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16-19RESOLUTION 16 -19 A RESOLUTION OF THE CITY OF CLEARWATER, FLORIDA, ADOPTING THE CITY OF CEARWATER THREE -YEAR HOUSING TRUST FUND PLAN COVERING FISCAL YEARS 2016 -2017 THROUGH 2018 -2019; PROVIDING AN EFFECTIVE DATE. WHEREAS, the City of Clearwater has established the FY 2016 -2017 through FY 2019 -2020 Consolidated Plan which identifies goals, objectives and strategies to develop viable urban communities by providing decent housing and suitable living environment and to expand economic opportunities principally for very-low to moderate - income persons /household; and, WHEREAS, the Clearwater City Council approved the Four -Year Consolidated Plan covering fiscal years 2016 -2017 through 2019 -2020 at their July 21, 2016 meeting; and, WHEREAS, the Consolidated Plan has established affordable housing as its highest priority; and, WHEREAS, Pinellas County Board of County Commissioners established a Housing Trust Fund (Ordinance No. 06 -28) to implement the Housing Trust Fund Program for the development and provision of affordable housing; and, WHEREAS, the City of Clearwater has established a Housing Trust Fund Plan under an agreement with Pinellas County Housing Finance Authority; and, WHEREAS, the City of Clearwater has established a Housing Trust Fund from which funds are allocated; and, WHEREAS, the Housing Trust Fund Plan provides that ten percent (10 %) of the total housing trust program income will be used for administrative expenses; and, WHEREAS, the funds distributed through the Housing Trust Fund Plan must: be leveraged at a minimum of 2:1; set aside a minimum of fifteen percent (15 %) of the funds for persons with special needs or persons earning thirty percent (30 %) or less of the area median income; and maintain that eighty percent (80 %) of the funds will be utilized as non - forgiven loans that generate program income; NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF CLEARWATER, FLORIDA: Resolution No. 16 -19 Section 1. The City of Clearwater hereby adopts the attached Housing Trust Fund Plan covering Fiscal Years 2016 -2017 through 2018 -2019. Section 2. This resolution shall take effect immediately upon adoption. PASSED AND ADOPTED this 1 stday of SPnthmhpr , 2016. Approved as to form: Laura Mahony Assistant City Attorney George N. Cretekos, Mayor Attest: 6-.10 / • ,[.�� Rosemarie Call, City Clerk Resolution No. 16 -19 HOUSING FINANCE AUTHORITY, PINELLAS COUNTY, FLORIDA City of Clearwater, Florida Local Housing Assistance Plan . Name of Participating Jurisdiction: City of Clearwater 2. Contact Person: Terry Malcolm -Smith Title: Housing Coordinator Address: P.O. Box 4748, Clearwater, Florida 33756 Telephone: 727-562-4036 E -mail: terry. malcolm- smith(a�myclearwater.com 3. Program Years Covered by Plan: FY 2016 -2017, 2017 -2018 and 2018 -2019 4. Narrative describing advertising plan (Rules, Section 3(6)(a)): In accordance with the referenced Rule, upon approval of this Plan by the Housing Finance Authority, the City of Clearwater will advertise the availability of the Plan for public viewing in a newspaper of general circulation and periodicals servicing ethnic and diverse neighborhoods at least 30 days before the beginning of the application period. This advertisement will also contain a Notice of Funding Availability and information about the application process for these funds. In addition, the advertisement will include the amount of program income projected to be received for the plan year, the beginning and end date of the application period and the name of the contact person and other pertinent information. Applications for the development of housing units will be considered on an on- going basis. Advertising will also be displayed on the city's Housing Department website and through press releases. 5. Narrative describing involvement of other public and private sector entities and partners: The city has established local housing partnerships and resources to increase the affordability of housing through down payment and closing costs assistance, low interest rate mortgage loans, grants and other direct subsidies that make market rate housing affordable to lower income households. Special interest rates, product pricing structures, special programs and other incentives are offered by lenders and real estate professionals to enhance affordability. All city housing programs encourage building active partnerships between government, lenders, builders and developers. Involvement is continually solicited through public hearings and forums, special housing committees and work groups, and consultations with public, quasi- public, and non - profit agencies. The city has ongoing funding relationships with area non - profits and housing developers through the administration of its other grant funds. 6. Narrative describing qualified system and selection criteria for applications for awards to eligible sponsors: 1 2 Eligible sponsors, by means of the City of Clearwater Consolidated Action Plan process, are considered by application and evaluated and rated by either staff or a review committee, depending upon the proposed activity. Areas that are evaluated include: economic feasibility of a project; timeliness of completion; past experience; commitment to expanding affordable housing opportunities to very-low, low- and moderate - income households; preservation of the housing stock to increase property values; and enhancement of a community's image in targeted areas for housing developers. Eligible sponsors must prepare an application which contains, but is not limited to, organizational capacity; project proposal; pro- forma; project budget; financial analysis; site information; zoning information; proof of clear title; and proof of environmental assessment. The designated participant must plan to complete the project within eighteen (18) months. Larger, longer -term projects may be proposed outside of the housing pool as funding is available. Incentives to designated participants will be granted to those organizations to facilitate local housing assistance strategies. 7. Narrative describing criteria for selection of eligible persons: Applications, for both owner - occupied rehabilitation and purchase assistance programs, will be funded on a first -come, first - qualified, first- served basis by administering agencies. Applicants must be income eligible; the property must meet the city's established requirements; and the property must be the occupied as primary residence. Tenants applying for rental housing units will be qualified on a first -come, first - qualified, first - served basis by housing sponsors. Tenants must be income - eligible and must occupy the rental -unit as their primary residence. What constitutes income eligibility will be defined in each specific program. No homeowner or tenant will be assisted whose gross income exceeds 120% of AMI as defined in Ordinance 06 -28. Income eligibility will be determined by the same HUD- established methodology currently utilized in other City of Clearwater housing programs. The current methodology is annual income as defined in 24 CFR Part 5. 8. Narrative describing the participating jurisdiction's maximum award schedule or system of amounts and how it is consistent with the intent and budget of this local housing assistance plan: The maximum award schedule under this plan will be based upon the amount of subsidy required by a project to produce units that can be sold or rented for no more than the maximum purchase price or the maximum rent allowed under the City's program. This methodology is consistant with the intent and budget of this Local Housing Assistance plan in that it relates maximum awards to the local price of housing and local rents. Further, it ensures that housing produced under this plan will be consistent with "community housing" as defined in the Ordinance. 9. Narrative describing the expenditure process (attach timeline for each fiscal year covered by this plan as Exhibit A): Exhibit A shows the anticipated expenditure pattern. If it is determined, during periodic reviews, that the expenditures under a particular strategy are not being made as 2 3 anticipated, the city may proceed with another strategy shown on Exhibits A and B without need for amendment of this plan. 10. Narrative regarding provision for the application of program income and recaptured funds, evidencing compliance with the provision of Ordinance 06 -28, Section 3(5): The City will continue its established Local Housing Assistance Fund with a qualified depository for all monies the City will receive from its share of program funds; recaptured program funds; program income; and other monies received or budgeted by the city for the Local Housing Assistance Plan. These funds will be placed in a separate account. The exception to the above paragraph is any program income resulting from proceeds used to match the Federal HOME program. Such program income shall be deposited to the HOME program fund, as required by Federal law. All funds distributed out of the Local Housing Assistance Fund must be leveraged on a 2:1 basis. The eighty percent (80 %) non - forgiven loan requirement and twenty percent (20 %) for special needs /extremely low - income requirement do not apply to program income. 11. Narrative regarding ownership housing affordability period provisions: Loans or grants for houses constructed, rehabilitated or otherwise assisted through this Plan shall be subject to equity sharing and recapture requirements deemed appropriate at the time the loan is made. Minimum requirements, however, as required by the Rules are: Ninety percent (90 %) recapture within two years from the date of purchase and Fifty (50 %) recapture after two years or more from the date of purchase. The intent of the programs administered under this Plan is to allow property owners to realize a portion of the equity if a property is occupied or used for its intended purpose for a specific period of time, but also to prevent property owners from realizing inordinate gains. The city also intends to perpetuate affordability of housing units when appropriate. These goals could be realized through resale restrictions or through other types of agreements that fulfill these intents, but in no event shall the requirements be less than those mandated by the Rules of the Housing Trust Fund. 12. Narrative regarding process followed to assess and prioritize housing needs: The City of Clearwater has identified priorities for assisting households. The first priority is to provide safe, decent, adequate and affordable housing in safe and desirable environments for homeowners, homebuyers and renters. The second priority is to provide housing and supportive services housing programs. Studies are undertaken for the Housing Element of the City's Comprehensive Plan and for the Federal Consolidated Planning process. In addition to formal studies, stakeholder input is sought through public meetings and forums. 13. Strategy 1 — Produce new rental and owner housing - Brief narrative regarding activities to be carried out under this strategy, including (a) the proposed sales price of owner housing produced; (b) what resources through partnership will be combined to reduce the cost of housing; (c) any support services provided by the participating jurisdiction to the residents of the housing; (d) what initiatives will be used to conduct outreach and to attract applicants for assistance; and (e) a description of how this strategy furthers the housing element, 3 goals, policies, and objectives of the participating jurisdiction's comprehensive plan: Through the utilization of various funding sources and in conjunction with partnerships, a high priority is placed on collaborative efforts and effective use of resources to ensure that housing costs are minimized and impediments are removed. The City of Clearwater engages the community in seeking and promoting housing units which, based on surveys or citizen input, addresses the need of affordability, accessibility and meets the standard of suitable living environments. Partnerships are established that provide homebuyer education classes, which is a step that potential homebuyers can take to become informed on ways to increase their credit score and become a more desirable candidate for the finance industry to provide a home loan with a low interest rate. (a) The proposed sales price of owner - housing produced may not exceed the purchase limits for the city. The city's funding limits will be set forth on the Exhibit B, but may adjust such funding limits on a not to exceed State Housing Initiative Partnership (SHIP) program purchase price limits without amendments to this Plan. (b) The City will continue to develop partnerships with non - profits and developers for construction of new units. The cost of construction can be reduced by utilizing incentives provided for Affordable Housing Developments. Loans to affordable housing builders, and eventual homeowner, will provide a below market supplement to private market financing to further reduce costs. (c) Support services may be provided by the participating jurisdiction to the residents of housing. Necessity for support services, however, will be determined on a project - by- project basis. If a proposed project is intended to serve a population that traditionally needs specific support services to sustain housing, the proposal must clearly demonstrate how those support services will be delivered and maintained by the developer of the housing project. (d) The city will continue to develop relationships with non - profits and other agencies that assist applicants in finding suitable rental- housing which offer services that prepare applicants for homeownership. The city advertises its housing program through print media and its website. Developers of housing are required to submit an Affirmative Marketing Plan as part of the application process. Homeowner and rental applicants will be qualified on a first -come, first - served basis by the developer and /or administering agencies. Applicants must meet the income guidelines applicable to the strategy and must occupy the purchased or rented property as a primary residence. (e) This strategy furthers the Housing Element of the comprehensive plan that acknowledges deficits in both rental and owner - occupied housing for extremely low - to moderate - income households through the year 2020, addressing the factors which prevent homeownership due to excessive cost burdens and barriers that are prevalent in the pursuit of purchasing decent and affordable housing. 14. Strategy 2 — Preserve existing rental and owner housing - Brief narrative regarding activities to be carried out under this strategy, including (a) the proposed sales price of any rehabilitated properties to be sold; (b) proposed caps on the value of any owner occupied housing to be rehabilitated; (c) what resources through partnership will be combined to 4 reduce the cost of housing; (d) any support services provided by the participating jurisdiction to the residents of the housing; (e) what initiatives will be used to conduct outreach and to attract applicants for assistance; and (f) a description of how this strategy furthers the housing element, goals, policies, and objectives of the participating jurisdiction's comprehensive plan: Both rental and owner housing may be preserved through acquisition of existing units and rehabilitation of units. Although this strategy appears primarily as a rental strategy on the attached Exhibit B, this strategy may be carried out for both owner and rental housing at any time during the three -year period covered by this Plan without amendment to this Plan. The estimated number of households proposed to be served, by income, as shown on Exhibit B, may be adjusted at any time without amendment to this Plan. Additional preservation activities may be added as need and market conditions change without amendment to this Plan. (a) The proposed sales price of any rehabilitated property to be sold under this strategy may not exceed the purchase price limits under the City's program in effect at the time the home is sold. The current SHIP purchase price limit is $168,000. The City anticipates that funding limits will be set forth on Exhibit B, but may adjust such funding limits, not to exceed SHIP purchase price limits, without amendment to this Plan. (b) The value of the owner - occupied housing to be rehabilitated may not exceed the purchase price limit under the City's program in effect at the time the home is sold. Value will be determined using the same methodology utilized in other city Housing programs at the time of rehabilitation. Currently, the city utilizes the "Sales Comparable Value" as documented by the Pinellas County Property Appraiser's Office. (c) The city will continue to develop partnerships with non - profits and developers for acquisition and rehabilitation of units, as is done in all other housing programs the city currently carries out. The cost of substantial rehabilitation may be reduced through the use of loans which provide a below market supplement to private market financing. (d) Support services are available from various sources which include, but are not limited to: Homeownership Counseling (Pre and Post), Credit Counseling, Tenant Counseling and Transportation. (e) The city will continue to develop relationships with non - profits and other agencies that assist applicants in finding suitable rental housing and which offer services that prepare applicants for homeownership. The city also widely advertises its housing programs through print media and its website. Developers of housing undertaking substantial rehabilitation or conversion of non - residential properties to rental housing are required to submit an Affirmative Marketing Plan as part of the application process. Homeowner and rental applicants will be qualified on a first - come, first - served basis by the developer and /or the administrating agencies. Applicants must meet the income guidelines applicable to the strategy and must occupy the purchased or rented property as a primary residence. (f) This strategy furthers the Housing Element of the Comprehensive Plan. In addition, 5 preservation may include acquisition of existing units by non - profits or a Community Land Trust to preserve these units as affordable housing by taking them out of the market rate housing pool. These units assist the deficit of affordable housing units described in Strategy 1. The preservation of existing housing stock is the first objective under the current Consolidated Action Plan and furthers the goals, policies and objectives by ensuring there are provisions available for preservation through the use of state and federal funds for rehabilitation, code compliance and adherence to building standards, and elimination of blight. The city also focuses on the removal of architectural barriers, thus allowing for homeowners to maintain their units while making necessary modifications. Internal guidelines and procedures are established to ensure that costs related to preservation are limited to a standard of reasonableness. 15. Strategy 3 — Promote Housing Opportunities - Brief narrative regarding activities to be carried out under this strategy, including (a) proposed caps on the value of homes to be purchased under this strategy; (b) what resources through partnership will be combined to reduce the cost of housing; (c) any support services provided by the participating jurisdiction to the residents of the housing; (d) what initiatives will be used to conduct outreach and to attract applicants for assistance; and (e) a description of how this strategy furthers the housing element, goals, policies, and objectives of the participating jurisdiction's comprehensive plan: Through this strategy, down payment and closing cost assistance will be provided to income - qualified households. This strategy may be carried out at any time during the three -year period covered by this Plan. While this strategy is primarily intended to assist with the promotion of homeownership opportunities, it may be utilized to assist with the promotion of rental opportunities through rental assistance activities without amendment to the Plan. The estimated number of households proposed to be served by income as shown on Exhibit B, may be adjusted at any time without amendment to this Plan. Additional activities to promote housing opportunities may be added as needs and market conditions change without amendment to this Plan. (a) The purchase price of homes purchased under this strategy may not exceed the city's maximum purchase price for new or existing homes. The current maximum purchase price is $228,000 for newly constructed homes and $168,000 for existing homes. The city's funding limits will be set forth in Exhibit A or B, but may adjust such funding limits from time to time, not to exceed the SHIP purchase price limits, without amendment of this Plan. The monthly rent for tenants assisted under this strategy may not exceed the 120% rent limits under the SHIP program in effect at the time the unit is rented. (b) The City will continue to develop partnerships with non - profits who prepare applicants for homeownership and with lenders that make primary loans. Homebuyer education may reduce the cost of housing by helping the homebuyers to obtain better pricing for services required for their real estate transaction. Partnership with lenders may reduce the price of housing by allowing homebuyers to obtain a more favorable interest rate on primary loans. (c) Support services will not be provided by the city to the residents of housing. Necessity for support services, however, will be determined on a case -by -case 6 7 basis by agencies administering the assistance programs. If needed, support services for credit counseling, pre - purchase, post - purchase and foreclosure prevention counseling will be provided through these agencies. (d) The city will continue to develop relationships with non - profits and other agencies that offer services that prepare applicants for homeownership or which assist applicants in need of rental housing. The city advertises its housing programs through the print media and website. Developers of housing are required to submit an Affirmative Marketing Plan as part of the application process. Applicants will be qualified on a first -come, first - served basis by eligible sponsors and administering agencies. Applicants must meet the income guidelines applicable to the strategy and must occupy the property as primary residence. (e) This strategy furthers the Housing Element of the comprehensive plan that acknowledges deficits in housing for the extremely low- to moderate - income households through the year 2020. The subsidy provided to a household through this strategy can close the affordability gap and ease the deficit. 16. Strategy 4 — Provide Housing Services - Brief narrative regarding activities to be carried out under this strategy, including: (a) what resources through partnership will be combined to reduce the cost of housing; (b) any support services provided by the participating jurisdiction to the residents of the housing; (c) what initiatives will be used to conduct outreach and to attract applicants for assistance; and (d) a description of how this strategy furthers the housing element, goals, policies, and objectives of the participating jurisdiction's comprehensive plan: Through this strategy, available support services may include, but are not be limited to, fair housing services, housing placement services, pre- and post - purchase homeownership counseling, credit counseling, and foreclosure prevention counseling. The estimated number of households proposed to be served by income as shown on Exhibit B may be adjusted at any time without amendment to this Plan. Additional housing services activities may be added as needs and market conditions change without amendments to this Plan. (a) The city will continue to develop partnerships with non - profits that prepare applicants for homeownership and with lenders that make primary loans, as is currently taking place in other promotion of housing opportunity programs done through the city. (b) The support services available under this strategy will be provided through non- profits and other qualified agencies. (c) The city will continue to develop relationships with non - profits and other agencies that offer the services to be carried out under this strategy. The city widely advertises its housing programs through print media and website information. (d) This strategy furthers the Housing Element of the comprehensive plan by which the city's Comprehensive Plan assists homeowners and renters find and sustain decent and safe housing. 17. Narrative explaining how the activities carried out under these Strategies will meet the requirements of Ordinance 06 -28, Section 3(4)(a) — Leveraging 2:1: 7 Checklist of required documents (will satisfy the table of contents or checklist requirement): O This Local Housing Assistance Plan O Exhibit A - Timeline for each fiscal year covered by this plan O Exhibit B - Local Housing Assistance Plan Summary Chart for each fiscal year covered by this plan O Exhibit C - Copy of policy of participating jurisdiction regarding sub -prime loans [Ordinance Section 3(1)(b)] 8 The city will meet this requirement on a program year allocation basis and not on an individual project basis. The city will track its portion of the Housing Trust Funds used in each project for leveraging. Leveraging may come from, but is not limited to: loans made to projects by other lenders; grants made to projects; donated land; developer and sponsor owner - equity and donated materials; supplies, labor and services. 18. Narrative explaining how the activities carried out under these Strategies will meet the requirements of Ordinance 06 -28, Section 3(4)(b) — 80% non - forgiven loans: The city will meet this requirement by using both amortized loans and deferred payment loans. No loan will be forgiven. The type of loan made will be determined on a project by project basis, as the debt service capability of each project is underwritten. This requirement does not apply to the expenditure of program income. 19. Narrative explaining how the activities carried out under these Strategies will meet the requirements of Ordinance 06 -28, Section 3(4)(c) —15% special needs or <30% MFI: The city will meet this requirement by producing or preserving units specifically for this targeted population or by working with other Participating Jurisdictions on a collaborative basis. Additional activities to utilize the fifteen percent (15 %) set -aside may be carried out by one of the four strategies as needs and market conditions change without amendment to this Plan. This requirement does not apply to the expenditure of program income. 20. Narrative explaining how rental developments assisted under this plan will be monitored annually and how tenant eligibility shall be determined throughout the compliance period: For rental housing assisted under this Plan, the city, or its agent, shall annually monitor and determine tenant eligibility and subsidy amounts using the HUD established methodology utilized in other city housing programs. The current methodology is annual income as defined in 24 CFR Part 5. However, to the extent another governmental entity provides the same monitoring and determination, the city may rely on such monitoring and determination of tenant eligibility. Tenant eligibility will be monitored, at minimum, once a year for fifteen (15) years, or the term of the assistance, whichever period is longer. Loans for rental housing development made under this Plan shall be secured by a mortgage recorded against real property and a promissory note. The continued use of the real property for affordable rental shall be ensured by recording a Land Use Restriction Agreement (LURA) attached to the land. Developers and sponsors that offer rental housing for sale, prior to the expiration of a LURA, must ensure continued occupancy by eligible person(s) for the remainder of the affordability period required under the LURA. Checklist of required documents (will satisfy the table of contents or checklist requirement): O This Local Housing Assistance Plan O Exhibit A - Timeline for each fiscal year covered by this plan O Exhibit B - Local Housing Assistance Plan Summary Chart for each fiscal year covered by this plan O Exhibit C - Copy of policy of participating jurisdiction regarding sub -prime loans [Ordinance Section 3(1)(b)] 8 O Exhibit D - Copy of policy of participating jurisdiction regarding subordination of loans [Ordinance Section 3(1)(c)] O Exhibit E - Copy of sample Land Use Restriction agreement [Ordinance Section 3(4)(f)] O Exhibit F - Certifications and Required Statements with original signature O Exhibit G - Adopting Resolution 9 Housing Finance Authority of Pinellas County Local Housing Assistance Plan Timeline of Expenditures - Exhibit A Required by the Rules, Section 3(6)(d) Timeline for the Program Year: Allocation - $0 Tittle Period 4400000 Participating Jurisdiction: CITY OF CLEARWATER EXHIBIT A 2 Year 1 10/01/16 - 9/30/17 Program Income w/ Beg Bal $476,684 Year 2 10/01/17 - 9/30/18 Program Income $48,349 Year 3 10/01/17- 9/30/19 Program Income $48,349 Available for projects $558,877 (Allocation less administration) 2 Strategy 1 - Production Owner Activity Rental Activity Other Activity - Special Needs Rental Strategy 2 - Preservation Owner Activity Rental Activity Other Activity Strategy 3 - Promote Housing Opportunities Activity 1 - Down Payment Assistance Activity 2 - Activity 3 - Strategy 4 - Provide Housing Services Activity 1 - Housing Placement Activity 2 - Activity 3- Contingency TOTALS $0 $0 $0 FY2 $150,000 ;? _.i• §' '$98,500. .;. -:. ' $52,800 $98,500 $72;047 $471,847 $0 $0 $0 $43,515 $0 $14,505 $14,505 $14,505 $179,010 $98,500 $0 $81,810 $127,510 $0 $72,047 $0 $0 $0 $0 $43,515 $0 $0 $0 $0 $558,877 Should equal $558,877 i Housing Finance Authority of Pinellas County Local Housing Assistance Plan Summary Chart - Exhibit B Required by the Rules, Section 3(5) Strategies for the Program Year: 10/01116 - 09/30/17 Participating Jurisdiction: CITY OF CLEARWATER Criteria 2:1 leveraging 80% non - forgiven loans that generate program income 15% special needs or < 30% MFI Criteria Set - Asides Allocation Administration Estimates Salaries and Benefits Office Supplies & Equipment Travel and Workshops Advertising Total - not to exceed $4,834.90 $3,050.00 $1,785.00 $0.00 $0.00 $4,835.00 # units Strategy 1 - Production Owner Activity Rental Activity Other Activity - Special Needs Rental Total Strategy 1 30% or Spec maximum Needs VLI LI MI funding /unit Total Leveraging Allocation Amount $0.00 Program Income w/ Beg Bal Administration (10 %) 20% forgiven loans /services 80% non - forgiven loans 15% special needs $476,684.00 $4,834.90 $0.00 $0.00 $0.00 $0 Available for projects: $471,849 (Allocation +PI less administration) 12 $12,500 $150,000 Amount funded from HTF 2 549,250 598,500 Amount funded from HTF $0 Amount funded from HTF 14 0 0 0 0 $248,500 Strategy 2 - Preservation Owner Activity 2 526,400 $52,800 Amount funded from HTF Rental Activity 2 $49,250 $98,500 Amount funded from HTF Other Activity $0 Amount funded from HTF Total Strategy 2 4 0 0 0 0 $151,300 Strategy 3 - Promote Housing Opportunities Activity 1 - Activity 2 - Activity 3 - Total Strategy 3 Strategy 4 - Provide Housing Services Activity 1 - Housing Placement Amount funded from HTF Activity 2 - $0 Amount funded from HTF Activity 3- $0 Amount funded from HTF Clients Assisted under Strategy 4 0 0 0 0 $0 $0 15 15 0 $4,803 $72,049 Amount funded from HTF 50 Amount funded from HTF $0 Amount funded from HTF $72,049 Total Units 33 EXHIBIT B: Program Year 2018 $for30 %or Spec Needs $ non- forgiven $0 $0 $0 Contingency/5% Holdback - $4,835 5471,849 Must exceed Must exceed Must exceed Must exceed $0 $23,834 $0 $0 • Housing Finance Authority of Pinellas County Local Housing Assistance Plan Summary Chart - Exhibit B Required by the Rules, Section 3(5) Strategies for the Program Year: 1011/17 - 09130118 Participating Jurisdiction: CITY OF CLEARWATER Criteria 2:1 leveraging 80% non - forgiven loans that generate program income 15% special needs or < 30% MFI Criteria Set - Asides Allocation b Administration Estimates Salaries and Benefits $3,050.00 Office Supplies & Equipment $1,785.00 Travel and Workshops 50.00 Advertising $0.00 Total - not to exceed 54,835.00 $4,834.90 # units Allocation Amount $0.00 Program Income Administration (10 %) 20% forgiven loans /services 80% non - forgiven loans 15% special needs $48,349.00 $4,834.90 $0.00 $0.00 $0.00 Available for projects: (Allocation +PI less administration) 50 $43,514 EXHIBIT B: Program Year 2017 30% or Spec maximum $ for 30% or Needs VLI LI MI fundinglunit Total Leveraging Spec Needs $ non- forgiven Strategy 1 - Production Owner Activity 1. $14,505 $14,505 Amount funded from HTF Rental Activity $0 Amount funded from HTF Other Activity - Special Needs Rental 50 Amount funded from HTF Total Strategy 1 0 0 0 0 514,505 Strategy 2 - Preservation Owner Activity 1 Rental Activity Other Activity Total Strategy 2 2 0 Strategy 3 - Promote Housing Opportunities Activity 1 - Activity 2 Activity 3 - Total Strategy 3 0 0 Strategy 4 - Provide Housing Services Activity 1 - Housing Placement Activity 2 - Activity 3- Clients Assisted under Strategy 4 0 0 0 0 0 0 $14,505 $14,505 Amount funded from HTF 514,505 $14,505 Amount funded from HTF $0 Amount funded from HTF $29,010 50 Amount funded from HTF $0 Amount funded from HTF $0 Amount funded from HTF $0 Amount funded from HTF $0 Amount funded from HTF $0 ' S Amount funded from HTF $0 $0 $0 SO $0 Contingency/5% Holdback - $4,835 Total Units 3 $43,515 Must exceed Must exceed Must exceed Must exceed $0 $2,417 $0 50 r[" Housing Finance Authority of Pinellas County Local Housing Assistance Plan Summary Chart - Exhibit B Required by the Rules, Section 3(5) Strategies for the Program Year: 10/01/18 - 09130119 Participating Jurisdiction: CITY OF CLEARWATER Criteria 2:1 leveraging 80% non - forgiven loans that generate program income 15% special needs or < 30% MFI Criteria Set - Asides Allocation b Administration Estimates Salaries and Benefits $3,050.00 Office Supplies & Equipment $1,785.00 Travel and Workshops .$0.00 Advertising 50.00 Total - not to exceed $4,835.00 54,834,90 Strategy 1 - Production Owner Activity Rental Activity Other Activity - Special Needs Rental Total Strategy 1 Strategy 2 - Preservation Owner Activity 1 $14,5051 $14,505 Amount funded from HTF Rental Activity 1 $14,505 $14,505 Amount funded from HTF Other Activity $0 Amount funded from HTF Total Strategy 2 2 0 0 0 0 $29,010 Allocation Amount 50.00. Program Income Administration (10%) 20% forgiven loans /services 80% non - forgiven loans 15% special needs $48,349.00 $4,834.90 $0.00 $0.00 $0.00 Available for projects: (Allocation +PI less administration) $0 $43,514 EXHIBIT B: Program Year 2018 30% or Spec maximum $ for 30% or 9 units Needs VLI LI MI funding /unit Total Leveraging Spec Needs $ non- forgiven 0 0 0 $14,505 $14,505. Amount funded from HTF $0 Amount funded from HTF $0 Amount funded from HTF $14,505 Strategy 3 - Promote Housing Opportunities Activity 1 - Activity 2 - Activity 3 - Total Strategy 3 Strategy 4 - Provide Housing Services Activity 1 - Housing Placement Activity 2 - Activity 3- Clients Assisted under Strategy 4 0 Total Units 3 0 $0a $0 $0 50 Amount funded from HTF Amount funded from HTF Amount funded from HTF Amount funded from HTF $0 Amount funded from HTF $0 Amount funded from HTF $0 50 $0 $0 $0 Contingency /5% Holdback - $4,835 $43,515 Must exceed Must exceed Must exceed Must exceed 50 52,417 $0 $0 Exhibit C City of Clearwater Housing Policy Sub -Prime Lending Policy The city will not assist Borrowers who are being charged more than a combined two percent (2 %) for loan discount and origination fees by the first mortgage provider. The city will also not assist Borrowers who are obtaining adjustable rate first mortgages, interest only mortgages, mortgages financed by the owner /seller, or mortgages with above - market interest rates or excessive fees. Interest rate expressed as Annual Percentage Rate (APR) may not exceed two percent (2%) above the Market Rate (A rate that is no more than 25 basis points greater than the most - recent Freddie Mac Weekly Primary Mortgage Market Survey (PMMS) Rate for 30 -year fixed -rate conforming mortgage). In addition, the city will not assist Borrowers with loans that require high up -front and out of pocket fees, prepayment penalties, loans for more that the property's value, unfavorable balloon payments, loans that requires credit life or credit disability insurance, unreasonable penalties for late fees, having a mandatory arbitration clause (give or right to sue in court), negative amortizing loans, or open ended mortgages. Exhibit D City of Clearwater Housing Division Loan Subordination Policy Revised - July 2016 In general, the City of Clearwater does not subordinate mortgages made using CDBG, HTF, HOME, and SHIP funds. However, under the following circumstances, the City will consider taking a subordinate position: 1. The original borrower continues to own and occupy the home as its primary residence. 2. The original borrower is experiencing financial hardship which would be benefited by securing a lower interest rate on his or her first mortgage accompanied by lower monthly payments. 3. The new monthly payment includes escrows for taxes and insurance, and represents between 30% - 35% of a borrower's gross monthly income. 4. The new first mortgage interest rate is at least two percentage points below the original first mortgage, and /or as a result of the monthly savings, the borrower should be able to recoup (break -even) the loan closing costs within 3 -5 years. 5. The new loan's origination fee, points, commitment fees, buy down fees and other lender charges do not exceed 2% of the loan amount. 6. The new first mortgage is a permanently fixed rate mortgage with no balloon payments and no pre - payment penalty. Terms may be made for as few as ten years, and may go up to thirty years as applicable based on the original loan balance and the term remaining on the original note. 7 The borrower does not receive any cash out for any purpose, including but not limited to, home improvement loans, bill consolidation loans, lines of credit, future advances, personal loans, medical collections, other mortgages or encumbrances or liens. 8. The borrower must have sufficient equity in the home so as not to displace the City beyond a 125% loan to value ratio. 9. If the borrower has a payment type loan, the account must be current. 10. Property Taxes must not be delinquent. 11. Borrower must submit proof of homeowner's insurance. 12. Processing fee of $100 will be charged for subordination review and processing. Borrowers interested in seeking approval from the City's Housing Division to subordinate a first mortgage must: 1. Write the City of Clearwater's Housing Division requesting the City subordinate to their lender and authorize the lender to receive information regarding their loan for the purposes of the refinance. Last Updated: July 2016 2. The Lender must provide the details of the loan being requested by supplying copies of the Loan Estimate, Itemization of Fees, Title Commitment, Appraisal and the projected settlement costs. 3. Provide additional information as needed to establish that the loan is strictly for a reduction in payment/interest rate and that the lender is not charging rates or providing terms that will in some way fall under the category of predatory lending practices. 4. The City must review a copy of the HUD -1 Closing Statement prior to release of the City's executed Subordination Agreement. If a title company faxes the HUD - 1 to the City when completed, and supplies their FedEx account number, the City will overnight, or fax, if acceptable, the executed Subordination Agreement, if in agreement with the figures on the HUD -1. 5. All requests for subordination must be made at least thirty (30) days prior to closing. This Loan Subordination Policy may be amended from time to time. For the most up to date version please contact the City of Clearwater — Economic Development & Housing Department at 727.562.4036. I have read the above City of Clearwater — Subordination Policy and understand the terms and conditions of the policy. Borrower Date Borrower Date Last Updated: July 2016 EXHIBIT "E" LAND USE RESTRICTION AGREEMENT CITY OF CLEARWATER HOME Investment Partnership Program & Pinellas County Housing Trust Fund Program THIS DECLARATION, made this _ day of , between ., a Florida not - for -profit corporation, its successors, assigns and transferees of the project described below, whose mailing address is , Clearwater, Florida , hereinafter called ( "Borrower ") and the City of Clearwater, Florida, a municipal corporation organized and existing under the laws of the State of Florida hereinafter called ( "City "). WHEREAS, the Borrower shall renovate certain real property for affordable rental units to low- moderate income tenants described herein and agrees with the City that the real property which is subject to this executed Mortgage and Note shall be subject to the restrictive covenants set forth herein. WHEREAS, the Borrower agrees that the restrictive covenants shall remain in full force and effect against the real property until the end of a thirty (30) year affordability period ( "Affordability Period "). This Agreement shall be properly filed and recorded by the City in the Official Public Records of the Pinellas County, Florida and shall constitute a restriction upon the use of the property subject to and in accordance with the terms contained herein. IN CONSIDERATION of funds the City has provided through the HOME Investment Partnership Program and the Pinellas County Housing Trust Fund Program to the Borrower for a loan of $ to finance the rehabilitation or construction of certain units and closing costs associated with the project in the City of Clearwater, Pinellas County, Florida, more particularly described as: Exhibit "A" Attached. In consideration of financing for the rehabilitation of the above referenced property, the Borrower acknowledges that this Agreement is necessary to comply with the affordability requirements of the HOME program as stated at 24 CFR Part 92, and the Pinellas County Housing Trust Fund Program, from which funds were obtained to finance such loan, and subpart B of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, §24.101, and therefore, borrower covenants and agrees that in connection with the rehabilitation of the project, that the City should approve any transfer or sale of the subject property and borrower will comply, and will require any subsequent purchaser of the project to comply, with the following: 1. Covenants and Restrictions on Use of Funds. HOME Investment Partnership Program and Pinellas County Housing Trust Fund Program allocations provided to this project will be used for rehabilitation of the real property. During the Period of Affordability as defined herein, the units shall be rented to tenants having an annual income which does not exceed 80 percent of the median family income for the area, as determined and made available by the U.S. Department of Housing and Urban Development with adjustments for smaller and larger families at the time of occupancy. The income of the persons who will occupy the unit shall be verified by the City or a designated party agreed to by the Borrower and the City, by obtaining third party verification of current income for the tenants who will occupy the housing units and verification of assets. Source documentation evidencing annual income may include wage statements, interest statements, and unemployment compensation statements, other documentation approved by the -1- City. In the event that neither of the above methods is suitable, the Borrower may use other methods acceptable to the City to verify income. Annual income for the purpose of this Agreement shall be as defined by the U.S. Department of Housing and Urban Development for the HOME Program. (a) For the purpose of this Agreement, the Period of Affordability shall commence upon the date of this Agreement and end on the last day of the thirtieth (30`h) year thereafter. (b) During the Period of Affordability, the HOME Investment Partnership Program and the Pinellas County Housing Trust Fund shall require four of the HOME- assisted units must rent at the low HOME rents level and of the units at the high HOME rents level for a period of thirty years. It is encouraged that all other units remain affordable with rents at or below the Fair Market Rents as defined annually by the U. S. Department of Housing and Urban Development. (c) All proceeds, program income and recaptured funds associated with this project shall be returned to the City of Clearwater within 30 days. (d) Any noncompliance with the requirement of this Section shall be corrected within 30 days after such error is first discovered or would have been discovered by the exercise of reasonable diligence. 2. Property Standards: The units shall meet and maintain all applicable local codes, the Florida Building Code, ordinances, including but not limited to, zoning ordinances at the time of project completion. All units must meet all applicable State and local housing quality standards, code requirements and accessibility requirements at 24 CFR Part 8, which implements Section 504 of the Rehabilitation Act of 1973 and covered multifamily dwellings as defined at 24 CFR 100.20, and must also meet the design and renovation requirements at 24 CFR 100.205, which implement the Fair Housing Act. Renovation of the unit must meet the Model Energy Code. 3. Location of HOME Investment Partnership Program and Pinellas County Housing Trust Fund Program Assisted Units. The location of the units is as follows: , Clearwater, Florida . Legal Description Attached. The Borrower agrees that there will be no material changes to the units after initial commitment by the City without assurances provided by Borrower and approved by City that any proposed changes will not adversely affect the HOME assisted units or any provision of this Agreement. 4. No Discrimination. The Borrower shall not discriminate, as defined by Federal Statutes, on the basis of race, creed, color, sex, age or national origin in the use or occupancy of the HOME assisted unit or in connection with the employment or application for employment of persons for the operation and management of the project. 5. Affirmative Marketing Efforts. The Borrower will follow the affirmative marketing procedures and requirements for the HOME Program to attract eligible tenants in the housing market area to the available housing without regard to race, color, national origin, sex, religion, familial status or disability. 6. Environmental Reviews. The acquisition project must be assessed for environmental effects in accordance with the provisions of the National Environmental Policy Act of 1969 (NEPA) and related authorities listed in HUD's implementing regulations at 24 CFR parts 50 and 58. 7. Displacement, relocation, and acquisition. The Borrower will take reasonable measures to minimize displacement of persons as a result of a project being assisted with HOME funds in accordance with the requirements of the Uniform Relocation Assistance and Real -2- Properties Acquisition Act. The borrower shall be responsible for any relocation expenses incurred without City approval. 8. Lead Based Paint. The Borrower shall be responsible for maintaining that all HOME assisted units meet the requirements listed in the Lead Based Paint Poisoning Prevention Act and 24 CFR part 35. 9. No Conflicts with Other Documents. The Borrower warrants that it has not, and will not, execute any other agreement with provisions contradictory to, or in opposition to, the provisions hereof, and that, in any event, the requirements of this Agreement are paramount and controlling as to the rights and obligations herein set forth and supersede any other requirements in conflict herewith. 10. Requests for disbursement of funds. Loan funds will be placed in an escrow account at a title company. The Borrower shall request funding for the project from the City of Clearwater in accordance with its application and approval for such funds. 11. Records. The Borrower shall retain all records pertaining to Project for a period of five years after audit and/or resolution of audit findings involving this loan. The Borrower shall maintain accurate information regarding the occupancy for each HOME unit during the term of the Affordability Period and, at the request of the City, shall submit this information to the City for the City's review and comment. The Borrower shall maintain documentation substantiating compliance with Affirmative Marketing Requirements. These Project records shall be made available to The City of Clearwater, U.S. Department of Housing and Urban Development and /or representatives of the Comptroller General of the United States for audit, inspection or copying purposes during normal business hours. The Owner shall maintain project records that include the following: (1) A full description of each unit assisted with HOME funds, including the location and form of HOME assistance. (2) The source and application of funds for each unit, including supporting documentation in accordance with 24 CFR 85.20. (3) Records demonstrating that each unit meets the property standards of the lead based paint requirements. (4) Records demonstrating that each tenant is income eligible. (5) Records demonstrating that the purchase price or estimated value is in accordance with program guidelines. (6) Records demonstrating that each HOME assisted unit meets the affordability requirements. (7) Records documenting required inspections, monitoring reviews and audit, and the resolution of any findings or concerns (8) Records documenting equal opportunity and fair housing records. (9) Records documenting all HOME related financial activities. (10) Records documenting affirmative marketing and MBE /WBE activities. 12. Monitoring. The Borrower shall permit the City or its designee to inspect all records pertaining to units upon reasonable notice and within normal working hours and shall submit to the City such documentation as required by the City to document compliance with this Agreement and HOME Program rules. If the project is new construction, the Borrower shall provide the required documentation quarterly, until all HOME units are sold. 13. Successors Bound. This Agreement and the covenants contained herein shall run with the land and shall bind, and the benefits shall inure to, respectively, the Borrower and its - 3 - successors and assigns and all subsequent owners of the project or any interest therein, and to the City for the Period of Affordability set forth in this Agreement. 14. Enforcement of Terms. The benefits of this Agreement shall inure to, and may be enforced by the City for the Period of Affordability, whether or not the City shall continue to be the holder of the Mortgage, whether or not the project loan may be paid in full, and whether or not any bonds issued for the purpose of providing funds for the project are outstanding. 15. Conflict of Interest. The Borrower warrants that no person covered who exercises or exercised any functions or responsibilities with respect to HOME activities or who is in the position to participate in decisions or gain inside information may obtain a financial interest or benefit from a HOME activity; or have an interest in any contract, subcontract or agreement for themselves or for persons with business or family ties. 16. Conditions of Religious Organizations. HOME funds may not be used for rehabilitation or construction of housing that is owned by primarily religious organizations or to assist primarily religious organizations in acquiring housing. 17. Uniform Administrative Requirements. If the owner of the HOME assisted project is a not- for - profit organization, the owner agrees to comply with applicable federal administrative requirements of OMB Circular A -87 and applicable provisions of 24 CFR 85 for government entities, or OMB Circular A -122 and applicable provisions of 24 CFR Part 84 for non -profit entities. 18. Severability. The invalidity of any clause, part or provision of this Agreement shall not affect the validity of the remaining portion thereof. 19. Defaults and Remedies. If the Borrower shall fail to observe or perform any covenant, condition or agreement contained herein on its part to be observed or performed, then and in such event, the City shall be entitled, in addition to all other remedies provided by law or in equity: (a) To compel specific performance by the Borrower of its obligations under this Agreement, it being recognized that the beneficiaries of Borrower obligations hereunder cannot be adequately compensated by monetary damages in the event of Borrower's default. (b) To cause the Borrower to pay to the City an amount equal to all HOME Investment and Pinellas County Housing Trust Fund Program funds loaned to Borrower less any principal balance previously repaid by Borrower or the transfer of real property acquired with HOME Investment Partnership Program and Pinellas County Housing Trust Program assistance, if any assisted unit is knowingly or negligently rented to persons who do not comply with the requirements for such unit or doesn't have low to moderate income tenants. (c) In addition, to these remedies, a default by the Borrower hereunder shall constitute a default under the Mortgage and Note which will enable the City thereunder, after notice and an opportunity to cure as therein provided, to accelerate the Borrower's loan and take such other actions as may be permitted under the terms of the Mortgage. Name of the organization By: , Inc. a Florida not - for - profit corporation By: President CITY OF CLEARWATER, FLORIDA By and through City Council through the Dept. Director - 4 - By: , Director Economic Development & Housing EXHIBIT "A" EXHIBIT "E -1" LAND USE RESTRICTION AGREEMENT HOME INVESTMENT PARTNERSHIP PROGRAM HOME BUYER THIS DECLARATION is entered into this day of between his /her successors, assigns and transferees regarding the real property described below, hereinafter called (" Borrower ") and the City of Clearwater, Florida, unit of local government organized and existing under the laws of the State of Florida hereinafter called ( "City "), whose address is 112 South Osceola Avenue, Clearwater, Florida 33756 (Lender). WHEREAS, the Borrower shall purchase certain real property described herein and agrees to the City that the real property which is the subject of a Mortgage and Note executed by Borrower of even date herewith, shall contain the restrictive covenants set forth herein, WHEREAS, Borrower agrees that the hereafter described restrictive covenants shall remain in full force and effect against the real property until the end of the Period of Affordability, WHEREAS, these covenants shall be properly filed and recorded by City in the Official Public Records of the Pinellas County, Florida and shall constitute a restriction upon the use of the property subject to and in accordance with the terms contained herein, and IN CONSIDERATION of funds the City has provided to the Borrower for a loan to finance the down payment and closing costs on real property located in the City of Clearwater, Pinellas County Florida described as: (LEGAL DESCRIPTION) which has the address of: (herein "Property Address ") and which real property is described in the mortgage between the City and the Borrower, the Borrower acknowledges that these Restrictive Covenants are necessary to comply with the program requirements of the HOME program stated at 24 CFR §92.254, from which funds were obtained to finance such loan and covenants and agrees with the following: 1. Covenants and Restrictions on Use of HOME Funds. HOME funds provided to this project will be used for down payment and closing costs for the acquisition of the real property. At the time of the application, the Borrower's annual income should not exceed 80 percent of the area median income, as determined and made available by the U.S. Department of Housing and Urban Development with adjustments for smaller and larger families at the time of purchase of the new home. The home must be the principal residence of the family. a. The value of the HOME assisted unit shall not exceed 95 percent of the median purchase price for that type of single family housing for the area (FHA 203(b) limits). The maximum per unit subsidy amount shall not exceed the per dollar limits established under section 221(d)(3)(ii) of the National Housing Act. b. The Borrower shall have fee simple title to the property. c. For the purpose of these Covenants, the Period of Affordability shall be a period beginning when the HOME funds are invested and ending at the end of the ( ) years thereafter. 1 A d. During the Period of Affordability, the single family unit must be occupied by the Borrower. Should the Borrower sell the property to any willing buyer at whatever price the market will bear, the sale will trigger repayment of the HOME assistance. In addition, if the Borrower should rent and /or transfer the property, or if the home shall cease to be the principal /homestead residence of the Borrower, it will trigger repayment of the HOME assistance. e. The City will use the recapture provision for repayment of the loan should the Borrower not abide with the affordability period or any other default provision in the mortgage, note or covenant. In the event of default, the Borrower shall repay the City in accordance with the following: (1) The " Net Proceeds" from the sale shall be determined by subtracting the amount of the seller's closing costs and repayments of the outstanding loans on the property, including the repayments of any loans of HOME or other funds provided by the City; (2) The Borrower may recover his or her initial investment from the Net Proceeds. The initial investment included the amounts he or she contributed to the down payment when the property was originally purchased, to any permanent improvements to the property and to payment of principal on the permanent financing. (3) Any balance remaining from the initial investment shall be divided proportionally between the Borrower and the City according to their investments and formulas. The City's investment shall include all grants and loans of HOME or other City funds provided to the Borrower, minus any repayments previously made to the City. (4) In the event the proceeds from the sale of the property are insufficient to permit the Borrower to recover any of the amounts indicated in (1), (2) or (3) above, neither the City nor any previous owner shall be liable for such insufficiency. f. In the event the housing is conveyed pursuant to a foreclosure sale, the provisions of Section 92.254 (a)(5)(ii) of the HOME Program shall apply. The recapture provision provides for shared net proceeds (if any) from the foreclosure sale. If there are no net proceeds from the foreclosure, repayment by the City or the Borrower is not required and HOME Program requirements are considered to be satisfied. g. Enforcement. Violation or breach of any restrictions or covenant herein contained shall give the City the right to institute any proceeding at law or in equity necessary to recover the applicable sum set forth in this agreement. If action is instituted by the City to recover the sum, Borrower or its successors in the title agree to pay all costs to collection, including court costs and reasonable attorney's fees. IN WITNESS WHEREOF, this document has been duly signed by the Borrower on or as of the day and year first above written. In the presence of: Witness Witness STATE OF FLORIDA COUNTY OF PINELLAS 1 1 Borrower Borrower The foregoing instrument was acknowledged before me this day of , 20 by and , husband and wife, personally known to me oho have produced a drivers license as identification. My Commission expires: Notary Public 2 HOUSING FINANCE AUTHORITY, PINELLAS COUNTY, FLORIDA Local Housing Assistance Plan - Exhibit "F" Certifications and Required Statements: In implementing the strategies and activities outlined in this plan, housing for which a household devotes more than 30 percent of its income shall be deemed affordable if the first institutional mortgage lender is satisfied that the household can afford mortgage payments in excess of the 30 percent benchmark or, in the case of rental housing, does not exceed those rental limits adjusted for bedroom size established by the Florida Housing Finance Corporation. This participating jurisdiction has a plan to advertise the availability of the housing assistance plan at least 30 days before the beginning of the application period in a newspaper of general circulation. This participating jurisdiction has developed a qualification system and selection criteria for applications for awards to eligible sponsors, adopted criteria for selection of eligible persons, and adopted a maximum award schedule or system of amounts consistent with the intent and budget of its local housing assistance plan. This participating jurisdiction has developed a time line for the expenditure of Program distribution funds in sufficient detail to allow for a comparison of such plan with actual expenditures. This participating jurisdiction has a provision for the application of program income and recaptured funds from loan repayments, reimbursements or other repayments, and interest earnings on the local housing distribution funds. This participating jurisdiction shall establish and maintain a local housing assistance fund with a qualified depository, as defined in Chapter 280, F.S. Amounts on deposit shall be invested, as permitted by law, for the program funds of this participating jurisdiction. This fund shall be separately stated as a special revenue fund in this participating jurisdiction's audited financial statements. In accordance with the provisions of ss.760.20- 760.37, it is hereby certified that this participating jurisdiction will not discriminate on the basis of race, creed, religion, color, age, sex, marital status, familial status, national origin or handicap in the award application process for eligible housing. It is hereby certified that the staff or entity that has administrative authority for implementing a local housing assistance plan assisting rental developments shall annually monitor and determine tenant eligibility through the compliance period as described in Pinellas County Ordinance 06 -28, Section 3 and as amended in Ordinance 09 -44. It is hereby certified that this document is the eligible entity's local housing assistance plan and all provisions of the plan conform to the requirements of Pinellas County Ordinance 06 -28 and the Rules. 9frorty• C^ek-ttos Authorized Official Tito Date