COVID-19 TCAC guidance for recertifications, services and work orders

The California Tax Credit Allocation Committee (TCAC) has issued guidance for recertifications, services and work orders because of COVID-19.  For households that start their 120 day certification/recertification period on or after March 20, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms.  Third party verifications should be sent to employers directly.  Tenants should be able to return document via mail or drop box.  TCAC strongly suggests giving tenants 60 to 90 days to gather and return information.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

For certifications and recertifications that were in process on March 19, 2020, management should provide households with a certification/recertification packet containing all TCAC required forms. Tenants should be able to return document via mail or drop box.  Management agents can sign forms after the date the tenants signs and returns the forms if it is within the normal 120 day certification/recertification period.

Initial tenant income certification meetings and other necessary meetings will continue in person.

Any documentation signed after the normal 120 day certification/recertification period must have  a statement in the tenant file stating why the recertification was completed late.

For work orders, management should notice tenants that any non-essential work order will be postponed.  Remaining work orders should be scheduled based on need and severity.

Service amenities including access to the community room and after school programs should be limited for social distancing.  All food-related programs should be suspended except for canned or prepackaged deliveries.  For properties that cancel or postpone required service amenities, required hours must be made up before the end of 2020.  (Tax Credit Allocation Committee Memo, March 19, 2020.)

COVID-19 reverification of employment and appraisals for FHA Single Family loans

The United States Department of Housing and Urban Development temporarily changed re-verification of employment and appraisal rules for FHA Single Family programs.  Until May 17, 2020 mortgagees do not need to re-verify employment within 10 days of the Note or within 10 days of loan disbursement if there is no loss of employment by the borrower.

Appraisers may do Exterior-only (viewing from the street) or Desktop-Only (relying on various documents and not viewing the property) appraisals for FHA Single Family loans.

There changes also apply to refinances and reverse mortgages.  (Mortgagee Letter 2020-05, March 27, 2020.)

COVID-19 foreclosure and eviction moratorium for Sections 184 and 184A loans

The United States Department of Housing and Urban Development has authorized a moratorium on foreclosures and evictions for loans guaranteed under the Section 184 Indian Home Loan Guarantee Program and Section 184A Native Hawaiian Housing Loan Guarantee Program for 60 days.

Properties secured by Section 184 or 184A guaranteed loans are subject to a moratorium on initiation of foreclosures and foreclosures in process for 60 days.  Eviction of people from properties previously secured by Section 184 or 184A guaranteed loans are suspended for 60 days.  (DLL -2020-04, March 20, 2020.)

COVID-19 suspension of foreclosures and evictions for Fannie Mae and Freddic Mac

The Federal Housing Finance Agency has directed Fannie Mae and Freddie Mac to suspend foreclosures for 60 days because of COVID-19.  This suspension applies to Fannie Mae and Freddie Mac backed single family mortgages.

Previously the Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac would provide payment forbearance for borrowers impacted by COVID-19 for 12 months.  (News Release, March 18, 2020.)

VA mortgage special relief for COVID-19

The Department of Veterans Affairs (VA) has issued information regarding special relief for COVID-19.  VA will conduct meetings by telephone with persons for people with symptoms of or exposed to COVID-19.

VA encourages holders or guaranteed loans to extend forbearance to borrowers in distress because of COVID-19. VA encourages waiving late charges on affected loans.  Servicers are encouraged to suspend credit reporting on affected loans.  (Circular 26-20-7, March 16, 2020.)

VA request for foreclosure moratorium

The Department of Veterans Affairs (VA) strongly encourages loan holders to establish a 60 day moratorium beginning on March 18, 2020 on completing foreclosures or initiating new foreclosures on loans.  VA regulations allow additional interest in a guarantee claim when termination is delayed by VA requested forbearance.

Loan holders should consider the impact of completing an eviction action when choosing to retain a property instead of conveying to VA.  VA requests holders not expose Veterans and their families to additional risk through an eviction action.  (Circular 26-20-8, March 18, 2020.)