Title
Hold a public hearing and consider an ordinance authorizing a Substantial Amendment to Annual Action Plans for Program Years 2017, 2021, 2022, and 2023 to reprogram HOME funds to provide for affordable housing activities and to remove the City’s requirement under the 2020-24 Consolidated Strategic Plan for HUD Certified Housing Counseling to provide services to recipients as a provision of the HOME Program Tenant Based Rental Assistance (TBRA).
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DATE: July 15, 2025
TO: Kent Cagle, City Manager
FROM: Tiffanie McNair, Executive Director of Community Development
SUBJECT: A reprogramming of HOME funds for affordable housing activities and the removal of the City’s requirement for recipients of Tenant Based Rental Assistance (TBRA) to receive housing counseling from a HUD Certified Housing Counselor as a provision to receiving TBRA assistance.
BACKGROUND AND FINDINGS:
A request was made to HUD to convert prior year Community Housing Development Organization (CHDO) set-asides to Entitlement funds as staff has been unable to identify eligible CHDOs. Once converted, funds can be allocated and expended on other eligible activities in a timelier manner. Staff has received approval from HUD and the Office of Affordable Housing Programs for the conversion.
The Ft. Hood Area Habitat for Humanity was recommended for funding in FY 2023 for the purchase of lots to construct homes. The organization did not execute a funding agreement to meet proposed project objectives which allowed for the funds to be eligible for reprogramming. In addition, due to the required use of HOME program income prior to the use of FY 2017 HOME Entitlement funds for expenditures, remaining funds were identified and made available for reprogramming. On April 3, 2025, the Community Development Advisory Committee met to discuss, consider, and approve the recommendation to reprogram 2017 funds in the amount of $1,573.80, the reprogramming of the converted CHDO funds in the amount of $162,059.55 and the Ft. Hood Area Habitat for Humanity allocation in the amount of $456,007.68 to fund affordable housing activities, in particular Tenant Based Rental Assistance. In accordance with the Citizen’s Participation Plan, a substantial amendment is required whenever there is a substantial change in the purpose, scope, location, or beneficiaries of an activity (project) and reprogramming is necessitated.
During the development and subsequent acceptance of the 2020-2024 Consolidated Strategic Plan (Con Plan), the Tenant Based Rental Assistance Program (TBRA) proposed the use of a HUD Certified Housing Counselor (CHC) to provide person to person housing counseling to persons receiving assistance under the TBRA. As the use of a HUD CHC is not a regulatory requirement under the TBRA and the lack of availability of HUD CHCs in the area creates an undue burden on recipients, the removal of this requirement is recommended.
The first public hearing regarding the proposed Substantial Amendment was held on June 3, 2025. The public comment period was from June 9-July 15, 2025.
THE ALTERNATIVES CONSIDERED:
N/A
Which alternative is recommended? Why?
Hold a public hearing on and consider an ordinance authorizing a Substantial Amendment to Annual Action Plans for Program Years 2017, 2021, 2022, and 2023 to reprogram HOME funds to provide for affordable housing activities and to remove the City’s requirement under the 2020-24 Consolidated Strategic Plan for HUD Certified Housing Counseling to provide services to recipients as a provision of the HOME Program Tenant Based Rental Assistance (TBRA).
CONFORMITY TO CITY POLICY:
This action conforms to the Citizen Participation Plan adopted by City Council.
FINANCIAL IMPACT:
What is the amount of the revenue/expenditure in the current fiscal year? For future years?
$619,641.03
Is this a one-time or recurring revenue/expenditure?
This is a one-time expenditure.
Is this revenue/expenditure budgeted?
This expenditure is budgeted.
If not, where will the money come from?
N/A
Is there a sufficient amount in the budgeted line-item for this revenue/expenditure?
Yes, sufficient funding is budgeted within the program accounts of the existing programs identified for reprogramming. Upon approval of this amendment, a budget transfer will move the funds to the approved programs.
RECOMMENDATION:
Hold a public hearing on and consider an ordinance authorizing a Substantial Amendment to Annual Action Plans for Program Years 2017, 2021, 2022, and 2023 to reprogram HOME funds to provide for affordable housing activities and to remove the City’s requirement under the 2020-24 Consolidated Strategic Plan for HUD Certified Housing Counseling to provide services to recipients as a provision of the HOME Program Tenant Based Rental Assistance (TBRA).
DEPARTMENTAL CLEARANCES:
Legal
Finance
ATTACHED SUPPORTING DOCUMENTS:
Ordinance
Meeting Minutes
Draft Substantial Amendment
Presentation