The State demonstrates its commitment to civil rights through its policies, procedures and practices. These are conveyed to each recipient city, county and business through workshop participation, contractual language, management guide instructions and technical assistance. Through project monitoring, IDED reviews each recipient’s civil rights performance. IDED designates a member to oversee the civil rights compliance program. When a grant is awarded, the recipient is informed it must comply with IDED civil rights requirements. Normal monitoring procedures include the review of civil rights compliance of each grant recipient. If noncompliance is indicated, further actions are taken. No instances of noncompliance were noted in 2006. Equal Employment Commission EEO-4 The Iowa Department of Personnel maintains EEOC EEO-4 form data for IDED. PART D: HOME This section addresses several compliance issues related to the HOME program. 1. Results of On-site Inspections IDED performed on-site inspections (or contracted with USDA for on-site inspections) of 48 HOME-funded projects during 2006. inspections revealed only minor instances of with housing codes or other regulations. The field staff members responsible for monitoring these projects report that there have been no significant instances of non-compliance. 2. Private Sector Participation The State has made every effort to maximize the private sector participation of nonprofit and organizations in the financing, development, rehabilitation and management of affordable housing. IDED markets its programs directly to potential private investors, including developers and investors. In reviewing project applications, IDED attempts to ensure the maximization of private financing resources before committing HOME gap financing. The State expects projects to meet departmental standards both limiting the owner's rate of return and regarding the maintenance of a proper debt coverage ratio throughout the required period of affordability. Projects are, when possible, renegotiated to contain a greater share of local private sector funds. In FY 06, over percent (69.4 %) of HOME funds were awarded to for-profit organizations or individuals. 3. In FY 06, over seven percent (7.3 %) of the State’s HOME funds were awarded to CHDOs. There are 30 certified CHDOs in the State (some certified by IDED, others certified by entitlement cities). 4. Tenant Assistance/Relocation
Any governmental agency that receives HOME funds from the state must comply with Section 104(d) of the Housing and Community Development Act, as amended (the associated Rules are at 24 CFR Parts 42, 91, 92, and 570.) Compliance with these requirements would include the preparation and adoption of a Residential Anti-Displacement and Relocation (RARA) Plan that identifies the steps the recipient will take to minimize displacement. The following are sample actions recommended by IDED that could be part of the RARA Plan: Coordinate code enforcement with rehabilitation and housing assistance programs. Evaluate housing codes and rehabilitation standards in reinvestment areas to prevent undue financial burden on established owners and tenants. Rehabilitate rental units in such a way as to allow tenants to remain in the building/complex during and after the rehabilitation, working with empty units first. Arrange for facilities to house persons who must be relocated temporarily. Adopt policies to identify and mitigate displacement resulting from intensive public investment in the neighborhood. Adopt policies that provide reasonable protection for tenants faced with conversion to a condominium or cooperative. tax assessment policies, such as deferred tax payment plans, to reduce the impact of increasing property tax assessments on lower income owner-occupants or tenants in revitalizing areas. Separate from the requirements on governmental agencies, any HOME (or CDBG) project that involves displacement of tenants must comply with the policies and procedures set forth in 49 CFR Part 24 (which implement the Uniform Relocation Act.) One HOME-assisted project, 04-HM-428-21, included tenant assistance/relocation. The Historic Hotel Iowa, L.L.L.P. was acquired for rehabilitation to create 53 rental units of permanent affordable housing for elderly persons. Twenty-eight of the project’s units received HOME assistance. Thirty-five of the hotel building’s rooms were occupied at the time of acquisition. The project owner followed URA and 104(d) requirements. Twenty-five persons were displaced and ten persons returned to live in the rehabilitated building. The total cost for moving tenants, providing rental assistance and security deposits was $20,350. The administrative costs incurred for counseling and coordinating the relocation are not included in that total.