May/June 2019, Volume 7 Issue 09
FAQs: Inquiring Minds Want to Know
How can I ensure that my agency is able to access the eLOCCS system as soon as possible once we sign the Comprehensive Housing Counseling Grant Agreement?
Agencies often experience difficulties accessing the electronic Line of Credit Control System (eLOCCS) as a result of Approving Officials and Users not accessing the system regularly. Please note that if either an Approving Official or User does not access these systems every 90 days, their access will be suspended. It is highly recommended that Approving Officials and Users log in to Secure Systems and access eLOCCS every month to ensure that they are not terminated due to inactivity. The instructions to reinstate these users can be found in the eLOCCS Access Guidelines for Grantees.
During the period between a grantee’s last draw under a previous grant, and before signing a new grant agreement, the agency should assure that both Approving Officials and Users access the system at least every 90 days.
The agency’s business partner information should be reviewed to ensure that it remains current. This includes:
- Opening the ‘General’ tab and checking that the agency address, Tax ID, and contact information are correctly reflected
- Opening the ‘eLOCCS Users’ tab and confirming that the Approving Official and all other users are accurately reflected and active in both Secure Systems and eLOCCS
- Opening the ‘Banking’ tab to assure that the correct account information is reflected
If any of this information needs to be updated, please review the following eLOCCS guidance documents:
- eLOCCS Quick Reference Guide
- eLOCCS Access Guidelines for Grantees
- eLOCCS Getting Started Guide
- eLOCCS Registration Guide
If you have any specific questions, please reach out to your agency’s Point of Contact (POC) at the Office of Housing Counseling (OHC).
Our agency, an SHFA, was not awarded a HUD Comprehensive Housing Counseling grant. Must we still perform oversight activities over our network of agencies?
Yes, a State Housing Finance Agency (SHFA) participating in HUD's Housing Counseling Program must perform oversight activities over its network of affiliates. Even if an agency does not receive HUD funding in a particular grant year, any agency participating in the Housing Counseling Program is subject to HUD requirements. According to HUD Housing Counseling Handbook 7610.1 REV-5, it is the responsibility of the intermediary entity to evaluate initial and ongoing eligibility and ensure compliance of branches and affiliates in its network.
When billing for reimbursement of qualified time/activity, can grantees bill HUD a combined hourly rate that consists of both base salary and fringe, or does the agency need to itemize (i.e., break down) the expenses?
According to the FY 2018 Grant Agreement, grantees must identify each counselor or other employee whose time/activity is being billed to the grant; the individual’s title and the hourly billing rate used to calculate the reimbursement from HUD or an intermediary organization for that individual’s time/activity; or, in the event of fixed-priced reimbursement, document actual expenses (which must be reasonable and do not exceed actual cost). The agency must explain the method used for calculating hourly rates, e.g., whether benefits are included in the rate.
When documenting actual costs, the grantee must submit a detailed, comprehensive, itemized accounting of actual costs, listing expenses for each distinct quarter and the grant period to date under the grant. At a minimum, the accounting must include the following (if applicable): salaries, fringe and other benefits, training, marketing, outreach, and indirect costs. The accounting must itemize the expenditure of each dollar being billed to the grant. The itemized accounting of actual expenses may be submitted on form HUD-424 CB, or in a format of the grantee’s choosing if the form HUD-424 CB does not provide enough detail. Any deviation between the itemized accounting of actual costs and the budget submitted at the time of grant execution must be explained in detail and approved by the agency’s Point of Contact (POC).
In this year’s grant application, I indicated that my agency would provide default counseling to reverse mortgage/HECM clients. How do I report this information?
HUD collects grant reports throughout the period of performance. When submitting your progress report and requesting drawdowns, agencies providing reverse mortgage and Home Equity Conversion Mortgage (HECM) default counseling should include a short narrative indicating: (1) the name of counselors providing such services, (2) the title and duration of any reverse mortgage trainings taken during the three years prior to the end of the period of performance, and (3) the total number of HECM default clients who have received counseling during the period of performance.
Currently, HUD-9902 Section 9 does not have a separate category for HECM default clients, so agencies providing HECM default counseling will need to report such clients under item 9f (Resolving or Preventing Mortgage Delinquency or Default). Additionally, such agencies must provide the information outlined above to their HUD POC during grant quarterly reporting. If funded for default counseling in FY 2018, agencies are reminded that they must counsel a minimum of ten HECM Default clients per year, starting October 1, 2018 to September 30, 2019, to remain eligible for the award bonus.
Can an intermediary/SHFA advance actual costs to its subgrantees (upon receipt of required activity documentation) and then reimburse itself with HUD draw down?
Yes, intermediaries and State Housing Finance Agencies (SHFAs) may be reimbursed for actual costs incurred when they advance funds to subgrantees for eligible grant expenses. The agencies should consult their grant agreements, the HUD Housing Counseling Handbook 7610.1 REV-5, and the Housing Counseling Program regulations to ensure that they are only covering eligible expenses (i.e., for approved housing counseling services) and are requesting the appropriate supporting documentation (including, but not limited to, timesheets, personnel activity reports, receipts, etc.). Agencies should also outline this arrangement in their subgrantee agreements and reference the aforementioned documents. If the agency seeks reimbursement from HUD for ineligible costs, those costs will not be reimbursed. For more information regarding eligible expenses, please review the October 30, 2018 Preparing a Budget Training or contact your Point of Contact (POC) at the Office of Housing Counseling (OHC).
Are costs associated with an agency’s housing counseling Client Management System eligible to be billed to the FY 2018 Comprehensive Housing Counseling Grant?
Yes, costs related to your agency’s housing counseling Client Management System (CMS) are billable as a direct cost to the FY 2018 Comprehensive Housing Counseling Grant, as the use of a CMS is a necessary part to oversight, compliance, and quality control. Please see FAQ 3447 regarding reimbursable costs for the FY 2018 Comprehensive Housing Counseling Grant.
Are sub-grantee housing counseling agencies subject to the same FY 2018 eligible costs policies as their parent agency?
Yes, grantees and sub-grantees will be reimbursed only for the applicable activities outlined in the FY 2018 Comprehensive Housing Counseling NOFA and the grant agreement, and that grantees shall ensure that all sub-grantees comply with the provisions of cost reimbursement. Please see FAQ 3447 regarding reimbursable costs for the FY 2018 Comprehensive Housing Counseling Grant.