Green Affordable Housing Act of 2009

Budget of the United States Government, Fiscal Year 2011; all provisions relating to the U.S. Department of Housing and Urban Development (HUD) and U.S. Department of Agriculture-Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service proposals related to the Low Income Housing Tax Credit and bond-financed multifamily housing programs. (continued) HR 5850-Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2011: A bill making appropriations for the Departments of Transportation, HUD and Related Agencies for the fiscal year ending September 30, 2011, and for other purposes; Title II Housing and Urban Development; - all funding & administrative provisions related to affordable housing programs, with particular emphasis on full funding of 12 month terms of project-based Section 8 contracts and fair housing activities to create translations and programs to assist persons with limited English proficiency (LEP). Requested amendments [to H.R. 5850, Title II] to include Sections 101 & 102(b) of H.R. 4868 to provide a conversion mechanism for Rent Supp and RAP properties to a Project-Based Section 8 contract and subsidies [not included]; S 3644- Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2011: A bill making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2011, and for other purposes; Title II Housing and Urban Development - all funding & administrative provisions related to affordable housing programs, with particular emphasis on full funding of 12 month terms of project-based Section 8 contracts and fair housing activities to create translations and programs to assist persons with limited English proficiency (LEP). Requested amendments [to S. 3644, Title II] to include Section 101 & 102(b) of H.R. 4868 to provide a conversion mechanism for Rent Supp and RAP properties to a Project-Based Section 8 contract and subsidies [not included]. S 3606-Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2010: A bill providing USDA, FDA and other agencies with appropriations for FY 2011; Title III Rural Development programs, all funding and administrative provisions related to affordable rural housing programs. H.R. 3081 Continuing Appropriations Act, 2011: A bill making continuing appropriations for fiscal year 2011, and for other purposes; all provisions which affect funding and administration of federal multifamily housing programs in Sections 101, 103, 106 and 110. Also requested language in H.R. 3081directing HUD to obligate funds to renew or amend, in a timely manner, all project-based Section 8, Section 202, and Section 811 rental assistance contracts & specifically allowing payments to be made beyond the CR end date [not included]. HR 4868-The Housing Preservation and Tenant Protection Act of 2010: A bill to help preserve federally financed and state-financed affordable housing at risk of conversion to market-rate housing, restore housing at risk of loss due to deterioration, protect residents of affordable housing; preserve troubled projects facing foreclosure, maintain housing affordability, create an affordable housing database, and reform the section 202 and rural housing programs; all provisions. S 118-Section 202 Supportive Housing for the Elderly Act of 2009: A bill to amend section 202 of the Housing Act of 1959 to improve the program under such section for supportive housing for the elderly, and for other purposes; all provisions. HR 2876- Rural Housing Preservation Act of 2009: A bill to establish a program to preserve rural multifamily housing assisted under the Housing Act of 1949; all provisions. HR 1675-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. S 1481-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. HR 1989- The Section 538 Improvement Act of 2009: a bill to provide for subsidies for interest on loans for rural multifamily housing guaranteed by the Rural Housing Service of the Department of Agriculture; all provisions. S 1676- Affordable Housing Preservation and Revitalization Act of 2009: A bill to allow the use of residual receipts from project-based voucher funded properties with expiring contracts to be transferred to nonprofit agencies that commit to preserving the affordable units; all provisions. Draft Legislation from HUD- Preservation, Enhancement, and Transforming Rental Assistance Act of 2010: The legislation would streamline the rental assistance programs would allow public housing and privately owned RAP, Rent Supp, and old Mod Rehab properties to convert to long-term project-based rental assistance, which includes a resident mobility feature; all provisions [not introduced]. HR 3045-The Section 8 Voucher Reform Act of 2009: A bill to reform the housing choice voucher program under section 8 of the United States Housing Act of 1937; all provisions. Requested amendment [to HR 3045] to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds (owners of HUD-subsidized properties are recipents of federal funds) [not included]. Requested free standing legislation, A bill to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds (owners of HUD-subsidized properties are recipents of federal funds) [not introduced during reporting period]. U.S. Department of Housing and Urban Development [Docket No. FR4878N02], Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, Jan. 22, 2007; all provisions. (Owners of HUD-subsidized properties are recipents of federal funds.) HR 5072-FHA Reform Act of 2010: A bill to improve the financial safety and soundness of the FHA mortgage insurance program; Sec. 19 Maximum Mortgage Amount Limits for Multifamily Housing, all provisions related to multifamily housing projects with elevators and extremely high-cost areas. S 3700- A bill to increase the maximum mortgage amount limitations under the Federal Housing Administration mortgage insurance programs for multi-family housing projects with elevators and for extremely high-cost areas; all provisions. HR 3527-The FHA Multifamily Loan Limit Adjustment Act of 2009: A bill increasing the maximum mortgage amount limitations under the FHA mortgage insurance programs for multifamily housing projects with elevators and for extremely high-cost areas; all provisions. HR 2887-Affordable Housing Preservation Tax Relief Act of 2009: A bill to amend the Internal Revenue Code of 1986 to provide an incentive to preserve affordable housing in multifamily housing units which are sold or exchanged; all provisions. HR 4109-Low Income Housing Tax Credit Act of 2009:A bill to amend the Internal Revenue Code to allow the low-income housing credit to be carried back 5 years; all provisions. S 3141-Low Income Housing Tax Credit Recovery Act of 2010: A bill to provide a five-year carry-back for current and future low-income housing tax credit investments and allow LIHTCs to offset 100 percent of federal tax liability; all provisions. HR 2995-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election; all provisions. S 1326-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election; all provisions. HR 4173- Dodd-Frank Wall Street Reform and Consumer Protection Act: A bill to provide financial regulatory reform, protect consumers and investors, enhance Federal understanding of insurance issues, and regulate the over-the-counter derivatives markets; Title XIV Subtitle G, all provisions in Sec. 1481 about the Multifamily Mortgage Resolution Program and in Sec. 1484 about Protecting tenants at foreclosure extension and clarification. S 3793-Job Creation and Tax Cuts Act of 2010. The bill would extend a number of expiring tax provisions; Title II Subtitle B Part II Low-Income Housing Credits, all sections; Title II Subtitle D Part II Subpart b, all provisions of Section 297 Extension of low-income housing credit rules for buildings in GO zones; Title IV, Subtitle A Personal Service Income Earned in Pass-thru Entities, all provisions which affect taxation of managing general partners [affordable multifamily properties are often owned by partnerships]; & Title VI Subtitle A all provisions of Sec. 603 Housing Trust Fund. Requested amendments [to S. 3793] to extend the LIHTC cash exchange program to 4% credits generated from bonds, to provide a 5-year carry-back for the low-income housing tax credit & to change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included]. HR 4766 - Permanently Protecting Tenants at Foreclosure Act of 2010: a bill to permanently extend the Protecting Tenants at Foreclosure Act of 2009 (which allows renters to continue occupying foreclosed properties for a period of time and creates additional protections for tenants receiving Section 8 assistance); all provisions. HR 4106-Green Affordable Housing Act of 2009: The legislation would authorize HUD to create a program to make grants and loans to owners of eligible federally assisted housing projects for making eligible green retrofit improvements to their properties as long as those owners agree to an affordability extension, as determined by HUD, for the building; all provisions. HR 5872- General and Special Risk Insurance Funds Availability Act. The act authorizes an additional $5 billion of commitment authority for FHA to insure mortgages under the General Insurance/Special Risk Insurance (GI/SRI) Fund for multifamily rental and health care facilities; all provisions. HR 4213- American Jobs and Closing Tax Loopholes Act of 2010 (as passed by the House 5/28/10):A bill to extend several expiring tax provisions; all provisions related to affordable multifamily housing in: Title II Sec. 231 Election for Direct Payment of Low-Income Housing Credit for 2010 [not included in final bill]; Title II Section 297 Extension of Low-Income Housing Credit Rules for Buildings in GO Zones [not included in final bill]; Title VI Sec. 412. Income of Partners for Performing Investment Management Services Treated as Ordinary Income Received for Performance of Services (affects ownership structures of some multifamily properties) [not included in final bill]; Title VI Sec. 606 Housing Trust Fund [not included in final bill]. Requested that the Senate add amendments [to H.R.4213] to extend the LIHTC cash exchange program to 4% credits generated from bonds and GO Zone Credits, to provide a 5-year carry-back for the low-income housing tax credit & to change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included]. HR 3929- A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. S. 1761-A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. HR 4687-Low Income Housing Tax Credit Exchange Expansion and Job Creation Act of 2010: A bill to provide grants to States for low-income housing projects in lieu of low-income housing credits; all provisions. S 3326- Job Creation and Affordable Housing Act of 2010: A bill to provide grants to States for low-income housing projects in lieu of low-income housing credits, and to amend the Internal Revenue Code of 1986 to allow a 5-year carryback of the low-income housing credit; all provisions. HR 5297-Small Business Jobs and Credit Act of 2010; Title IV Subtitle A--Small Business Lending Fund, all provisions which provide captial in community banks and qualifying Community Development Financial Institutions (CDFIs) that make loans to small businesses. [In hopes the capital investment would permit these institutions to help meet the pent-up loan demand for construction and permanent financing of affordable rental housing.] HUD Handbook 4381.5, REV-2, Change-3 The Management Agent Handbook Chapter 6, Section 6.38 Management Costs Charged to the Projects Operating Account, all provisions in paragraph (e) related to requirements for Retirement Accounts for Front-Line Staff. HUD Handbook 4350.1 REV-1CHG-2 "Multifamily Asset Management and Project Servicing," Chapter 6: Conducting Management Reviews; all provisions. U.S. Department of Housing and Urban Development "Annual Contributions Contracts, Project-based Section 8 Contract Administration," May 14, 2010; all provisions. U.S. Department of Housing and Urban Development [Docket No. FR5351F02], "Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification SystemAmendments; Final Rule," December 29, 2009; all provisions. U.S. Department of Housing and Urban Development, Notice H 09-20, "Enterprise Income Verification (EIV) System," December 7, 2009; all provisions. U.S. Department of Housing and Urban Development Notice H10-08 "Implementation of Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification System - Amendments; Final Rule," April 13, 2010. U.S. Department of Housing and Urban Development Notice H10-10 "Enterprise Income Verification (EIV) System," July 1, 2010; all provisions. All funding and administrative provisions related to HUD's Big Buy program, which assists affordable multifamily properties in meeting the financial impact of complying with the Lead Safe Housing Rule (24 CFR Part 35). All policies, funding and administrative issues related to managment and preservation of affordable multifamily housing subject to HUD, USDA-RHS and Treasury-IRS regulations. Advocated for timely and accurate Operating Cost Adjustment Factors from HUD (inflation factor applied to rents) & for a HUD mechanism to provide timely relief from unforeseen operating cost increases in HUD assisted properties. Advocated for more timely completions and accurate rents in HUD's mark-up-to-market program. Advocated for a repeal of HUD's policy prohibiting owners of HUD-assisted mixed subsidy properties from using project expenses to pay for Low Income Housing Tax Credit compliance fees mandated by state agencies. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties, especially related to the need for utility and operating cost relief. Advocated for the Department of Housing and Urban Development to revise its policies and handbooks regarding the use of residual receipts. Requested that HUD reinstate 24 CFR 207.260 for insurance loss. Requested follow up from HUD regarding legal concerns over the Office of Affordable Housing Preservation Surplus Cash Analyses on Mark-to-Market properties. Requested guidance from HUD on how to treat tenants' requests to use medical marijuana. All policies related the Department of Housing and Urban Development 2530 previous participation certification policies and submission procedures. All policies related the Department of Housing and Urban Development's Management and Occupancy Review for owners and management agents. All policies related the Department of Housing and Urban Development's Real Estate Assesment Center scoring and procedures for HUD-assisted and/or FHA insured properties. Provided requested recommendations to HUD regarding possible reforms to the Section 202 elderly housing and Section 811 special needs housing programs. Requested clarification from U.S. Department of the Treasury (Treasury) and IRS officials regarding application of income and rent limits for properties financed with low-income housing tax credits (LIHTCs) or tax-exempt bonds (TEBs), pursuant to the "hold harmless" provisions within the Housing and Economic Recovery Act of 2008. U.S. Department of Agriculture-Rural Housing Service, Portfolio Management Division Draft Property Management Performance Assessment Review (would change management fee structure on certain rural affordable properties), May 2009; all provisions. Requested RHS form an "occupancy working group" to address vacancy challenges in affordable rural multifamily properties. Requested that IRS-Treasury, HUD and USDA-RHS form an interagency working group with stakeholder participation to identify and resolve major regulatory conflicts for affordable mixed-subsidy multifamily properties. Provided requested recommendations to the White House Executive Office of the President, HUD, Tresasury-IRS, USDA-RHS regarding the regulatory changes needed to harmonize federal rental assistance programs across agencies.

Client expense: $92,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), SENATE, Treasury, Dept of

H.R. 2454, American Clean Energy and Security Act of 2009, Title II, Subtitle A S. 1462, American Clean Energy Leadership Act, Title II, Subtitle C S. 3464, Practical Energy and Climate Plan of 2010, Title II S. 1637, Expanding Building Efficiency Incentives Act of 2009, A bill to amend the Internal Revenue Code of 1986 to improve and extend certain energy-related tax provisions, and for other purposes. S. 1733, A bill to create clean energy jobs, promote energy independence, reduce global warming pollution, and transition to a clean energy economy. H.R. 4226, Expanding Building Efficiency Incentives Act of 2009, all provisions S 3079, Building Star Energy Efficiency Act of 2010, all provisions H.R. 2336, GREEN Act of 2009, , all provisions H.R.4106, To authorize the Secretary of Housing and Urban Development to make grants and loans to owners of federally assisted housing projects for costs of making green retrofit improvements to such projects. H.R.1908, To amend the Internal Revenue Code of 1986 to provide a credit for property certified by the Environmental Protection Agency under the WaterSense program. S.1321, A bill to amend the Internal Revenue Code of 1986 to provide a credit for property labeled under the Environmental Protection Agency Water Sense program.

Client expense: $380,000 · Firm income: Not reported

H.R. 4868, H.R. 3045, H.R. 4106 and H.R. 4099

Client expense: $5,021 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4868, H.R. 3045, H.R.4106 and H.R. 4099

Client expense: $6,400 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 2454, American Clean Energy and Security Act of 2009, Title II, Subtitle A S. 1462, American Clean Energy Leadership Act, Title II, Subtitle C S. 3464, Practical Energy and Climate Plan of 2010, Title II S. 1637, Expanding Building Efficiency Incentives Act of 2009, A bill to amend the Internal Revenue Code of 1986 to improve and extend certain energy-related tax provisions, and for other purposes. S. 1733, A bill to create clean energy jobs, promote energy independence, reduce global warming pollution, and transition to a clean energy economy. H.R. 4226, Expanding Building Efficiency Incentives Act of 2009, all provisions S 3079, Building Star Energy Efficiency Act of 2010, all provisions H.R.5019, Home Star Energy Retrofit Act of 2010, all provisions S.3177, Home Star Energy Retrofit Act of 2010, all provisions H.R. 2336, GREEN Act of 2009, , all provisions H.R.4106, To authorize the Secretary of Housing and Urban Development to make grants and loans to owners of federally assisted housing projects for costs of making green retrofit improvements to such projects. H.R.1908, To amend the Internal Revenue Code of 1986 to provide a credit for property certified by the Environmental Protection Agency under the WaterSense program. S.1321, A bill to amend the Internal Revenue Code of 1986 to provide a credit for property labeled under the Environmental Protection Agency Water Sense program.

Client expense: $550,000 · Firm income: Not reported

Budget of the United States Government, Fiscal Year 2011; all provisions relating to the U.S. Department of Housing and Urban Development (HUD) and U.S. Department of Agriculture-Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service proposals related to the Low Income Housing Tax Credit and bond-financed multifamily housing programs. (continued) HR 4868-The Housing Preservation and Tenant Protection Act of 2010: A bill to help preserve federally financed and state-financed affordable housing at risk of conversion to market-rate housing, restore housing at risk of loss due to deterioration, protect residents of affordable housing; preserve troubled projects facing foreclosure, maintain housing affordability, create an affordable housing database, and reform the section 202 and rural housing programs; all provisions. S 118-Section 202 Supportive Housing for the Elderly Act of 2009: A bill to amend section 202 of the Housing Act of 1959 to improve the program under such section for supportive housing for the elderly, and for other purposes; all provisions. HR 2876- Rural Housing Preservation Act of 2009: A bill to establish a program to preserve rural multifamily housing assisted under the Housing Act of 1949; all provisions. HR 1675-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. S. 1481-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. HR 1989- The Section 538 Improvement Act of 2009: a bill to provide for subsidies for interest on loans for rural multifamily housing guaranteed by the Rural Housing Service of the Department of Agriculture; all provisions. HR 3045-The Section 8 Voucher Reform Act of 2009: A bill to reform the housing choice voucher program under section 8 of the United States Housing Act of 1937; all provisions. Requested amendment [to HR 3045] to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds (owners of HUD-subsidized properties are recipents of federal funds) [not included]. Requested free standing legislation, A bill to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds (owners of HUD-subsidized properties are recipents of federal funds) [not introduced during reporting period]. U.S. Department of Housing and Urban Development [Docket No. FR4878N02], Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, Jan. 22, 2007; all provisions. (Owners of HUD-subsidized properties are recipents of federal funds.) HR 476- Fair Housing Fairness Act: A bill to authorize $20 million for each of the next five years to allow HUD to test for discrimination in home buying, renting, or financing; all provisions. HR 4099- Energy Efficiency Modernization Act of 2009: A bill to establish incentives to increase the energy efficiency of federally assisted housing; all provisions. S. 2897 - Energy Efficiency Modernization Act of 2009: A bill to establish incentives to increase the energy efficiency of federally assisted housing. S 1676- Affordable Housing Preservation and Revitalization Act of 2009: A bill to allow the use of residual receipts from project-based voucher funded properties with expiring contracts to be transferred to nonprofit agencies that commit to preserving the affordable units; all provisions. HR 3897-Removing Reward for Section 8 Fraud Act of 2009:A bill to close a loophole that allows Project-Based Section 8 properties to lower rents for families who are repaying the government when welfare fraud has been detected; all provisions. HR 5072-FHA Reform Act of 2010: A bill to improve the financial safety and soundness of the FHA mortgage insurance program; Sec. 19 Maximum Mortgage Amount Limits for Multifamily Housing, all provisions related to multifamily housing projects with elevators and extremely high-cost areas. HR 3527-The FHA Multifamily Loan Limit Adjustment Act of 2009: A bill increasing the maximum mortgage amount limitations under the FHA mortgage insurance programs for multifamily housing projects with elevators and for extremely high-cost areas; all provisions. H.R. 2336-The Green Resources for Energy Efficient Neighborhoods (GREEN) Act of 2009:A bill to encourage energy efficiency and conservation and development of renewable energy sources for housing, commercial structures, and other buildings, and to create sustainable communities; all provisions. HR 2887-Affordable Housing Preservation Tax Relief Act of 2009: A bill to amend the Internal Revenue Code of 1986 to provide an incentive to preserve affordable housing in multifamily housing units which are sold or exchanged; all provisions. H.R. 4849-Small Business and Infrastructure Jobs Tax Act of 2010: A bill to provide tax incentives for small business job creation, extend the Build America Bonds program, and provide other infrastructure job creation tax incentives; Title II Section 204, Elective Payments in lieu of Low Income Housing Credits, all provisions authorizing elective payments (cash exchange) in lieu of LIHTCs for bond-financed buildings. HR 3641-Military Families Affordable Homes Act:A bill to simplify by the process for determining eligibility for a military housing allowance exclusion from income in a LIHTC property; all provisions. S 2827-Military Families Affordable Homes Act:A bill to simplify by the process for determining eligibility for a military housing allowance exclusion from income in a LIHTC property; all provisions. S. 1637-Expanding Building Efficiency Incentives Act of 2009: A bill to extend the existing new energy efficient home tax credit (section 45L) and allow it to be used more effectively with affordable multifamily housing; all provisions. HR 4109-Low Income Housing Tax Credit Act of 2009:A bill to amend the Internal Revenue Code to allow the low-income housing credit to be carried back 5 years; all provisions. S. 3141-Low Income Housing Tax Credit Recovery Act of 2010: A bill to provide a five-year carry-back for current and future low-income housing tax credit investments and allow LIHTCs to offset 100 percent of federal tax liability; all provisions. HR 2995-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election; all provisions. S 1326-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election; all provisions. H.R. 4173- Dodd-Frank Wall Street Reform and Consumer Protection Act: A bill to provide financial regulatory reform, protect consumers and investors, enhance Federal understanding of insurance issues, and regulate the over-the-counter derivatives markets; Title XIV, Subtitle G, all provisions in Sec. 1481 about the Multifamily Mortgage Resolution Program and in Sec. 1484 about Protecting tenants at foreclosure extension and clarification. HR 1935 -To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services; all provisions (affordable multifamily properties are often owned by partnerships in which the managing general partner assumes greater liablity for the property's compliance and management). H.R. 4106-Green Affordable Housing Act of 2009: The legislation would authorize HUD to create a program to make grants and loans to owners of eligible federally assisted housing projects for making eligible green retrofit improvements to their properties as long as those owners agree to an affordability extension, as determined by HUD, for the building; all provisions. Requested an additional $5 billion of commitment authority for FHA to insure mortgages under the General Insurance/Special Risk Insurance (GI/SRI) Fund for multifamily rental and health care facilities from the House Appropriations Committee on the first available vehicle. HR 4213- American Workers, State, and Business Relief Act of 2010 (as passed by the Senate 3/10/10):A bill to extend several expiring tax provisions; all provisions related to affordable multifamily housing in: Title I Sec. 121 Election for Refundable Low-Income Housing Credit for 2010; Title VI Sec. 604 Extension of Low-Income Housing Credit Rules for Buildings in GO Zones; Title VI Sec. 608 Election of Refundable Low Income Housing Credit for 2010 and Title VI Sec. 609 Low-Income Housing Grant Election. Requested amendments [to H.R.4213] to extend the LIHTC cash exchange program to 4% credits generated from bonds, to provide a 5-year carry-back for the low-income housing tax credit & to change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included]. HR 4213- American Jobs and Closing Tax Loopholes Act of 2010 (as passed by the House 5/28/10):A bill to extend several expiring tax provisions; all provisions related to affordable multifamily housing in: Title II Sec. 231 Election for Direct Payment of Low-Income Housing Credit for 2010; Title II Section 297 Extension of Low-Income Housing Credit Rules for Buildings in GO Zones; Title VI Sec. 412. Income of Partners for Performing Investment Management Services Treated as Ordinary Income Received for Performance of Services (affects ownership structures of some multifamily properties); Title VI Sec. 606 Housing Trust Fund. Requested amendments [to H.R.4213] to extend the LIHTC cash exchange program to 4% credits generated from bonds and GO Zone Credits, to provide a 5-year carry-back for the low-income housing tax credit & to change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included]. HR 3929- A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. S. 1761-A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. H.R. 4687-Low Income Housing Tax Credit Exchange Expansion and Job Creation Act of 2010: A bill to extend the LIHTC cash-exchange program for 2010 9 percent tax credits (Section 1602 from ARRA) and expand the program to include 4 percent LIHTCs; all provisions. S 3326- Job Creation and Affordable Housing Act of 2010: A bill to provide grants to States for low-income housing projects in lieu of low-income housing credits, and to amend the Internal Revenue Code of 1986 to allow a 5-year carryback of the low-income housing credit; all provisions. H.R. 4766-Permanently Protecting Tenants at Foreclosure Act of 2010: A bill to permanently extend the law that allows renters whose landlords have lost their properties to foreclosure the right to stay in the home for 90 days after the foreclosure or through the term of their lease, unless the property is sold to someone who will occupy the home; all provisions. Draft Legislation from HUD- Preservation, Enhancement, and Transforming Rental Assistance Act of 2010: The legislation would streamline the rental assistance programs would allow public housing and privately owned RAP, Rent Supp, and old Mod Rehab properties to convert to long-term project-based rental assistance, which includes a resident mobility feature; all provisions [not introduced]. U.S. Department of Housing and Urban Development [Docket No. FR5351F02], "Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification SystemAmendments; Final Rule," December 29, 2009; all provisions. Department of the Treasury-Internal Revenue Service Notice 2009-44 "Part III - Administrative, Procedural and Miscellaneous, Section 42. Low-Income Housing Credit," May 26, 2009; clarifies when utility submetering is permissible in Low Income Housing Tax Credit properies under the Section 42 utility allowance rules; all provisions. Department of Housing and Urban Development "Annual Contributions Contracts, Project-based Section 8 Contract Administration," May 14, 2010; all provisions. Department of Housing and Urban Development Office of Housing Assistance Contract Administration Oversight Draft Overview of Key Elements of Invitation for Submission of Applications for Contract Administrators and Annual Contributions Contract Revisions, January 26, 2010; all provisions. Department of Housing and Urban Development Public and Indian Housing Notice 2009-51: "PHA Determinations of Rent Reasonableness in the Housing Choice Voucher (HCV) Program Comparable Unassisted Units in the Premises," December 11, 2009; all provisions. Department of Housing and Urban Development Public and Indian Housing Notice PIH 2010- 18:"Revision to HUD Notice PIH 2009-51 PHA Determinations of Rent Reasonableness in the Housing Choice Voucher (HCV) Program Comparable Unassisted Units in the Premises," May 10, 2010; all provisions. Department of Housing and Urban Development Multifamily Housing Notice H2010-04: "Revised Protocol for Placing a Flag in the Active Partners Performance System (APPS) When a Property Receives a Physical Inspection Score Below 60 but Above 30," January 22, 2010; all provisions. HUD Handbook 4381.5, REV-2, Change-3 The Management Agent Handbook Chapter 6, Section 6.38 Management Costs Charged to the Projects Operating Account, all provisions in paragraph (e) related to requirements for Retirement Accounts for Front-Line Staff. HUD Handbook 4350.1 REV-1CHG-2 "Multifamily Asset Management and Project Servicing," Chapter 6: Conducting Management Reviews; all provisions. All funding and administrative provisions related to HUD's Big Buy program, which assists affordable multifamily properties in meeting the financial impact of complying with the Lead Safe Housing Rule (24 CFR Part 35). Urged HUD to provide greater transparency & opportunites for public comment in its policy development procedures and to improve communication with industry partners on policy determinations or interpretations that affect regulatory compliance. All policies, funding and administrative issues related to managment of affordable multifamily housing subject to HUD, USDA-RHS and Treasury-IRS regulations. Advocated for preservation of affordable multifamily housing participating in HUD, USDA-RHS programs or financed through Treasury-IRS Low Income Housing Tax Credit or bond programs. Advocated for timely and accurate Operating Cost Adjustment Factors from HUD (inflation factor applied to rents) & for a HUD mechanism to provide timely relief from unforeseen operating cost increases in HUD assisted properties. Advocated for more timely completions and accurate rents in HUD's mark-up-to-market program. Advocated for a repeal of HUD's policy prohibiting owners of HUD-assisted mixed subsidy properties from using project expenses to pay for Low Income Housing Tax Credit compliance fees mandated by state agencies. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties, especially related to the need for utility and operating cost relief. Advocated for the Department of Housing and Urban Development to revise its policies and handbooks regarding the use of residual receipts and requested HUD to reinstate 24 CFR 207.260 for insurance loss. U.S. Department of Housing and Urban Development, Notice H 09-20, "Enterprise Income Verification (EIV) System," December 7, 2009; all provisions. U.S. Department of Agriculture-Rural Housing Service, Portfolio Management Division Draft Property Management Performance Assessment Review (would change management fee structure on certain rural affordable properties), May 2009; all provisions. Requested that the Department of Agriculture-Rural Housing Service seek authority to join the necessary interagency agreements which would allow use of the Enterprise Income Verification income matching system for tenant income verification necessary for RHS multifamily housing programs. Requested that IRS-Treasury, HUD and USDA-RHS form an interagency working group with stakeholder participation to identify and resolve major regulatory conflicts for affordable mixed-subsidy multifamily properties. Provided requested recommendations to the White House Executive Office of the President, HUD, Tresasury-IRS, USDA-RHS regarding the regulatory changes needed to harmonize federal rental assistance programs across agencies. Requested guidance from HUD on how to treat tenants' requests to use medical marijuana. All policies related the Department of Housing and Urban Development 2530 previous participation certification policies and submission procedures. All policies related the Department of Housing and Urban Development's Management and Occupancy Review for owners and management agents. All policies related the Department of Housing and Urban Development's Real Estate Assesment Center scoring and procedures for HUD-assisted and/or FHA insured properties. Provided requested recommendations to HUD regarding needed reforms to the Section 202 elderly housing and Section 811 special needs housing programs. Provided requested recommendations to HUD and EPA regarding energy efficiency reforms to the Section 202 elderly housing and Section 811 special needs housing programs.

H.R. 1780, Smart Planning for Smart Growth of 2009 H.R. 1778, Retrofit for Energy and Environment Performance (REEP) Act H.R. 2454, American Clean Energy and Security Act of 2009 H.R. 2998, American Clean Energy and Security Act of 2009 H.R. 2336, Green Act of 2009 S. 598, Appliance Standards Improvement Act of 2009 S.1379, A bill to encourage energy efficiency and conservation and development of renewable energy sources for housing, commercial structures, and other buildings, and to create sustainable communities. S. 1462, An original bill to promote clean energy technology development, enhanced energy efficiency, improved energy security, and energy innovation and workforce development, and for other purposes. S. 1637, A bill to amend the Internal Revenue Code of 1986 to improve and extend certain energy-related tax provisions, and for other purposes. S. 1733, A bill to create clean energy jobs, promote energy independence, reduce global warming pollution, and transition to a clean energy economy. S. 2899, Renewable Energy Incentive Act S. 1637, Expanding Building Efficiency Incentives Act of 2009 H.R. 4256, Sustainable Property Grants Act of 2009 H.R. 4226, Expanding Building Efficiency Incentives Act of 2009 S 3079, Building Star Energy Efficiency Act of 2010 H.R.5019, Home Star Energy Retrofit Act of 2010 S.3177, Home Star Energy Retrofit Act of 2010 H.R. 2336, GREEN Act of 2009 H.R.4099, Energy Efficiency Modernization Act of 2009 H.R. 2847, Jobs for Main Street Act H.R. 2454, American Clean Energy and Security Act of 2009 PACE Bonds H.R. 3836, To authorize the Secretary of Energy to provide credit support to enhance the availability of private financing for clean energy technology deployment. H.R. 4155, Property Assessed Clean Energy Tax Benefits Act of 2009 H.R.4106, To authorize the Secretary of Housing and Urban Development to make grants and loans to owners of federally assisted housing projects for costs of making green retrofit improvements to such projects. H.R.1908, To amend the Internal Revenue Code of 1986 to provide a credit for property certified by the Environmental Protection Agency under the WaterSense program. H.R.3747, To promote water efficiency, conservation, and adaptation, and for other purposes. S.1321, A bill to amend the Internal Revenue Code of 1986 to provide a credit for property labeled under the Environmental Protection Agency Water Sense program.

H.R. 4868, H.R. 3045, H.R. 4106 and H.R. 4099

Client expense: $6,050 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE

-H.R. 4106, "Green Affordable Housing Act of 2009"

Client expense: $84,500 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Budget of the United States Government, Fiscal Year 2010; all provisions relating to the U.S. Department of Housing and Urban Development (HUD) and U.S. Department of Agriculture-Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service proposals related to the Low Income Housing Tax Credit and bond-financed multifamily housing programs. (continued) H.R. 3288-FY 2010 Consolidated Appropriations Act: A bill making appropriations for: Transportation-HUD; Commerce-Justice-Science; Financial Services; Labor-HHS; Military Construction-VA; and State-Foreign Operations, and related agencies for the fiscal year ending September 30, 2010, and for other purposes; Division A, Title II Housing and Urban Development; - all funding and administrative provisions related to affordable housing programs, with particular emphasis on full funding of 12 month terms of project-based Section 8 contracts and fair housing activities to create translations and programs to assist persons with limited English proficiency (LEP). Requested amendments [to H.R. 3288, Title II] to fully fund project-based Section 8 contracts [included], exempt multifamily property owners who received Project-Based Section 8 funding from the American Recovery and Reinvestment Act (ARRA, P.L. 111-5) from ARRA's Section 1512 reporting requirements (which requires recipients to report their project plan, the number of jobs created or retained, salaries of highest paid employees) and Section 1609 environmental review reporting requirements [not included], funding &/or report language for HUD's Big Buy program, which was to assist property owners with compliance costs of the Lead Safe Housing Rule [not included], & maintaining $500,000 line item for LEP translations and services [included]. H.R. 2997-Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations Act, 2010: A bill providing USDA, FDA and other agencies with appropriations for FY 2010; Title III Rural Development programs, all funding and administrative provisions related to affordable rural housing programs. Also requested amendments [to HR 2997] authorizing use of the Enterprise Income Verification income matching system for tenant income verification in RHS multifamily housing programs [not included]; & reinstating interest subsidy to Section 538 program [not included]. H.R. 2996- the FY 2010 Interior-Environment and Related Agencies Appropriations Act: A bill making appropriations for the Department of the Interior, environment, and related agencies (including a continuing resolution for FY 2009 appropriations until December 18, 2009); Division B Continuing Appropriations Resolution, 2010, Section 104 all provisions to prevent the termination of housing assistance to families with Housing Choice Vouchers in the new Section 169. Requested amendments [to HR 2996, Division B] to fully fund project-based Section 8 contracts[partial funding provided through Section 101, which included an extension for HUD funding under the continuing resolution], exempt multifamily property owners who received Project-Based Section 8 funding from the American Recovery and Reinvestment Act (ARRA, P.L. 111-5) from ARRA's Section 1512 reporting requirements (which requires recipients to report their project plan, the number of jobs created or retained, salaries of highest paid employees) and Section 1609 environmental review reporting requirements [not included], funding for HUD's Big Buy program, which was to assist property owners with compliance costs of the Lead Safe Housing Rule &/or committee report language [not included] & including the $500,000 line item for LEP translations &services [in HR 3288]. H.R. 1989- The Section 538 Improvement Act of 2009: a bill to provide for subsidies for interest on loans for rural multifamily housing guaranteed by the Rural Housing Service of the Department of Agriculture; all provisions. H.R. 2876- Rural Housing Preservation Act of 2009: A bill to establish a program to preserve rural multifamily housing assisted under the Housing Act of 1949; all provisions. H.R. 1675-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. S. 1481-Frank Melville Supportive Housing Investment Act of 2009: A bill to amend Section 811 to improve the housing for persons with disabilities program; all provisions. S. 118-Section 202 Supportive Housing for the Elderly Act of 2009: A bill to amend section 202 of the Housing Act of 1959 to improve the program under such section for supportive housing for the elderly, and for other purposes; all provisions. H.R. 3045-The Section 8 Voucher Reform Act of 2009: A bill to reform the housing choice voucher program under section 8 of the United States Housing Act of 1937; all provisions. Requested amendment [to HR 3045] to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds (owners of HUD-subsidized properties are recipents of federal funds) [not included]. H.R. 476- Fair Housing Fairness Act: A bill to authorize $20 million for each of the next five years to allow HUD to test for discrimination in home buying, renting, or financing; all provisions. Requested free standing legislation, A bill to allow the Department of Housing and Urban Development to Better Serve Persons with Limited Proficiency in the English Language by Providing Technical Assistance to Recipients of Federal Funds(owners of HUD-subsidized properties are recipents of federal funds) [not introduced during reporting period]. HR 2887-Affordable Housing Preservation Tax Relief Act of 2009: A bill to amend the Internal Revenue Code of 1986 to provide an incentive to preserve affordable housing in multifamily housing units which are sold or exchanged; all provisions. HR 2995-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election;all provisions. S 1326-The Disaster State Housing Recovery Act of 2009: To amend the American Recovery and Reinvestment Tax Act of 2009 to clarify the low-income housing credits that are eligible for the low-income housing grant election;all provisions. HR 3527-The FHA Multifamily Loan Limit Adjustment Act of 2009: A bill increasing the maximum mortgage amount limitations under the FHA mortgage insurance programs for multifamily housing projects with elevators and for extremely high-cost areas;all provisions. HR 2847- Jobs for Main Street Act of 2010: A bill providing additional appropriations for federal programs to boost the number of jobs in the economy; Division A, Title I, Chapter 6 Transportation and Housing and Urban Development, Department of Housing and Urban Development, Community Planning & Development, all provisions about the Housing Trust Fund. Requested amendments [none included] to extend the low-income housing tax credit Section 1602 cash exchange by 1 year, provide a 5 year carryback to the LIHTC and change passive loss laws to allow certain S corportations, limited liablity companies, and closely held C Corporations as LIHTC investors. HR 3766- Main Street TARP Act of 2009: A bill using amounts made available under the Troubled Assets Relief Program to provide relief to homeowners and affordable rental housing; Section 2 Housing Trust Fund all provisions about the HTF. HR 4099- Energy Efficiency Modernization Act of 2009: A bill to establish incentives to increase the energy efficiency of federally assisted housing; all provisions. HR 4106- Green Affordable Housing Act of 2009: A bill to authorize HUD to create a program to offer grants and loans to owners of federally assisted housing projects for costs of making green retrofit improvements; all provisions. S 1676- Affordable Housing Preservation and Revitalization Act of 2009: A bill to allow the use of residual receipts from project-based voucher funded properties with expiring contracts to be transferred to nonprofit agencies that commit to preserving the affordable units; all provisions. S 1731- Preserving Homes and Communities Act of 2009:A bill to provide grants and subsidized loans to states for homeowners in default and authorizes appropriations; Section 6 all provisions about the Housing Trust Fund. S 1733- Clean Energy Jobs and American Power Act: A bill to reduce U.S. greenhouse gas emissions; Division A, Title I, Subtitle F, Sec. 163. Energy Efficiency in Building Codes all provisions applicable to multifamily properties & Sec. 164 Retrofit for Energy and Environmental Performance, all provisions for a multifamily housing retrofit program. HR 3641-Military Families Affordable Homes Act:A bill to simplify by the process for determining eligibility for a military housing allowance exclusion from income in a LIHTC property; all provisions. S 2827-Military Families Affordable Homes Act:A bill to simplify by the process for determining eligibility for a military housing allowance exclusion from income in a LIHTC property; all provisions. HR 4109-Low Income Housing Tax Credit Act of 2009:A bill to amend the Internal Revenue Code to allow the low-income housing credit to be carried back 5 years; all provisions. H.R. 3897-Removing Reward for Section 8 Fraud Act of 2009:A bill to close a loophole that allows Project-Based Section 8 properties to lower rents for families who are repaying the government when welfare fraud has been detected; all provisions. HR 3793- Healthy Housing Council Act of 2009: A bill to establish an interagency council on Healthy Homes; all provisions. S. 1658- Healthy Housing Council Act of 2009: A bill to establish an interagency council on Healthy Homes; all provisions. HR 3929- A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. & S. 1761-A bill to provide an extension of the low-income housing credit placed-in-service date requirement for certain disaster areas; all provisions. S. 1861-A bill to amend the Internal Revenue Code of 1986 to provide a 2-year extension of the increased rehabilitation credit for structures in the Gulf Opportunity Zone; all provisions to benefit multifamily properties. H.R. 4173-Wall Street Reform and Consumer Protection Act of 2009:A bill to provide financial regulatory reform, protect consumers and investors, enhance Federal understanding of insurance issues, and regulate the over-the-counter derivatives markets; Title VII, Subtitle I, Section 9801 all provisions about the Multifamily Mortgage Resolution Program. H.R.3548-Worker, Homeownership, and Business Assistance Act of 2009. A bill to amend the Supplemental Appropriations Act, 2008 to provide for the temporary availability of certain additional emergency unemployment compensation; Sec. 13. 5-Year Carryback of Operating Losses. Requested amendments [to H.R.3548] to provide a 5-year carry-back for the low-income housing tax credit, extend Treasurys Section 1602 LIHTC cash-exchange program for 1 year & change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included]. HR 4213-The Tax Extenders Act of 2009:A bill to extend several expiring tax provisions; Title II, Sec. 207 Election for Refundable Low-Income Housing Credit for 2010, all provisions to extend the Section 1602 LIHTC cash exchange program. Requested amendments [to H.R.4213] to provide a 5-year carry-back for the low-income housing tax credit & change passive loss laws to include certain S Corporations, limited liability companies, & closely-held C Corporations as LIHTC investors. [none included] H.R. 2336-The Green Resources for Energy Efficient Neighborhoods (GREEN) Act of 2009:A bill to encourage energy efficiency and conservation and development of renewable energy sources for housing, commercial structures, and other buildings, and to create sustainable communities; all provisions. H.R. 2454-The American Clean Energy Security Act of 2009: A bill to create clean energy jobs, achieve energy independence, reduce global warming pollution and transition to a clean energy economy; Title II Subtitle H, Green Resources for Energy Efficient Neighborhoods all provisions related to multifamily housing. H.R.3715-Community Restoration and Revitalization Act of 2009: To amend the Internal Revenue Code of 1986 to expand the rehabilitation credit; all provisions applicable to multifamily properties. & S.1743-A bill to amend the Internal Revenue Code of 1986 to expand the rehabilitation credit;all provisions applicable to multifamily properties. Preliminary draft legislation, Housing Preservation and Tenant Protection Act of 2009; a bill to prevent loss of affordable dwelling units; all provisions [not introduced during reporting period]. Preliminary draft legislation, Real Estate Assessment Center Inspection Improvement Act: To improve inspections of public housing and federally assisted multifamily housing conducted by the Real Estate Assessment Center of the Department of Housing and Urban Development;all provisions [not introduced during reporting period]. Requested legislation, Mark-to-Market Extension and Enhancement Act: A bill to extend the Mark-to-Market program of the Department of Housing and Urban Development, and for other purposes;all provisions [not introduced during reporting period]. U.S. Department of Housing and Urban Development [Docket No. FR-4998-F-02], Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs; Final Rule, Jan. 27, 2009;all provisions. U.S. Department of Housing and Urban Development [Docket No. FR4998F05], Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Delay of Effective Date,August 28, 2009;all provisions. U.S. Department of Housing and Urban Development [Docket No. FR4878N02], Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, Jan. 22, 2007; all provisions. (Owners of HUD-subsidized properties are recipents of federal funds.) Department of the Treasury-Internal Revenue Service Notice 2009-44 "Part III - Administrative, Procedural and Miscellaneous, Section 42. Low-Income Housing Credit," May 26, 2009; clarifies when utility submetering is permissible in Low Income Housing Tax Credit properies under the Section 42 utility allowance rules; all provisions. U.S. Treasury Department Office of the Fiscal Assistant Secretary, "Application and Terms and Conditions:Grants to States for Low-Income Housing Projects in Lieu of Low-Income Housing Credits for 2009 under the American Recovery and Reinvestment Act of 2009," May 2009; all provisions [guidance for implmenting Section 1602 of the American Recovery and Reinvestment Act of 2009, a Low Income Housing Tax Credit gap-financing program which exchanges LIHTCs for cash]. U.S. Department of Housing and Urban Development Community Planning and Development Notice: CPD-09-03 "Implementation of the Tax Credit Assistance Program (TCAP)," May 4, 2009; all provisions [guidance for implementing gap financing assistance to Low Income Housing Tax Credit properties through the HOME Investment Partnership Program authorized by he American Recovery and Reinvestment Act of 2009]. Office of Management and Budget Memoradum to the Heads of All Departments and Agencies M-09-21: "Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009," June 22, 2009; all provisions which affected owners of apartments who received ARRA Project-Based Section 8 appropriations to fund their HAP contracts (these owners were considered recipients and were required to report on use of funds under Division A, Title XV, Sec. 1512 of ARRA (P.L. 111-5). Recovery Accountability and Transparency Board Office of the General Counsel Docket No. FR31AU09-47: "Proposed Information Collection Activities, Title of Collection: FederalReporting.Gov Recipient Registration Sytem," August 31, 2009; all provisions which affected owners of apartments who received ARRA Project-Based Section 8 appropriations to fund their HAP contracts (these owners were considered recipients and were required to report on use of funds under Division A, Title XV, Sec. 1512 of ARRA (P.L. 111-5) and potentially Division A, Title XVI, Section 1609 environmental review reporting requirements.) Advocated for the Office of Management and Budget and the Department of Housing and Urban Development to provide Project-Based Section 8 owners who received Project-Based Section 8 appropriations to fund their HAP contracts from the American Recovery and Reinvestment Act (P.L. 111-5) a waiver from the Section 1512 reporting requirements for use of funds and job calculations and Section 1609 environmental review reporting requirements. Also requested that OMB extend the filing deadline for the Section 1512 reporting requirements for the October 2009 reporting period for apartment owners who got Project-Based Section 8 appropriations for their HAP contracts from the ARRA (P.L. 111-5). Department of Housing and Urban Development Docket No. FR5323N01:"Request for Comments on Ending Hold Harmless Policy in Calculating Income Limits Under Section 8 of the United States Housing Act of 1937," September 14, 2009; all provisions. Department of Housing and Urban Development Office of Housing Assistance Contract Administration Oversight Draft Framework for the Revised Performance Based Contract Administrators Annual Contributions Contracts, October 20, 2009; all provisions. Department of Housing and Urban Development Public and Indian Housing Notice 2009-51: "PHA Determinations of Rent Reasonableness in the Housing Choice Voucher (HCV) Program Comparable Unassisted Units in the Premises," December 11, 2009; all provisions. HUD Handbook 4381.5, REV-2, Change-3 The Management Agent Handbook Chapter 6, Section 6.38 Management Costs Charged to the Projects Operating Account, all provisions in paragraph (e) related to requirements for Retirement Accounts for Front-Line Staff. HUD Handbook 4350.1 REV-1CHG-2 "Multifamily Asset Management and Project Servicing," Chapter 6: Conducting Management Reviews; all provisions. All funding and administrative provisions related to HUD's Big Buy program, which assists affordable multifamily properties in meeting the financial impact of complying with the Lead Safe Housing Rule (24 CFR Part 35). Urged HUD to provide greater transparency & opportunites for public comment in its policy development procedures and to improve communication with industry partners on policy determinations or interpretations that affect regulatory compliance. All policies, funding and administrative issues related to managment of affordable multifamily housing subject to HUD, USDA-RHS and Treasury-IRS regulations. Advocated for preservation of affordable multifamily housing participating in HUD, USDA-RHS programs or financed through Treasury-IRS Low Income Housing Tax Credit or bond programs. All policies related the Department of Housing and Urban Development 2530 previous participation certification policies and submission procedures. Advocated for timely and accurate Operating Cost Adjustment Factors from HUD (inflation factor applied to rents) & for a HUD mechanism to provide timely relief from unforeseen operating cost increases in HUD assisted properties. Advocated for more timely completions and accurate rents in HUD's mark-up-to-market program. Advocated for a repeal of HUD's policy prohibiting owners of HUD-assisted mixed subsidy properties from using project expenses to pay for Low Income Housing Tax Credit compliance fees mandated by state agencies. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties, especially related to the need for utility and operating cost relief. Advocated for the Department of Housing and Urban Development to revise its policies and handbooks regarding the use of residual receipts and requested HUD to reinstate 24 CFR 207.260 for insurance loss. U.S. Department of Agriculture-Rural Housing Service, Portfolio Management Division Draft Property Management Performance Assessment Review (would change management fee structure on certain rural affordable properties), May 2009; all provisions. Requested that the Department of Agriculture-Rural Housing Service and Internal Revenue Service seek authority to join the necessary interagency agreements which would allow use of the Enterprise Income Verification income matching system for tenant income verification necessary for RHS and IRS' multifamily housing programs Requested that IRS-Treasury, HUD and USDA-RHS form an interagency working group with stakeholder participation to identify and resolve major regulatory conflicts for affordable mixed-subsidy multifamily properties. Offered input on Draft 2010-2015 U.S. Department of Housing and Urban Development Strategic Plan; all provisions. Provided input in the HUD/DHS-FEMA Long Term Disaster Recovery Working Group for consideration in the White House Working Group Report to the President (on strengthing long-term disaster recovery) & the draft National Disaster Recovery Framework; all provisions related to federal rental assistance programs. Requested guidance from HUD on how to treat tenants' requests to use medical marijuana.