PRI_WAAHMA_VAWA_1hr_2015 Final

Transcription

Presented by:
© 2015 Zeffert & Associates
All Rights Reserved
Where We Get Direction
A key to references used in this manual
VAWA
___
Statute:
 Title IV, sec. 4001-40703 of the Violent
Crime Control & Enforcement Act
with 2000, 2005 and 2103 revisions
HUD
Formal guidance:
 HUD Handbook 4350.3
"Occupancy Requirements of Subsidized
Multifamily Housing Programs"


HUD Notices
HUD RHIIP Listserv
___
_____________________
VAWA (year, as applicable)
_____________________
4350.3 (paragraph/page#)
Notice H (year/#)
RHIIP Listserv (Posting #)
HOME___________________
_
Formal guidance:
 HOME Fires Newsletter
HOMEfires (Vol, #)
Formal guidance:
 Administrative notice
RD AN (#)
RD
___________________
LIHTC___ _______________
_
_
1. Legal Authority
1.
Section 42, Internal Revenue
Code (IRC).
Additional Formal IRS Guidance:
2. Treasury Regulations
§ 42
IRS1.42 ( -1 to -17)
2. Additional interpretive resources:

8823 Guide
Additional minor revisions 3-2011
8823 Guide (chapter-page #)
Now available online at www.IRS.gov
© Zeffert & Associates
www.zeffert.com
VAWA 2013 in Affordable Housing - 2014
Introduction
The Goal of this Session
The purpose of this training is to provide information for interested personnel to successfully
provide safe affordable housing that respects the rights of victims of violence.
VAWA History
The Violence Against Women Act of 1994 (VAWA) is a United States federal law (Title IV, sec.
40001-40703 of the Violent Crime Control and Law Enforcement Act of 1994) signed by President
Bill Clinton on September 13, 1994. The original Act provided $1.6 billion toward investigation
and prosecution of violent crimes against women, imposed automatic and mandatory restitution
on those convicted, and allowed civil redress in cases prosecutors chose to leave un-prosecuted.
The Act also establishes the Office on Violence Against Women within the Department of Justice.
VAWA was drafted by the office of Senator Joe Biden, with support from a broad coalition of
advocacy groups. The Act passed through Congress with bipartisan support in 1994.
In 2000, the Supreme Court of the United States held part of VAWA unconstitutional in United
States v. Morrison on federalism grounds. A sharply divided Court struck down the VAWA
provision allowing women the right to sue their attackers in federal court as an intrusion on
state’s rights. The provisions providing program funding were unaffected.
VAWA housing provisions are found in Title VI, titled Safe Homes for Victims of Domestic
Violence, Dating Violence, Sexual Assault and Stalking.
Reauthorization
VAWA was reauthorized in 2000, 2005 and 2013. The 2005 version first introduced provisions
that applied to housing. Specifically affected were Section 8 programs and public housing. The
2013 reauthorization expanded the housing programs covered by the Act greatly.
According to HUD, VAWA 2013, among other things, “enhances judicial and law enforcement
tools to combat violence against women; improves services for victims; enhances services,
protection, and justice for young victims of violence; strengthens the health care system’s
response to violence against women; and expands protections for Native American women and
immigrants.”
Fair Housing and VAWA
HUD 2011 FHEO Notice on Domestic Violence
According the HUD Office of Fair Housing Equal Opportunity, “statistics show that women are
overwhelmingly the victims of domestic violence. An estimated 1.3 million women are the victims
of assault by an intimate partner each year, and about 1 in 4 women will experience intimate
partner violence in their lifetimes. The U. S. Bureau of Justice Statistics found that 85% of victims
of violence are women. In 2009, women were about five times as likely as men to experience
domestic violence. These statistics show that discrimination against victims of domestic violence
is almost always discrimination against women. Thus, domestic violence survivors who are denied
housing, evicted, or deprived of assistance based on the violence in their homes may have a
cause of action for sex discrimination under the Fair Housing Act.
In addition, certain other protected classes experience disproportionately high rates for domestic
violence…this means that victims of domestic violence may also have a cause for action for race
or national origin discrimination under the Fair Housing Act.”
The FHEO Notice listed 10 example cases where victims of domestic violence filed suit under Fair
Housing Sex discrimination. Some of these cases also involved VAWA protections.
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Page 1
Housing Covered by VAWA
by Version of the Act
2005
-
Project-Based Section 8
Housing Choice Vouchers
Supportive Housing for the
Homeless
Section 6 Public Housing
2013
-
Project-Based Section 8
Housing Choice Vouchers
Supportive Housing for the
Homeless
Section 6 Public Housing
Section 202 Programs
(except Direct Loan and 202/162)
-
HOPWA
Section 221(d)(3) BMIR
Programs
HOME
NA
-
LIHTC
NA
-
RHS Housing programs
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Page 2
VAWA Provisions
Prohibited Basis for Denial or Termination of Assistance or Eviction
VAWA Title VI Sec 41411 (b)
“An applicant for or tenant of housing assisted under a covered housing program may not be
denied admission to, denied assistance under, terminated from participation in, or evicted from
the housing on the basis that the applicant or tenant is or has been a victim of domestic violence,
dating violence, sexual assault, or stalking, if the applicant or tenant otherwise qualifies for
admission, assistance, participation, or occupancy.”
For the victim, incidents of violence are not serious or repeated violations of a lease or good
cause for termination of assistance or tenancy. This is true for the victim, even if the perpetrator
also live in the unit.
Lease Bifurcation
VAWA requires that leases be bifurcated, allowing eviction or termination of assistance for the
perpetrator while retaining the victim.
Definition:
Remaining members are given a chance
to qualify for the housing they reside in.
bi·fur·cate
If they do not qualify without the
verb
perpetrator, then they must be given a
1.
“reasonable time” (as defined by the
1. Divide into two branches or forks.
appropriate agency) to find other housing
or to establish eligibility under another
"Just below Cairo the river bifurcates"
covered housing program.
A victim is not protected from eviction or
termination based on their own lease violations or good cause unrelated to the violence of which
they were a victim.
Workshop:
Remaining Members
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Page 3
Documentation
VAWA Title VI Sec 41411 (c)
When a person represents themselves as a victim to an owner/agent (O/A) or Public Housing
Agency (PHA), the O/A or PHA may request, in writing, that the person submit documentation
establishing their victim status.
The person has 14 business days, after receipt of the written notice, to provide the requested
documentation. If they do not within that time frame, the O/A can proceed with denial or
termination of occupancy or assistance.
An O/A or PHA can allow more time, at their discretion.
The O/A or PHA is not required to request documentation.
Confidentiality
Documentation must be maintained in confidence and may not be entered into any shared
database or disclosed to any other entity. Exceptions are applicable if 1) the victim requests or
consents to disclosure 2) the documentation is required in the bifurcation eviction proceedings or
3) otherwise required by applicable law.
Acceptable Documentation Options
The applicable federal agency can approve a certification form that:
 States that the person is a victim of covered violence
 That the incident of violence is covered under VAWA
 Includes the name of the perpetrator if known and safe to provide
A document signed by the victim and a qualified 3rd-party:
 Victim service provider
 Attorney
 Medical professional treating the victim because of the violence
That states under penalty of perjury that they believe the person to be a victim
covered under VAWA
A record of a law enforcement agency, court or administrative agency
A statement or other evidence provided by an applicant or tenant
(accepted at O/A PHA discretion)
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Page 4
Conflicting Certifications
If the first option above results in conflicting certifications, one of the 3rd-party options can be
required.
Notification
VAWA Title VI Sec 41411 (d)
HUD is required to develop a Notice of the rights of individuals under this section, including the
right to and limits of confidentiality. This Notice, along with the Certification Form that is first on
the list of acceptable documentation options above, must be provided:
 When an applicant is denied residency
 When an applicant is admitted to the property
 When notification is given of eviction or termination of assistance
The notifications must be given in multiple
languages, as appropriate, in accordance with
HUD LEP Guidance
HUD Limited English Proficiency (LEP) policy.
HUD Notice FR-4878-N-02
Emergency Transfer
An owner must determine the language makeup
of the area where the property is located and
address the needs of those in the area who
speak limited or no English. This requires the
translation of key documents into languages
common to the area and as necessary for other
languages.
VAWA Title VI Sec 41411 (e)
Each appropriate agency (HUD, RD and the
IRS) shall adopt a model emergency transfer
plan for housing that they monitor. The plan
allows victims to transfer to another available
and safe unit assisted under a covered
program. The tenant must expressly request
the transfer, and reasonable confidentiality measures must be incorporated to prevent the
perpetrator from discovering the location of the new unit. Situations where transfer would be
allowed are:
 Where the tenant reasonably believes that they are threatened with imminent harm of
further violence if they remain or
 A sexual assault occurred on the premises within 90 days prior to the request for
transfer.
Emergency Transfer Vouchers
VAWA Title VI Sec 41411 (f)
Section 8(o) of the United States Housing Act of 1937
HUD will establish policies and procedures under which a victim requesting an emergency
transfer may receive, section 8(o) tenant protection vouchers, subject to the availability of these
vouchers.
Workshop:
Threat to Others
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Page 5
VAWA 2013
VAWA 2005 to 2013 Changes





VAWA 2013 explicitly added “sexual assault” to the list of violent crimes covered.
“Immediate family member” from VAWA 2005 was replaced with “affiliated individual”
and broadens the scope.
VAWA Definition: “Affiliated Individual”
The opportunity to
qualify for the housing
for remaining household members and to
be given a reasonable
time to find new housing after bifurcation of a lease was added in 2013.
When completing the victim Certification Form, the person claiming victim status is not
required to provide the perpetrator’s name if it is unknown or unsafe to do so.
HUD, as opposed to each O/A PHA, is now required to develop a Notice of VAWA rights
and responsibilities to applicants and tenants.
“Self-Executing”?
HUD Notice 8-6-13
VAWA 2005 was determined by HUD to be “self-implementing.” In other words, owners were not
to wait for regulatory guidance to implement provisions of the law, as the actual Section 8 and 6
laws were amended by VAWA to conform. VAWA 2013, however, did not make conforming
changes to the other program laws, and is not “self-executing.” Regulatory guidance will need to
be given for owner to accurately apply parts of the law.
Until HUD issues its model transfer plan, for HUD housing, “PHAs, owners, or managers may
continue to implement any transfer plan at that property/program as described in an agency’s
admissions and occupancy plan or administrative plan.”
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Page 6
VAWA Model: Section 8
HUD
4350.3 Change 4 Chapters Affected: 4, 6 and Glossary
Original Sources: VAWA Final Rule Issued 10-27-10
HUD Notice 12-09
It is the 2005 version of the law that Change 4 deals with.
Important Note: We will need to wait for further guidance for the application of the 2013 law to
the recently-covered HUD programs. For now, the HUD handbook VAWA instructions should only
be applied to Section 8 projects.
VAWA and Tenant Selection Plan Basics…
4-4 A, B, E &F / 4-3 & 10
Owners MUST develop a public written tenant selection policy. It is not required that HUD
approve this policy. The plan should be reviewed annually and the plan should be available to the
public.
The REQUIRED topics that we will discuss next involve topics from all over the handbook that we
discuss in other sections. Numbers 3 and 7 relate to the waiting list and are detailed in chapter 4.
We will focus on these later in this chapter.
Required Contents of the Tenant Selection Plan
4-4 / 4-3 to 4-10 Figure 4-2 A / 4-5
Where discussed in 4350.3
1. Project Eligibility Requirements
(Chap. 3)
1. Project Specific Requirements (Example: Elderly or disabled designation)
2. Citizenship Requirements
3. SSN Requirements
2. Income Limits for Your Project
(Chap. 3)
3. Waiting List/Admission Procedures
(Chap. 4)
1. Taking Applications
2. Preferences That You Use
3. Screening Criteria (including Existing Tenant Search)
4. Rejecting Applicants
4. Occupancy Standards
(Chap. 3)
5. Unit Transfer Policies
(Chap. 7)
6. Fair Housing Act & 504 Compliance
(Chap. 2)
7. Procedures for Opening /Closing Wait List
(Chap. 4)
8. Eligibility of students
(Chap. 3)
9. Policies for applying VAWA protections
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(Chap. 4 & 6)
Page 7
Required Tenant Selection Policy Topic # 9
Policies for applying VAWA protections
VAWA
4-4 C 9/4-8 to 10
The Violence Against Women Act (VAWA) requires that the Tenant Selection Plan and House
Rules must include policies to support or assist victims of domestic violence, dating violence or
stalking and protect victims and their families from being denied housing or from losing HUD
assisted housing as a consequence of domestic violence, dating violence or stalking.
Tenants must be informed of their rights and obligations under VAWA. They must also be given
the option of completing form HUD-91066, Certification of Domestic Violence, Dating Violence or
Stalking. Opportunity to complete must be provided at:
 The time of admission to the property
 At the start of eviction proceedings, with a 14-day deadline to supply the form. An owner
may extend the deadline at their discretion.
 Other paperwork may replace the form (police reports, letters from victim service
providers, attorneys, medical professionals, etc.)
 Owners are not required to demand proof. At their discretion, they may provide
assistance based on self-statement. Care should be taken to evaluate abuse claims mad
to avoid eviction.
 The form should not be mailed if doing so puts the victim at further risk. Discuss
alternatives.
 Confidentiality should be maintained, per the limits listed on the form. The form should
be maintained in a secure file separate from the other tenant files.
Preferences and Protections
4-6 C 4 / 4-17 & 4-9 A/4-26
Owner-adopted occupancy preferences may be established for victims of violence. Applicants and
tenants must not have admission or assistance denied solely because of an incidence of violence
of which they or members of their immediate family were a victim.
Leasing
Documents to Accompany the Lease
Documents
Figure 6-9 / 6-47
Chapter 6 References (if applicable)
Lease, with the 50059 or HUD 50059-A
Move-in inspection form
Consent forms
Lead-Based Paint Disclosure Form (if applicable)
Lead Hazard Information Pamphlet (if applicable)
House Rules (if developed)
Pet Rules (if applicable)
Police/Security Addendum (if applicable)
Live-in Aide addendum (if applicable)
HUD/VAWA Lease Addendum
6-29 / 6-42 to 44
6-8 / 6-14 to 17
6-8 / 6-14 to 17
6-9 / 6-17 to 20
6-10 / 6-20 to 25
6-4 C / 6-5
EIV & You brochure
Resident Rights and Responsibilities brochure
How Your Rent is Determined fact sheet
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6-27 B 1 j / 6-43
6-27 B 1 i / 6-43
Page 8
VAWA HUD Form 91067
6-4 C / 6-5 Figure 6-3
This lease addendum is designed to apply VAWA 2005. The addendum must be completed and
attached to each Section 8 lease.
VAWA Protections
6-5 G / 6-12 to 13
The VAWA addendum enforces legal protections under VAWA including that a tenant may not be
evicted for incidences of violence where they were the victim, even if the perpetrator is also a
household member. Victims are not protected from their own criminal acts by virtue of their
victim status. If an owner can prove that an imminent threat to other tenants exists if the victim
is not evicted, there may still be grounds for legal eviction.
A lease may be “bifurcated” in order to remove an offending household member from the unit
without removing the victim(s). The owner is to honor court-orders regarding the distribution of
property as a result of the eviction.
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Page 9
Where We Stand
HUD
…Section 8
VAWA Final Rule Issued 10-27-10
4350.3 Chapters 5,6 and Glossary
VAWA 2005 provisions for Section 8 properties have been established through HUD Notice and
have been incorporated into HUD handbook 4350.3 (see “HUD Model” section above).
…Other HUD Programs
HUD Notice Published 8-6-13
HUD solicited comments on the application of VAWA 2013 to newly covered HUD programs. A
final rule has not been issued. It is anticipated that the policies and procedures set up for the
Section 8 program in the 4350.3 will be applied without a lot of modification.
Pending Issues…
Areas that HUD made specific requests for comment:
1. What period would be reasonable to find new housing or establish eligibility
under another HUD covered housing program?
2. How can form 91066 can be adapted for the newly covered HUD programs?
3. What content should be included in the notice of tenant’s rights?
4. What content should be included in the model emergency transfer plan?
RD
RD AN 4747
On February 10, 2014, RD published an administrative notice with a Model Emergency Transfer
Plan as Attachment B to the AN (see supplemental information at the end of this Handout for the
Model Plan).
RD clarified that no changes need to be made to Tenant Leases, Occupancy Rules or the
Management Plans at this time (AN 4747 page 2). However, later in the AN, it is suggested that
Occupancy Rules should be revised, as necessary,
3560.158(d)
Leases may be bifurcated, per VAWA. Victims who stay in the unit are to be addressed per
current rules for “Remaining Members.”
HB-2-3560 6.30 D / 6-41
RD Rules for “Remaining Members”
Members of a household residing in a multi-family housing project may continue to occupy the
unit after the departure of the original tenant, regardless of age, provided that:
 They are eligible with respect to income
 They were either a cotenant or member of the household, have the legal capacity to
sign the lease, and are U.S. citizens or qualified aliens
 They occupied the unit with the original tenant at the time the original tenant departed
 They sign a new tenant certification establishing their own tenancy, and
 They have the legal ability to sign a lease for the rental unit, except where a legal
guardian may sign when the tenant or member is otherwise eligible
Remaining household members that are over housed must move to a suitably sized rental unit
within 30 days of its availability. If a suitably sized unit does not exist at the property, the tenant
will be required to vacate the property in accordance with Paragraph 6.32 A.
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Page 10
Suggested Actions
RD AN 474, page3
“Owners and managers of housing affected by the VAWA Act should update their Tenant
Selection Policy and Occupancy Rules, if applicable, to incorporate the tenant’s rights and
protections, to ensure uniformity in spreading awareness of the VAWA Act, and to avoid improper
evictions.”
RD with Section 8 Assistance
Owners and managers of housing covered by this AN, and that receive Section 8 assistance,
should comply with any HUD requirements. HUD currently utilizes Lease Addendum, Form HUD
91067, which includes certain rights and provisions of the VAWA Act.
Housing Preservation Grants
The ownership agreement between the HPG grantee and rental property owner or co-op should
include a clause that the owner(s) agrees and certifies that the assistance being made available
is subject to the VAWA Act.
The Grant Agreement should be amended using as a model Exhibit B of subpart N of 7 C.F.R.
part 1944, to state that the HPG grantee shall comply with the VAWA Act and should include a
clause in the ownership agreement that the assistance being made available is subject to the
VAWA Act. Any amendments will require Rural Development’s approval.
Pending Issues…
Per page 3 of AN 4747, we are waiting on two agencies to fully implement VAWA for RD:
HUD: once HUD publishes the Individual Rights under VAWA notice, RD will
implement it and amend AN 4747.
RD: RD has not developed their version of the Certification for use by victims.
Once this form is developed, RD will amend AN 4747.
HOME
HOMEfires Vol. 11 #1
HUD Notice Published 8-6-13
The above-mentioned HUD Notice published 8-6-13 also applies to the HOME program. HUDs
rulemaking process and final regulations will apparently cover HOME along with HUDs MultiFamily and Public Housing programs.
HUD 2011 FHEO Memo on Domestic Violence
The HOMEfire does contain the following reminder.
“If a housing provider refuses to rent, evicts, or otherwise treats someone differently because of
that person’s status as a victim of domestic violence, dating violence, sexual assault, or stalking,
HUD or the courts may find a violation under the Fair Housing Act due to direct discrimination,
unequal treatment, or disparate impact.”
LIHTC
VAWA Non-Compliance and Section 42
VAWA Sec. 41411 (b) CONFORMING AMENDMENTS (C)(3)
§42 (g)(9) IRS Reg 1.42-9(a) 8823 Guide Chapter 13
HUD 2011 FHEO Notice on Domestic Violence
Lack of compliance with VAWA is not grounds for loss of the Low Income Tax Credit. However, if
HUD, a substantially equivalent agency or the Department of Justice find that violations of
victims’ rights led to discrimination under the Fair Housing Act, Tax Credits may be at risk under
the Section 42 General Public Use regulation. Note: an actual finding of discrimination results in
the loss of credits. However, if HUD or DOJ starts an investigation, they will inform the state HFA,
who will report it to the IRS on form 8823, (see the Memorandum Of Understanding between the
IRS, HUD and DOJ reproduced in the 8823 Guide as Exhibit 13-2).
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Page 11
IRS Responsibility
It is of note that VAWA did not change the actual Section 42 statute with conforming language,
as it did the Section 8 and 6 programs. As a federal agency, the IRS’ primary purpose is, not to
provide housing, but rather to enforce tax law. Because of the unique structure of the LIHTC
system, it is not clear that the IRS is an Appropriate Agency that ‘carries out’ the housing under
the meaning of VAWA Title VI Sect 41411 (a)(2). For these reasons, the IRS examining branch
has verbally expressed reluctance to propose specific VAWA provisions and possibly exceed their
authority. The primary guidance lacking for LIHTC housing will be the Certification Form from
VAWA Title VI Sec 41411 (c) and the model emergency transfer plan (e).
State HFA Responsibility
For the same reasons that it is unclear what the IRS’ required involvement in VAWA is, the role of
the state Housing Finance Agencies that work with the IRS to allocate and monitor compliance
with Section 42. As agents tasked with reporting noncompliance with Section 42, the VAWA may
well be beyond their mandate.
There is some advocacy pressure on HFAs to use their authority and influence to further the
cause of VAWA. Suggested actions for HFAs to take include:
Allocation
 Ensuring that policies are in place that define “special needs populations” to include
victims of violence, to avoid any general public use issues under Section 42.
 Qualified Allocation Plan points awarded for creating housing with preferences or
restrictions to victims of violence covered under VAWA.
 Establishing and enforcing requirements that developers applying for credits will attest
that they will apply VAWA laws.
Monitoring
 Providing notices to owners regarding their responsibilities under VAWA.
 Adding VAWA questions to the Owners Certification of Continuing Compliance or other
required certification.
 Requiring lease addenda or tenant selection plans provisions.
 Providing victim Certification Forms and model emergency transfer plans until such time
as the IRS does so.
Owner Responsibility
Faced with a lack of direction from HUD and the IRS, many owners are choosing to:
 Implement a victim Certification Form similar to the HUD 91066.
 Educate staff on VAWA requirements. Especially in cases of denying entrance or evictions
where violence may be a factor, an owner may consider having a specialist person or
persons to handle the situation.
As the statute clearly makes it HUDs responsibility, owners are not generally obligated to provide
a Notice of VAWA rights and responsibilities. Providing Form 91066-similar form fills this function
to some degree. As Section 42 allows the owner to develop leases, with only minimal nontransience and Fair Housing Act requirements, they may choose to implement VAWA language,
with legal counsel or state HFA input. Again, the HUD Form 91067 provides a template for model
language. However, note that RD did not see it necessary to implement lease adjustments at this
time, despite the availability of the HUD form. The statute clearly makes an agency responsible to
develop a model transfer plan. Until such time as one is provided for the LIHTC, simple
adjustment to current transfer policies may be in order.
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Page 12
A Few Words of Encouragement…
We Do this Job Well…
Violence is a major concern for housing providers, as is compliance with applicable laws. As such
a large portion of the American population are victims of violence, there is a good chance that
you or your loved ones will be a victim as some point. Hopefully the application of the letter and
spirit of VAWA will make your community safer and help protect everyone’s rights, including your
own.
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PRI_WAAHMA_VAWA_1hr_2015 Final

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