CM Epstein questions HPD on Article 11 resources and AMI structure
Epstein asks whether HPD has enough Article 11 funding for the plan. Levy says HPD was granted significant authority, is using Article 11 strategically as a bridge for acquisition with later rehabilitation, and generally targets buildings within statutory Article 11 income limits without seeing AMI as a barrier.
Thank you, Chair Sanchez.
Commissioner Levy, you mentioned Article 11 a lot, and what I've heard this year is, you know, I had a lot of buildings who wanted to get Article 11.
They didn't have enough Article 11 dollars.
I'm wondering if you feel like HPD has enough resources related to Article 11 to kind of do the...
Plan you have?
So we were very thoughtful coming into the housing plan and the executive budget about how we would use and how much Article 11 we would need.
And we have been granted quite a bit of authority there.
As you know, we're working on a number of preservation deals that are going to be highly reliant on getting those Article 11s.
And again, as we were discussing for COPA, we're starting to sort of see Article 11 as a great bridge for acquisition with then time for us to work through a capital investment for the second phase, which would be rehabilitation, both stabilizing and full rehab.
So I do feel like we are using Article 11 very strategically now, and we'll need to do so going forward as we work towards preservation of some of the buildings that I talked about that are both in foreclosure and in bankruptcy.
And some of these developments or some of these buildings have, you know, a variety of income levels in those buildings.
So how are you going to deal with Article 11 if you have higher AMIs in some of these properties?
Have you looked at changing the structure for AMIs for Article 11?
So generally in the buildings that we're approaching,
We know that they are within the statutory limits of what Article 11 allows.
I can't think of maybe one case I can think of.
I've only been here eight months, but one case I can think of where there was questions in our own mind about whether the building's residents were, frankly, over income to support an Article 11.
Generally, we're trying to target those areas where we have low-cost housing and lower-income tenants.
And I, to date, don't think we've seen it as a barrier for preservation.