are treated as a supplemental appropriation of CDBG funds for the undertaking of
activities that were not budgeted in the current year Action Plan.
The Substantial Amendment includes a needs analysis identifying the geographic areas of
greatest need within the City, and the proposed distribution and use of NSP funds. Sources of
information used include data derived and employed by HUD to determine its needs
3
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EXHIBIT 1
assessment in allocating NSP funds, 2006 U.S. Census information, foreclosure information
provided by RealtyTrac, and internal GIS data.
A.AREASOFGREA~STNEED
One of the most dramatic changes in financial services over the last few years has been the
expansion of mortgage products. In addition to the conventional fixed-rate 30-year loan, lenders
now offer a number of other mortgage products such as "interest-only" mortgages that allow a
borrower to pay only the interest for the first few years of the loan and "payment option"
adjustable-rate mortgages (ARMs) that include flexible payment options for the borrower.
These types of mortgages are often combined with second-lien mortgages and allow reduced
documentation of creditworthiness. In 2006, these so called "nontraditional" mortgages
accounted for more than one-third of all mortgage loans compared to 2% six years earlier.
While these mortgage products can benefit some consumers, data shows that these loans are
usually marketed to less sophisticated buyers or those who may not otherwise qualify for more
traditional mortgage loans. These loans eventually become unaffordable to the consumer and
result in default and foreclosure.
Between 1994 and 2006 the annual dollar volume of subprime loans issued across the United
States grew from $35 billion to more than $600 billion, and their share of home loan originations
increased from 4.5% to 20% (Inside Mortgage Finance, 2007)1. In 2006 the Federal Reserve
Board found that in minority areas approximately 46.6% of the home loans issued were high-
priced or sub-prime loans compared to 21.7% in non-minority communities. In San Bernardino,
with a minority population of 57.5%2, approximately 42.7% of existing home mortgage loans are
high-cost loans according to HUD's data. However, the rate is as high as 59% in certain areas
of the City.
HUD data indicates the foreclosure rate in the City of San Bernardino is 11.8%; it is the second
highest rate among municipalities within California. The data is based on the following: (1) the
change in home values as of June 2008 compared to 2000; (2) the percentage of high cost (or
subprime) mortgage loans made between 2004 and 2006; and (3) the unemployment rate as of
June 2008.
Additional data provided by RealtyTrac, an Irvine based company that tracks foreclosures
nationwide, indicates there are currently over 3,500 foreclosed upon homes in San Bernardino.
RealtyTrac was able to provide Assessor Parcel Numbers (APNs) for 3,109 of these properties.
Of this number, 2,264 foreclosed upon properties were identified and plotted within City
boundaries. Based on this more conservative figure of 2,264, the percentage of homes that
have been foreclosed upon ranges from a low of 8.1 % in Ward 3 to a high of 21.3% in Ward 2.
The first column of Table 1 and the map designated Exhibit 1 show the distribution of
foreclosures throughout the City on a ward-by-ward basis.
Further analysis of HUD's data at the tract and block group level reveals a clearer assessment
of the foreclosure crisis within the City. Table 1 shows the rate of subprime mortgages within
the City averages 42.7%. This varies by ward from an average low of 34.1 % in Ward 5 to a
high of 51.6% in Ward 2. However, the percentage of subprime mortgage loans ranges from a
1
Referenced by Chairman Ben S. Bernanke in his speech at the National Community Reinvestment Coalition Annual Meeting,
Washington, D.C, 3/14/2008.
2 U.S. Census Bureau, 2006 American Community Survey.
4
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EXHIBIT 1
low of 16.8% in Ward 4 to a high of 59% in Ward 1. The projected rate of foreclosures within
the next 18 months averages 11.7% throughout the City, and averages between a low of 10.4%
in Ward 5 to a high of 13.2% in Ward 2. And, again, in some areas of the City, the projection
can be much higher as in Ward 1 where the projected foreclosure rate is as high as 14.4%. For
the City overall, HUD's foreclosure and abandonment risk is high.
Table 1
Percentage of Average Foreclosure . 18-Month Projected
Foreclosed Subprlme Mortgages Abandonment Risk
Homes by Ward (% of Homes)' (Scale 1-10, Foreclosure Rate
Ward3 Range 10=worst) (% of homes)
Average 51.3% 10 13.1%
13.8% 1
Range 34.8% . 59.0% 8 -10 10.5% -14.4%
21.3% Average 51.6% 10 13.2%
2
Range 45.4% . 56.6% 9 -10 12.2% -14%
Average 39.9% 9 11.3%
8.1% 3
Range 25% - 51.7% 8 -10 8.9% - 13.2%
9.5% Average 34.9% 8 10.5%
4
Range 16.8% - 46.9% 4-10 7.6% -12.4%
15.7% 5 Average 34.1% 9 10.4%
Range 22.5% - 39.2% 8-9 8.5% -11.2%
Average 43.5% 9 11.8%
15.5% 6
Range 22.5% - 55.1 % 8 -10 8.5% -13.7%
16.1% Average 42.9% 9 11.8%
7
Range 35.9% - 49.4% 9 -10 10.7% -12.8%
11.8%' Average 42.7% 9 11.7%
Citywide
Range 16.8% - 59% 4 -10 7.6% -14.4%
B. DISTRIBUTION AND USES OF FUNDS
The data collected thus far clearly indicates the foreclosure crisis is occurring in practically every
residential neighborhood within San Bernardino. Grantee, therefore, recommends that NSP
funds be made available on a citywide basis, and has identified five (5) separate programs with
which to deploy the grant that include the following:
1. Down Payment Assistance: This program sets aside $920,000 of NSP funds for use as a
financing mechanism to ensure affordability for individuals and families purchasing NSP
assisted residential properties. Assistance will be provided in the form of down payment
assistance to individuals and families whose household income does not exceed 120% of
the AMI. It is estimated that structuring the use of the NSP funds in this manner will be
leveraged with an additional amount equal to approximately $4,600,000 in private first trust
deed funds.
Presently, Grantee provides up to 20% of the acquisition cost of a single family home to first
time home buyers whose household income does not exceed 120% of the AMI. Funds for
the existing program are currently derived from Redevelopment Agency housing set aside
3 Generated by the City of San Bernardino Geographic Information System based on 2,264 units identified by RealtyTrac as of 11/05/2008.
4 HUD User Data for NSP by census tract was aggregated for each Ward.
5 Based on HUD User Data used to make NSP allocations.
5
PlAgendaslAgenda Attachmenls\Exhibits\2008\11-17-08 Neighborhood Stabilization Program (Exhibit I),doc
EXHIBIT 1
dollars. The program would be augmented by incorporating NSP funds into the down
payment (up to 50% of the needed subsidy) and the requirement for a first time home buyer
would be waived. The Redevelopment Agency's standard 45-year affordability covenant
would apply.
2. Housing Opportunities for Households at or below 50% AMI: This program allocates
$2,100,000 of NSP funds to the Notice of Funding Availability (NOFA) recently issued by the
Agency for the provision of affordable housing. This complies with the NSP requirement
that at least 25% of the grant, in this case $2,100,000, be allocated to address the housing
needs of individuals and households whose income does not exceed 50% of the AMI and
maximizes the projected benefit of the NOFA. It is anticipated that the NSP funds for this
component will be leveraged by an additional amount upwards of $10,500,000 in private
capital.
The recently released NOFA invites the development community to, among other things,
identify specific multifamily housing projects with a history of public service calls,
documented conditions associated with poor management and those sites that are generally
considered a blighting influence on the surrounding community. Developers submitting
projects with these specifications would have the opportunity to compete for a portion of
Grantee funds to acquire, rehabilitate and manage such properties under a new professional
management agreement. In response to the NSP, the Grantee also added the opportunity
for the development community to compete for these funds to acquire and rehabilitate
similar properties provided they had been foreclosed upon or abandoned under the
definitions identified in Section II A of HERA and would be purchased at discount of between
5% and 15% of appraised value.
3. Acquisition, Rehabilitation and Resale: This program allocates $3,700,000 of NSP funds
for the acquisition and rehabilitation of single-family homes through participating
intermediaries, such as builder/developer contractors. These intermediaries will be retained
through a Request for Production/Qualifications (RFP) process and will be vetted by Agency
staff with recommendations submitted to the Council. The RFP process will begin in
January of 2009. It is anticipated that the NSP funds allocated under this component will
attract an additional $18,500,000 in private first trust deed capital. Upon rehabilitation, the
homes will be made available for purchase to qualifying households whose incomes do not
exceed 120% of the AMI.
Key qualifying points of the RFP would include, but not be limited to: (1) experience in the
last five years of rehabilitating single family housing structures; (2) reference letters from as
many as three separate municipal jurisdictions attesting to the amount and quality of
rehabilitation work completed; and (3) demonstrated ability to provide the financial resources
to rehabilitate multiple properties simultaneously with the expectation of reimbursement
upon close of escrow. All requirements including, but not limited to, those associated with
the 120% the AMI ceiling and the purchase discount would be maintained for each
acquisition.
4. Acquisition, Demolition and Redevelopment: This program is designed to address
abandoned or foreclosed upon residential units in physical conditions too costly for
rehabilitation. With a budget of $920,000, this program will allow for the acquisition,
demolition and future redevelopment of the site. Grantee anticipates these program funds
will be leveraged with an additional amount equal to approximately $4,600,000 in private
development capital for future infill developments on these various sites.
6
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EXHIBIT 1
Grantee would consult with the City's Building Official regarding the structural soundness of
the property and, if deemed appropriate, demolition would occur. Plans to develop the
parcel as an in-fill unit or units would commence as soon as the local housing market begins
to stabilize. Several redevelopment options would be considered. One option would be to
redevelop the site utilizing modular housing thus ensuring quality building products and a
rapid turn around. Other options might include selling the parcel to a non-profit such as
Habitat for Humanity for a reduced price to help subsidize their next new construction
project or another non-profit expert in special needs housing.
5. Administration: Administration of the program will not exceed 10% of the NSP grant and
10% of program income.
It is the expectation of Grantee to team up with other local jurisdictions that have been awarded
NSP funds to collaborate on such program components as jointly paying for home buyer
education courses, conducting joint procurement activities with regards to identifying and
contracting with builder/developer intermediaries and negotiating bulk sale opportunities with
various lenders with large pools of REO properties.
c. DEFINITIONS AND DESCRIPTIONS
Bliqhted Structure: The City of San Bernardino uses the State of California's definition of blight
as found at California Health and Safety Code Sections 33030 and 33031.
Affordable Rents: For NSP assisted rental activity, "affordable rents" shall be defined as 30%
of the household's adjusted income, less utility allowances as adopted by the County of San
Bernardino Housing Authority for the Section 8 program, as appropriate. HUD's Fair Market
Rent Schedule for the Riverside-San Bernardino-Ontario metropolitan area will be used. Should
any gap be present, funds for this gap will be required from other sources of funding.
To ensure continued affordability of NSP assisted rental housing, the program will include an
annual certification of occupancy including adequate verifiable documentation of income
pertaining to each member of the qualifying household. In addition, Grantee will impose
affordability covenants for a period of fifty-five (55) years through a deed restriction. This is
consistent with other multifamily and senior housing developments the Grantee has subsidized
in the past under California Redevelopment Law.
To ensure continued affordability of NSP assisted ownership housing, the program will impose
affordability covenants for a term not to exceed forty-five (45) years, commensurate with the
source of program funding and consistent with the Grantees existing down payment assistance
program. This will be enforced through deed restrictions and will also require annual
certification of owner occupancy and documentation to support proof of occupancy. This is
consistent with the City's existing home buyer down payment assistance program and is
consistent with both California Redevelopment Law and the State of California CalHome
Program.
NSP assisted rehabilitation activities will be conducted in accordance with all local, state, and
federal codes, statutes, and regulations and/or homeowner association or mobile home park
rules, and historic preservation requirements, as applicable, and will include modern, green
building and energy-efficiency improvements consistent with California Green Building
7
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EXHIBIT 1
Standards Code, as incorporated in Part 11 of the California Code of Regulations, Title 24, also
known as the California Building Standards Code.
D. Low INCOME TARGETING
At least $2,100,000 or 25% of the total award, under the NSP will be allocated to the Grantee's
recently released NOFA. Grantee has released a NOFA inviting the development community
to, among other things, identify specific multifamily housing projects with a history of public
service calls, documented conditions associated with poor management and those sites that are
generally considered to be a blighting influence on the surrounding community. Developers
submitting projects with these specifications would have the opportunity to compete for a portion
of Grantee funds to acquire, rehabilitate and manage such properties under a new professional
management agreement.
In response to the NSP, Grantee also added the opportunity for the development community to
compete for these funds to acquire and rehabilitate similar properties provided they had been
foreclosed upon or abandoned under the definitions identified in Section II A of HERA and
would be purchased at discount of between 5% and 15% of appraised value.
In the event Grantee receives no adequate response for the use of NSP funds from the
development community under its NOFA, Grantee will then issue a specific solicitation to
providers of housing to special needs groups including, but not limited to, the developmentally
disabled, the homeless in need of transitional housing and senior citizens.
E. ACQUISITIONS & RELOCATION
Grantee will generate preliminary title reports on those properties it intends to acquire looking
for, among other things, any deed restrictions associated with affordability. Should there be
deed restrictions, Grantee will arrange for those restrictions to remain after the structure is
rehabilitated and new occupants for the property are identified.
In the unlikely event the Grantee identifies a property that is beyond repair that must be
demolished that also has affordability covenants tied to it, the City will make note of this. Next,
Grantee will either: (1) attempt to replace the demolished structure with a new structure on the
same site with affordability covenants that are at least as restrictive as the original, or (2) identify
a different residential site to apply those affordability covenants.
Based on current estimates, Grantee anticipates demolishing or converting no greater than 20
dwelling units that currently benefit households at or below 80% of the AMI as a direct result of
NSP-assisted activities.
8
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EXHIBIT 1
Maximum Household Income 50% AMI
Activity Expected Housing Units Proposed
to be Produced Commencement/Completion
Acquisition/rehabilitation of One year from approval of
multifamily properties amendment by HUD/One year
through Grantee NOFA 100 after initiation of construction
process and/or rehabilitation
Maximum Household Income 120% AMI
Activity Expected Housing Units Proposed
to be Produced Commencement/Completion
Acquisition/rehabilitation and 90 days from approval of
resale of single family homes 200 amendment by HUD/4 years
from the initial HUD approved
amendment
Acquisition/demolition of 120 days from approval of
single family homes 50 amendment by HUD/4 years
from the initial HUD approved
amendment
90 days from approval of
Mortgage down payment 50 amendment by HUD/4 years
assistance from the initial HUD approved
amendment
Total Housing Units 400
Expected
F. PUBLIC COMMENT
A summary of public comments received to the proposed NSP Substantial Amendment will be
added after the public hearing on November 17, 2008.
9
P:\Agendas\Agenda Attachrnenls\Exhibits\2008\ 11-17-08 Neighborhood Stabiliution Program (Exhibit] ),doc
EXHIBIT 1
Down Payment Assistance
(1) Activitv Name: Financing Mechanism for Down Payment Assistance for
Households Under 120% of the AMI
(2) Activity Type:
CDBG Activity: Direct Homeownership Assistance
NSP Eligible Use: Financing Mechanism
(3) National Objective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Projected Start Date:
April 15, 2009
January 15, 2013
(5) Projected End Date:
(6) Responsible Organization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description:
Citywide
(8) Activity Description: This activity will benefit individuals and families whose incomes do
not exceed 120% of AMI to purchase a home within the City which is currently experiencing one
of the highest foreclosure and abandonment rates in the state of California.
This activity will provide a one-time benefit of homeownership to qualifying individuals and
families. The duration of the term of assistance is a moment in time at the point of escrow
closing as the activity consists of down payment assistance exclusively for home buyers whose
incomes do not exceed 120% of the AMI.
Program participants will be required to enter into an affordability covenant that will be tied the
property for a term not to exceed forty-five (45) years, commensurate with the source of
program funding and consistent with the Grantees existing down payment assistance program
and is in compliance with California redevelopment law and the State of California CalHome
Program.
Initial acquisition will average at least 15% below a current appraised value.
The sales price will be no greater the total investment on the property by the City (including
acquisition, rehabilitation, and associated program delivery costs).
10
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EXHIBIT 1
(9) Total Budqet: $ 920,000 (Estimated NSP allocation)
$4,600,000 (Estimated publiC and private fundS)
(10) Performance Measures: Number of units sold to individuals and families whose income
does not exceed 120% of the AMI.
11
P:\AgendasIAgenda AuachmentslExhibits\2008\11-17-08 Neighborhood Stabilization Program (Exhibit 1) doc
EXHIBIT 1
HousinCl Opportunities for Households At or Below 50% AMI
(1) Activity Name: Rental Housing Opportunities for Households at 50% of the AMI
(2) Activity Type:
CDBG Activity: Acquisition and Rehabilitation
NSP Eligible Use: Purchase and rehabilitation of foreclosed upon or abandoned homes and
residential properties in order to rent.
(3) National Objective: Benefit to individuals and families whose household income does not
exceed 50% of the AMI.
(4) Projected Start Date:
April 15, 2010
(5) Projected End Date:
December 31, 2011
(6) Responsible Orqanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Alln: Carey K. Jenkins
Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activity Description: This activity is for acquisition/rehabilitation/rental, specifically to provide
affordable rental opportunities for households earning less than 50% of the AMI. Rents charged
will be no greater than the Fair Market Rents, as published by HUD. Household rent cannot
exceed 30% of the household's monthly income, less appropriate utility allowances. Should a
gap exist, a subsidy from another source must be identified.
I. Total Budqet:
$ 2,100,000 (Estimated NSP allocation)
$10,500,000 (Estimated public and private funds)
J. Performance Measures
Number of rental housing units produced for individuals and families whose income does not
exceed 50% of the AMI.
12
Pc\Agendas\Agenda Attachments\Exhibils\2008\11.17.08 Neighborhood Stabiliution Program (Exhibit I).doc
EXHIBIT 1
Acquisition, Rehabilitation and Resale
(1) Activitv Name: Acquisition, Rehabilitation and Resale of Single Family Homes
(2) Activitv Tvpe:
CDBG Activity: Acquisition and rehabilitation
NSP Eligible Use: Purchase and rehabilitation of foreclosed upon or abandoned homes for
resale.
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Proiected Start Date: April 15, 2009
(5) Proiected End Date: January 15, 2013
(6) Responsible Oraanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activitv Description: This activity is for acquisition/rehabilitation/resale to qualifying income
eligible homebuyers. The tenure of the beneficiaries is home ownership; the duration of the
assistance will be dependent on the household's debt capacity. Should there be an affordability
gap, some portion of the City's original investment of acquisition and/or rehabilitation funds
would remain in the property as a "silent second" to be repaid upon change in title or status as
owner-occupied housing. The property would have an affordability covenant recorded against it
for a term not to exceed forty-five (45) years, commensurate with the source of program funding
and consistent with the Grantees existing down payment assistance program and in compliance
with California redevelopment law and the State of California CalHome Program. As with other
assisted single family units through the City's rehabilitation programs and down-payment
assistance programs, continued affordability is ensured through an annual monitoring process.
The sales prices will be no greater than the total investment by the city (including acquisition,
rehabilitation, and associated program delivery costs).
1. Total Budaet:
$ 3,700,000 (Estimated NSP Allocation)
$18,500,000 (Estimated public and private fundS)
J. Performance Measures: Number of foreclosed upon or abandoned properties acquired,
rehabilitated and resold to qualified home buyers.
13
P\Agendas\Agenda Attacbments\Exbibits\2008\1 1-17-08 Neighborhood Stabilization Program (Exhibit 1) doc
EXHIBIT 1
Acquisition. Demolition and Redevelopment
(1) Activitv Name: Acquisition/Demolition/Redevelopment
(2) Activitv Tvpe:
CDBG Activity: Acquisition/Rehabilitation/Resale
NSP Eligible Use: AcquisitionlDemolition
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(5) Proiected End Date:
April 15, 2009
April 15, 2013
(4) Proiected Start Date:
(6) Responsible Oraanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activitv Description: This activity is for acquisition/demolition/redevelopment of foreclosed,
abandoned single family properties that would require more funds to rehabilitate than to
demolish and eventually rebuild. After consultation with the City's Building Official, a
determination would be made to demolish the structure instead of attempting rehabilitate it. The
property would then be made available to housing providers to plan the redevelopment of the
property as soon as feasible. Redevelopment may include sale of the property at current fair
market value, or below current fair market value, or partnership with a non-profit agency.
I. Total Budaet:
$ 920,000 (Estimated NSP allocation)
$4,600,000 (Estimated public and private funds)
J. Performance Measures: Number of foreclosed or abandoned housing units acquired,
rehabilitated or demolished for the income levels of households not exceeding 120% of the AMI.
14
P:lAgendas\Agenda Atlacbments\EJ\hibits\1008\11-17-08 Neighborhood Stabilization Program (Exhibit l)doc
EXHIBIT 1
Administration
(1) Activitv Name: Administration
(2) Activitv Tvpe:
CDBG Activity: Administration
NSP Eligible Use: Administration
(3) National Objective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Projected Start Date: September 29, 2008
(5) Projected End Date: April 15, 2013
(6) Responsible Orqanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: The City of San Bernardino Economic Development Agency will be
the lead agency - 201 North "E" Street, Suite 301, San Bernardino, CA 92401.
(8) Activitv Description: Administration of the NSP grant.
I. Total Budqet: $800,000
J. Performance Measures: Not applicable for program administration.
15
P:\Agendas\Agenda Attachments\ExhibitsI2008\11-17-08 Neighborhood Stabilization Program (Exhibit I),doc
EXHIBIT 2
(Map of ForecIosed Properties)
City of San Bernardino
Number of Foreclosed Properties as of November 05, 2008
"
Legend
Ward 1 (312 Properties) (13.8%)
D Ward 2 (483 Properties) (21.3%)
Ward 3 (183 Properties) (8.1%)
D Ward 4 (216 Properties) (9.5%)
D Ward 5 (356 Properties) (15.7%)
D Ward 6 (350 Properties) (15.5%)
D Ward 7 (364 Properties) (16.1%)
Totai : 2,264 Properties
w.'
,
Number of foreclosures is based on 2,264 units identified by
Realt Trac as of 11/05/2008
1
2
3
4
5
6
7
RESOLUTION NO.
rF n 1[5) ;;
\~~:~-;) \~)) lr~ d
RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE CITY
OF SAN BERNARDINO, CALIFORNIA, APPROVING A SUBSTANTIAL
AMENDMENT TO THE CONSOLIDATED ANNUAL ACTION PLAN FOR
FISCAL YEAR 2008-2009; AND AUTHORIZING THE CITY MANAGER OR
HIS DESIGNEE TO EXECUTE, ON BEHALF OF THE CITY, SUCH
DOCUMENTS AS REQUESTED BY THE UNITED STATES DEPARTMENT
OF HOUSING AND URBAN DEVELOPMENT TO EFFECTUATE THE
SUPPLEMENT AL APPROPRIATION
8 WHEREAS, in Fiscal Year 2008-2009 the City of San Bernardino, California (the "City'), is
9 entitled to receive $8.4 million from the United States Department of Housing and Urban
10 Development ("HUD") under the Neighborhood Stabilization Program ("NSP") for the purpose of
11 redeveloping abandoned and foreclosed homes and residential properties as authorized under Title
12 III Division B of the Housing and Economic Recovery Act ("HERA") of2008; and
13 WHEREAS, the NSP is subject to certain statutory and regulatory provisions governing the
14 Community Development Block Grant ("CDBG") program as necessitated by HERA; and
15 WHEREAS, the City, as a direct recipient of CDBG funds has submitted to HUD and HUD
16 has approved a Consolidated Plan for Fiscal Years 2005-2010 and a Consolidated Annual Action
17 Plan for Fiscal Year 2008-2009 (the "Action Plan"); and
18 WHEREAS, HUD considers NSP Grant Funds to be a supplemental appropriation of CDBG
19 Funds requiring a substantial amendment to the Action Plan; and
20 WHEREAS, the City is required by the NSP to prepare and submit a substantial amendment
21 to the annual Action Plan by December 1, 2008, in accordance with the consolidated plan
22 procedures for a substantial amendment under the annual CDBG program; and
23 WHEREAS, the City has provided citizens adequate opportunity to review and comment on
24 the proposed substantial amendment to the annual Action Plan as required by HUD's alternative
25 requirements to 42 U.S.C. 5304(a)(2) under the NSP that waive the requirements of Sections
26 91.105(k) and 91.1 15(i) to the extent necessary to allow a grantee to provide no fewer than fifteen
27 (15) calendar days for citizen comment; and
28
I
P'Agendas\Resol<.ltions\Reso\ulion.\2008\11-11-0S Substantial Amendment - Annual Action Plan FYOS.o9 MCC Reso,doc
Of?
1 WHEREAS, the City seeks to redevelop abandoned and foreclosed homes and residential
2 properties to address the significant costs that foreclosure activity imposes on local municipalities
3 and neighborhoods within the City.
4 NOW, THEREFORE. IT IS HEREBY RESOLVED, DETERMINED AND ORDERED BY
5 THE MAYOR AND COMMON COUNCIL OF THE CITY OF SAN BERNARDINO, AS
6 FOLLOWS:
7 Section 1. That the Mayor and Common Council hereby approves the Substantial
8 Amendment to the Consolidated Annual Action Plan for Fiscal Year 2008-2009 to include a
9 supplemental appropriation in the amount of $8.4 million under the Neighborhood Stabilization
10 Program for the purpose of the redevelopment of abandoned and foreclosed homes and residential
11 properties. A copy of the Substantial Amendment is attached hereto as Exhibit I and by this
12 reference made a part hereof as though set forth herein at length.
13 Section 2. That the City Manager, or his designee, is authorized to execute and submit to
14 HUD the appropriate applications, agreements and ancillary documents necessary to implement the
15 NSP as said applications, agreements and ancillary documents that are prepared and herein
16 approved, a copy of which are on file with the City Clerk. and are incorporated herein by reference
17 as though fully set forth at length.
18 Section 3. This Resolution shall take effect upon its adoption and execution in the manner
19 as required by the City Charter.
20 1/1
21 1/1
22 1/1
23 1/1
24 1/1
25 1/1
26 /II
27 /II
28 1/1
~
"-
P.\Agendas\Resolutions"Resolutions\2008\ll-17-0S Substantial Amendment - Annual Action Plan FYOS-09 ~ICC Resodoc
1
2
3
4
5
6
RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE CITY
OF SAN BERNARDINO, CALIFORNIA, APPROVING A SUBSTANTIAL
AMENDMENT TO THE CONSOLIDATED ANNUAL ACTION PLAN FOR
FISCAL YEAR 2008-2009; AND AUTHORIZING THE CITY MANAGER OR
IDS DESIGNEE TO EXECUTE, ON BEHALF OF THE CITY, SUCH
DOCUMENTS AS REQUESTED BY THE UNITED STATES DEPARTMENT
OF HOUSING AND URBAN DEVELOPMENT TO EFFECTUATE THE
SUPPLEMENT AL APPROPRIATION
I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the Mayor and
7 Common Council of the City of San Bernardino at a
meeting
8 thereof, held on the day of , 2008, by the following vote to wit:
9 Council Members: Aves Navs Abstain Absent
10 ESTRADA
11 BAXTER
12 BRINKER
13 DERRY
14 KELLEY
15 JOHNSON
16 MC CAMMACK
17
18
19
Rachel G. Clark, City Clerk
day of
,2008.
The foregoing Resolution is hereby approved this
20
21
22
Patrick J. Morris, Mayor
City of San Bernardino
23
24
25
26
27
28
Approved as to Form:
~
I
I
,
90
.! ~/J
/}~ '.....c i,- '"Y2---
James F. Penman, City Attorney
,
---,'
3
P~endas\ResolutiOl\S\Resol11tions\2008\11.17.08 Substantial Amendment - Annual Action Plan FY08-09 MCC Reso_doc
EXHIBIT 1
CITY OF SAN BERNARDINO
Neighborhood Stabilization Program
Substantial Amendment to the
Fiscal Year 2008-2009 Action Plan
November 17,2008
Pc\.6.gendas\Agenda Anachments\Exhibiu\200S\11-17.08 Neighborhood Stabiliution Program (Exhibit 1) doc
EXHIBIT 1
City of San Bernardino
Neighborhood Stabilization Program
Substantial Amendment to the Fiscal Year 2008-2009 Action Plan
Table of Contents
Introduction...... ... ... ......... ............ ................................. ......... .............................3
A. Areas of Greatest Need...... ..................... .................................... ................4
B. Distribution and Uses of Funds.................................................................. ..5
C. Definitions and Descriptions...................................................... ................ ..7
D. Low Income Targeting............ ................................. ......... ..........................8
E. Acquisitions & Relocation....................................... ..................... ................. 8
F. Public Comment.................................................................................... ...9
Activities
(1) Down Payment Assistance .......................................... ........................ .....10
(2) Housing Opportunities for Households At or Below 50% AMI............ ............... .12
(3) Acquisition, Rehabilitation and Resale ........................................................13
(4) Acquisition, Demolition and Redevelopment... ...... ...... ...... ............... ...... ........14
(5) Administration...... ............ ................................. ..................... ...................15
2
P\Agcndas\Agenda A!tachmentslExhibits\200S\11-j7-08 Neighborhood Stabilization Program {EJdlibit I). doc
EXHIBIT 1
City of San Bernardino
Neighborhood Stabilization Program
Substantial Amendment to the Fiscal Year 2008-2009 Action Plan
City of San Bernardino
NSP Contact
Carey K. Jenkins, Director of Housing and Community Development
San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401
Tel: (909) 663-1044. Fax: (909) 888-9413
Email: cjenkins@sbrda.org
www.sbrda.org
INTRODUCTION
In response to the national rise in subprime mortgage foreclosures and the significant costs that
foreclosures impose on local municipalities and neighboring homeowners, Congress authorized
$3.92 billion for the redevelopment of abandoned and foreclosed homes and residential
properties under Title III of the Housing and Economic recovery Act of 2008 (HERA). The funds
are administered by the United States Department Housing and Urban Development (HUD)
under a new entitlement grant program referred to as the Neighborhood Stabilization Program
(NSP).
Under the NSP, the City of San Bernardino ("San Bernardino" or "City") was allocated $8.4
million. Allocations were made by HUD based on qualifying grantees' (1) number of and
percentage of home foreclosures, (2) number of and percentage of homes financed by a
subprime mortgage related loan, and (3) number of and percentage of homes in default or
delinquency. For San Bernardino, HUD determined the City has a local foreclosure rate of
11.8%, the second highest rate among general local governments in California. The percentage
of homeowners holding subprime mortgage loans within the city ranges between 16.8% and
59% with an overall average of 42.7%, and the percentage of homes at risk of foreclosure
ranges between 7.6% and 14.4% with an overall average for the City of 11.7%.
To receive NSP funding, San Bernardino is required to submit to HUD a Substantial
Amendment to the Consolidated Annual Action Plan for Fiscal Year 2008-2009 ("Substantial
Amendment") by December 1, 2008. This Substantial Amendment is required because NSP
grants are treated as a supplemental appropriation of CDBG funds for the undertaking of
activities that were not budgeted in the current year Action Plan.
The Substantial Amendment includes a needs analysis identifying the geographic areas of
greatest need within the City, and the proposed distribution and use of NSP funds. Sources of
information used include data derived and employed by HUD to determine its needs
3
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EXHIBIT 1
assessment in allocating NSP funds, 2006 U.S. Census information, foreclosure information
provided by RealtyTrac, and internal GIS data.
A. AREAS OF GREA TEST NEED
One of the most dramatic changes in financial services over the last few years has been the
expansion of mortgage products. In addition to the conventional fixed-rate 3D-year loan, lenders
now offer a number of other mortgage products such as "interest-only" mortgages that allow a
borrower to pay only the interest for the first few years of the loan and "payment option"
adjustable-rate mortgages (ARMs) that include flexible payment options for the borrower.
These types of mortgages are often combined with second-lien mortgages and allow reduced
documentation of creditworthiness. In 2006, these so called "nontraditional" mortgages
accounted for more than one-third of all mortgage loans compared to 2% six years earlier.
While these mortgage products can benefit some consumers, data shows that these loans are
usually marketed to less sophisticated buyers or those who may not otherwise qualify for more
traditional mortgage loans. These loans eventually become unaffordable to the consumer and
result in default and foreclosure.
Between 1994 and 2006 the annual dollar volume of subprime loans issued across the United
States grew from $35 billion to more than $600 billion, and their share of home loan originations
increased from 4.5% to 20% (Inside Mortgage Finance, 2007)'. In 2006 the Federal Reserve
Board found that in minority areas approximately 46.6% of the home loans issued were high-
priced or sub-prime loans compared to 21.7% in non-minority communities. In San Bernardino,
with a minority population of 57.5%2, approximately 42.7% of existing home mortgage loans are
high-cost loans according to HUD's data. However, the rate is as high as 59% in certain areas
of the City.
HUD data indicates the foreclosure rate in the City of San Bernardino is 11.8%; it is the second
highest rate among municipalities within California. The data is based on the following: (1) the
change in home values as of June 2008 compared to 2000; (2) the percentage of high cost (or
subprime) mortgage loans made between 2004 and 2006; and (3) the unemployment rate as of
June 2008.
Additional data provided by RealtyTrac, an Irvine based company that tracks foreclosures
nationwide, indicates there are currently over 3,500 foreclosed upon homes in San Bernardino.
RealtyTrac was able to provide Assessor Parcel Numbers (APNs) for 3,109 of these properties.
Of this number, 2,264 foreclosed upon properties were identified and plotted within City
boundaries. Based on this more conservative figure of 2,264, the percentage of homes that
have been foreclosed upon ranges from a low of 8.1 % in Ward 3 to a high of 21.3% in Ward 2.
The first column of Table 1 and the map designated Exhibit 1 show the distribution of
foreclosures throughout the City on a ward-by-ward basis.
Further analysis of HUD's data at the tract and block group level reveals a clearer assessment
of the foreclosure crisis within the City. Table 1 shows the rate of subprime mortgages within
the City averages 42.7%. This varies by ward from an average low of 34.1% in Ward 5 to a
high of 51.6% in Ward 2. However, the percentage of subprime mortgage loans ranges from a
1
Referenced by Chairman Ben S. Bernanke in his speech at the National Community Reinvestment Coalition Annual Meeting,
Washington. D.C. 3/141 2008.
2 U.S. Census Bureau, 2006 American Community Survey.
4
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low of 16.8% in Ward 4 to a high of 59% in Ward 1. The projected rate of foreclosures within
the next 18 months averages 11.7% throughout the City, and averages between a low of 10.4%
in Ward 5 to a high of 13.2% in Ward 2. And, again, in some areas of the City, the projection
can be much higher as in Ward 1 where the projected foreclosure rate is as high as 14.4%. For
the City overall, HUD's foreclosure and abandonment risk is high.
Table 1
Percentage of Average Foreclosure . 18-Month Projected
Foreclosed Ward Subprime Mortgages Abandonment Risk Foreclosure Rate
Homes by (% of Homes}4 (Scale 1-10, (% of homes)
Ward3 Range 10=worst)
Average 51.3% 10 13.1%
13.8% 1
Range 34.8% - 59.0% 8.10 10.5% . 14.4%
Average 51.6% 10 13.2%
21.3% 2
Range 45.4% - 56.6% 9.10 12.2% -14%
Average 39.9% 9 11.3%
8.1% 3
Range 25% - 51.7% 8 -10 8.9% -13.2%
Average 34.9% 8 10.5%
9.5% 4
Range 16.8% - 46.9% 4-10 7.6% -12.4%
Average 34.1% 9 10.4%
15.7% 5 8.5%-11.2%
Range 22.5% . 39.2% 8.9
Average 43.5% 9 11.8%
15.5% 6
Range 22.5% - 55.1 % 8.10 8.5% -13.7%
Average 42.9% 9 11.8%
16.1% 7
Range 35.9% .49.4% 9 -10 10.7% -12.8%
11.8%5 Citywide Average 42.7% 9 11.7%
Range 16.8% - 59% 4-10 7.6% -14.4%
B. DISTRIBUTION AND USES OF FUNDS
The data collected thus far clearly indicates the foreclosure crisis is occurring in practically every
residential neighborhood within San Bernardino. Grantee, therefore, recommends that NSP
funds be made available on a citywide basis, and has identified five (5) separate programs with
which to deploy the grant that include the following:
1. Down Payment Assistance: This program sets aside $920,000 of NSP funds for use as a
financing mechanism to ensure affordability for individuals and families purchasing NSP
assisted residential properties. Assistance will be provided in the form of down payment
assistance to individuals and families whose household income does not exceed 120% of
the AMI. It is estimated that structuring the use of the NSP funds in this manner will be
leveraged with an additional amount equal to approximately $4,600,000 in private first trust
deed funds.
Presently, Grantee provides up to 20% of the acquisition cost of a single family home to first
time home buyers whose household income does not exceed 120% of the AMI. Funds for
the existing program are currently derived from Redevelopment Agency housing set aside
3 Generated by the City of San Bernardino Geographic Information System based on 2,264 units identified by RealtyTrac as of 1110512008.
4 HUD User Data for NSP by census tract was aggregated for each Ward.
S Based on HUD User Data used to make NSP allocations.
5
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dollars. The program would be augmented by incorporating NSP funds into the down
payment (up to 50% of the needed subsidy) and the requirement for a first time home buyer
would be waived. The Redevelopment Agency's standard 45-year affordability covenant
would apply.
2. Housing Opportunities for Households at or below 50% AMI: This program allocates
$2,100,000 of NSP funds to the Notice of Funding Availability (NOFA) recently issued by the
Agency for the provision of affordable housing. This complies with the NSP requirement
that at least 25% of the grant, in this case $2,100,000, be allocated to address the housing
needs of individuals and households whose income does not exceed 50% of the AMI and
maximizes the projected benefit of the NOFA. It is anticipated that the NSP funds for this
component will be leveraged by an additional amount upwards of $10,500,000 in private
capital.
The recently released NOFA invites the development community to, among other things,
identify specific multifamily housing projects with a history of public service calls,
documented conditions associated with poor management and those sites that are generally
considered a blighting influence on the surrounding community. Developers submitting
projects with these specifications would have the opportunity to compete for a portion of
Grantee funds to acquire, rehabilitate and manage such properties under a new professional
management agreement. In response to the NSP, the Grantee also added the opportunity
for the development community to compete for these funds to acquire and rehabilitate
similar properties provided they had been foreclosed upon or abandoned under the
definitions identified in Section II A of HERA and would be purchased at discount of between
5% and 15% of appraised value.
3. Acquisition, Rehabilitation and Resale: This program allocates $3,700,000 of NSP funds
for the acquisition and rehabilitation of single-family homes through participating
intermediaries, such as builder/developer contractors. These intermediaries will be retained
through a Request for Production/Qualifications (RFP) process and will be vetted by Agency
staff with recommendations submitted to the Council. The RFP process will begin in
January of 2009. It is anticipated that the NSP funds allocated under this component will
attract an additional $18,500,000 in private first trust deed capital. Upon rehabilitation, the
homes will be made available for purchase to qualifying households whose incomes do not
exceed 120% of the AMI.
Key qualifying points of the RFP would include, but not be limited to: (1) experience in the
last five years of rehabilitating single family housing structures; (2) reference letters from as
many as three separate municipal jurisdictions attesting to the amount and quality of
rehabilitation work completed; and (3) demonstrated ability to provide the financial resources
to rehabilitate multiple properties simultaneously with the expectation of reimbursement
upon close of escrow. All requirements including, but not limited to, those associated with
the 120% the AMI ceiling and the purchase discount would be maintained for each
acquisition.
4. Acquisition, Demolition and Redevelopment: This program is designed to address
abandoned or foreclosed upon residential units in physical conditions too costly for
rehabilitation. With a budget of $920,000, this program will allow for the acquisition,
demolition and future redevelopment of the site. Grantee anticipates these program funds
will be leveraged with an additional amount equal to approximately $4,600,000 in private
development capital for future infill developments on these various sites.
6
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Grantee would consult with the City's Building Official regarding the structural soundness of
the property and, if deemed appropriate, demolition would occur. Plans to develop the
parcel as an in-fill unit or units would commence as soon as the local housing market begins
to stabilize. Several redevelopment options would be considered. One option would be to
redevelop the site utilizing modular housing thus ensuring quality building products and a
rapid turn around. Other options might include selling the parcel to a non-profit such as
Habitat for Humanity for a reduced price to help subsidize their next new construction
project or another non-profit expert in special needs housing.
5. Administration: Administration of the program will not exceed 10% of the NSP grant and
10% of program income.
It is the expectation of Grantee to team up with other local jurisdictions that have been awarded
NSP funds to collaborate on such program components as jointly paying for home buyer
education courses, conducting joint procurement activities with regards to identifying and
contracting with builder/developer intermediaries and negotiating bulk sale opportunities with
various lenders with large pools of REO properties.
C. DEFINITIONS AND DESCRIPTIONS
Bliahted Structure: The City of San Bernardino uses the State of California's definition of blight
as found at California Health and Safety Code Sections 33030 and 33031.
Affordable Rents: For NSP assisted rental activity, "affordable rents" shall be defined as 30%
of the household's adjusted income, less utility allowances as adopted by the County of San
Bernardino Housing Authority for the Section 8 program, as appropriate. HUD's Fair Market
Rent Schedule for the Riverside-San Bernardino-Ontario metropolitan area will be used. Should
any gap be present, funds for this gap will be required from other sources of funding.
To ensure continued affordability of NSP assisted rental housing, the program will include an
annual certification of occupancy including adequate verifiable documentation of income
pertaining to each member of the qualifying household. In addition, Grantee will impose
affordability covenants for a period of fifty-five (55) years through a deed restriction. This is
consistent with other multifamily and senior housing developments the Grantee has subsidized
in the past under California Redevelopment Law.
To ensure continued affordability of NSP assisted ownership housing, the program will impose
affordability covenants for a term not to exceed forty-five (45) years, commensurate with the
source of program funding and consistent with the Grantees existing down payment assistance
program. This will be enforced through deed restrictions and will also require annual
certification of owner occupancy and documentation to support proof of occupancy. This is
consistent with the City's existing home buyer down payment assistance program and is
consistent with both California Redevelopment Law and the State of California CalHome
Program.
NSP assisted rehabilitation activities will be conducted in accordance with all local, state, and
federal codes, statutes, and regulations and/or homeowner association or mobile home park
rules, and historic preservation requirements, as applicable, and will include modern, green
building and energy-efficiency improvements consistent with California Green Building
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Standards Code, as incorporated in Part 11 of the California Code of Regulations, Title 24, also
known as the California Building Standards Code.
D. Low INCOME TARGETING
At least $2,100,000 or 25% of the total' award, under the NSP will be allocated to the Grantee's
recently released NOFA. Grantee has released a NOFA inviting the development community
to, among other things, identify specific multifamily housing projects with a history of public
service calls, documented conditions associated with poor management and those sites that are
generally considered to be a blighting influence on the surrounding community. Developers
submitting projects with these specifications would have the opportunity to compete for a portion
of Grantee funds to acquire, rehabilitate and manage such properties under a new professional
management agreement.
In response to the NSP, Grantee also added the opportunity for the development community to
compete for these funds to acquire and rehabilitate similar properties provided they had been
foreclosed upon or abandoned under the definitions identified in Section II A of HERA and
would be purchased at discount of between 5% and 15% of appraised value.
In the event Grantee receives no adequate response for the use of NSP funds from the
development community under its NOFA, Grantee will then issue a specific solicitation to
providers of housing to special needs groups including, but not limited to, the developmentally
disabled, the homeless in need of transitional housing and senior citizens.
E. ACQUISITIONS & RELOCATION
Grantee will generate preliminary title reports on those properties it intends to acquire looking
for, among other things, any deed restrictions associated with affordability. Should there be
deed restrictions, Grantee will arrange for those restrictions to remain after the structure is
rehabilitated and new occupants for the property are identified.
In the unlikely event the Grantee identifies a property that is beyond repair that must be
demolished that also has affordability covenants tied to it, the City will make note of this. Next,
Grantee wili either: (1) attempt to replace the demolished structure with a new structure on the
same site with affordability covenants that are at least as restrictive as the original, or (2) identify
a different residential site to apply those afford ability covenants.
Based on current estimates, Grantee anticipates demolishing or converting no greater than 20
dwelling units that currently benefit households at or below 80% of the AMI as a direct result of
NSP-assisted activities.
8
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EXHIBIT 1
Maximum Household Income 50% AMI
Activity Expected Housing Units Proposed
to be Produced Commencement/Completion
Acquisition/rehabilitation of One year from approval of
multifamily properties amendment by HUD/One year
through Grantee NOFA 100 after initiation of construction
process and/or rehabilitation
Maximum Household Income 120% AMI
Activity Expected Housing Units Proposed
to be Produced Commencement/Completion
Acquisitionirehabilitation and 90 days from approval of
resale of single family homes 200 amendment by HUD/4 years
from the initial HUD approved
amendment
Acquisition/demolition of 120 days from approval of
single family homes 50 amendment by HUD/4 years
from the initial HUD approved
amendment
90 days from approval of
Mortgage down payment 50 amendment by HUD/4 years
assistance from the initial HUD approved
amendment
Total Housing Units 400
Exoected
F. PUBLIC COMMENT
A summary of public comments received to the proposed NSP Substantia/ Amendment will be
added after the public hearing on November 17, 2008.
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Down Payment Assistance
(1) Activitv Name: Financing Mechanism for Down Payment Assistance for
Households Under 120% of the AMI
(2) Activitv Tvpe:
CDBG Activity: Direct Homeownership Assistance
NSP Eligible Use: Financing Mechanism
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Proiected Start Date:
April 15, 2009
(5) Proiected End Date:
January 15, 2013
(6) Responsible Orqanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description:
Citywide
(8) Activitv Description: This activity will benefit individuals and families whose incomes do
not exceed 120% of AMI to purchase a home within the City which is currently experiencing one
of the highest foreclosure and abandonment rates in the state of California.
This activity will provide a one-time benefit of homeownership to qualifying individuals and
families. The duration of the term of assistance is a moment in time at the point of escrow
closing as the activity consists of down payment assistance exclusively for home buyers whose
incomes do not exceed 120% of the AMI.
Program participants will be required to enter into an affordability covenant that will be tied the
property for a term not to exceed forty-five (45) years, commensurate with the source of
program funding and consistent with the Grantees existing down payment assistance program
and is in compliance with California redevelopment law and the State of California CalHome
Program.
Initial acquisition will average at least 15% below a current appraised value.
The sales price will be no greater the total investment on the property by the City (including
acquisition, rehabilitation, and associated program delivery costs).
10
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(9) Total Budoet: $ 920,000 (Estimated NSP allocation)
$4,600,000 (Estimated public and private funds)
(10) Performance Measures: Number of units sold to individuals and families whose income
does not exceed 120% of the AMI.
11
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EXHIBIT 1
Housina Opportunities for Households At or Below 50% AMI
(1) Activitv Name: Rental Housing Opportunities for Households at 50% of the AMI
(2) Activitv Tvpe:
CDBG Activity: Acquisition and Rehabilitation
NSP Eligible Use: Purchase and rehabilitation of foreclosed upon or abandoned homes and
residential properties in order to rent.
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 50% of the AMI.
(4) Proiected Start Date:
April 15, 2010
(5) Proiected End Date:
December 31, 2011
(6) Responsible Orqanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn: Carey K. Jenkins
Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activitv Description: This activity is for acquisition/rehabilitation/rental, specifically to provide
affordable rental opportunities for households earning less than 50% of the AMI. Rents charged
will be no greater than the Fair Market Rents, as published by HUD. Household rent cannot
exceed 30% of the household's monthly income, less appropriate utility allowances. Should a
gap exist, a subsidy from another source must be identified.
I. Total Budqet:
$ 2,100,000 (Estimated NSP allocation)
$10,500,000 (Estimated public and private funds)
J. Performance Measures
Number of rental housing units produced for individuals and families whose income does not
exceed 50% of the AMI.
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Acauisition. Rehabilitation and Resale
(1) Activity Name: Acquisition, Rehabilitation and Resale of Single Family Homes
(2) Activity Type:
CDBG Activity: Acquisition and rehabilitation
NSP Eligible Use: Purchase and rehabilitation of foreclosed upon or abandoned homes for
resale.
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Proiected Start Date: April 15, 2009
(5) Proiected End Date: January 15, 2013
(6) Responsible Orqanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activity Description: This activity is for acquisition/rehabilitation/resale to qualifying income
eligible homebuyers. The tenure of the beneficiaries is home ownership; the duration of the
assistance will be dependent on the household's debt capacity. Should there be an affordability
gap, some portion of the City's original investment of acquisition and/or rehabilitation funds
would remain in the property as a "silent second" to be repaid upon change in title or status as
owner-occupied housing. The property would have an affordability covenant recorded against it
for a term not to exceed forty-five (45) years, commensurate with the source of program funding
and consistent with the Grantees existing down payment assistance program and in compliance
with California redevelopment law and the State of California CalHome Program. As with other
assisted single family units through the City's rehabilitation programs and down-payment
assistance programs, continued affordability is ensured through an annual monitoring process.
The sales prices will be no greater than the total investment by the city (including acquisition,
rehabilitation, and associated program delivery costs).
I. Total Budqet:
$ 3,700,000 (Estimated NSP Allocation)
$18,500,000 (Estimated public and private funds)
J. Performance Measures: Number of foreclosed upon or abandoned properties acquired,
rehabilitated and resold to qualified home buyers.
13
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Acquisition. Demolition and Redevelopment
(1) Activity Name: AcquisitionlDemolition/Redevelopment
(2) Activity Type:
CDBG Activity: Acquisition/Rehabilitation/Resale
NSP Eligible Use: Acquisition/Demolition
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(5) Proiected End Date:
April 15, 2009
April 15, 2013
(4) Proiected Start Date:
(6) Responsible Oroanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: Citywide
(8) Activity Description: This activity is for acquisition/demolition/redevelopment of foreclosed,
abandoned single family properties that would require more funds to rehabilitate than to
demolish and eventually rebuild. After consultation with the City's Building Official, a
detenmination would be made to demolish the structure instead of attempting rehabilitate it. The
property would then be made available to housing providers to plan the redevelopment of the
property as soon as feasible. Redevelopment may include sale of the property at current fair
market value, or below current fair market value, or partnership with a non-profit agency.
I. Total Budoet:
$ 920,000 (Estimated NSP allocation)
$4,600,000 (Estimated public and private funds)
J. Perfonmance Measures: Number of foreclosed or abandoned housing units acquired,
rehabilitated or demolished for the income levels of households not exceeding 120% of the AMI.
14
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EXHIBIT 1
Administration
(1) Activity Name: Administration
(2) Actiyity Type:
CDBG Activity: Administration
NSP Eligible Use: Administration
(3) National Obiective: Benefit to individuals and families whose household income does not
exceed 120% of the AMI.
(4) Proiected Start Date: September 29, 2008
(5) Proiected End Date: April 15, 2013
(6) Responsible Oraanization:
City of San Bernardino Economic Development Agency
201 North "E" Street, Suite 301
San Bernardino, CA 92401-9413
(909) 663-1044
Attn.: Carey K. Jenkins, Director of Housing and Community Development
(7) Location Description: The City of San Bernardino Economic Development Agency will be
the lead agency - 201 North "E" Street, Suite 301, San Bernardino, CA 92401.
(8) Activity Description: Administration of the NSP grant.
I. Total Budaet: $800,000
J. Performance Measures: Not applicable for program administration.
15
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EXHIBIT 2
(Map of Foreclosed Properties)
City of San Bernardino
Number of Foreclose'd Properties as of November 05, 2008
:..
:.
Legend
D Ward 1 (312 Properties) (13.8%)
D Ward 2 (483 Properties) (21.3%)
D Ward 3 (183 Properties) (8.1%)
D Ward 4 (216 Properties) (9.5%)
o Ward 5 (356 Properties) (15.7%)
..=:::J Ward 6 (350 Properties) (15.5%)
D Ward 7 (364 Properties) (16.1%)
Total: 2,264 Properties
we,
s
Number of foreclosures is based on 2,264 units identified by
RealtvTrac as of 11/0512008