[FoCHAT] CHAT: We remember a pro-applicant policy that disappeared like 1000's of dispute resolution cases
Melanie Ehrlich
mehrlich8 at yahoo.com
Tue May 27 21:34:17 PDT 2008
Friends of CHAT,
1. Please write one email to members of the Senate Finance Committee on Wednesday (later may be too late) to support the Road Home Applicants' Bill of Rights, SB 740. It has been considered by that committee twice and is close to passing that committee and going on the to full Senate. It needs to be voted on by Senate Finance this week.
There was some LRA misinformation piled on top of misinformation today. The fiscal note for this bill was reduced from $3 billion to less than several million as discussed in that committee.
Here is a sample letter that you can copy for the Senate Finance Committee and add any of your own experience or you can write your own email:
Dear Senators,
Thank you for the time that you are spending on the Road Home Applicants Bill of Rights, SB 740. The Road Home has enough money for this bill to help thousands of applicants who have pleaded for a chance to have corrections in their grants but been ignored and deprived of that right.
Thank you,
The addresses are:
lasen23 at legis.state.la.us;
jacksonl at legis.state.la.us; donahuej at legis.state.la.us;
alarioj at legis.state.la.us; lasen15 at legis.state.la.us; smithcheek at legis.state.la.us; gautreauxn at legis.state.la.us;
lafleure at legis.state.la.us; murraye at legis.state.la.us;
smithj at legis.state.la.us; walsworthm at legis.state.la.us; longg at legis.state.la.us;
lasen27 at legis.state.la.us;
thompsof at legis.state.la.us
2. We hope that the revocation of a fair Road Home rule in effect since Nov. 11 (field review of homeowner-purchased appraisals that are more than 20% higher than Road Home's valuations) will be revoked to restore 3 months of a fair policy.
ON MARCH 4, 2008 WITH NO NOTICE TO THE PUBLIC, LRA REVOKED ONE OF THE NEW APPLICANT-FRIENDLY AND FAIR POLICIES DESCRIBED BELOW, 188G, FIELD REVIEW APPRAISALS EVEN THOUGH IT WAS WORKING WELL TO OBJECTIVELY FIX ERRORS IN ROAD HOME'S HOUSE VALUATIONS..
NOTE THAT NO NOTIFICATION BEYOND THE PRESS RELEASE BELOW WENT OUT TO APPLICANTS ABOUT THESE HELPFUL AND LONG-OVERDUE POLICIES CONTRARY TO WHAT WAS PROMISED IN THE PRESS RELEASE.
NOTE THAT THE HUD POLICY BOOK MAKES NO REFERENCE TO A 20% CAP AND THAT LRA HAS GOTTEN HUD IN THE PAST TO ACCEPT MAJOR POLICY CHANGES THAT IT WANTED ACCEPTED.
NOTE THAT OCD-LRA ADMITTED TO MEMBERS OF THE WORKING GROUP OF THE HOUSING TASK FORCE OF LRA IN A CONFERENCE CALL THAT THE 20% CAP WAS THEIR ARBITRARY CHOICE.
NOTE THAT INITIALLY OCD-LRA STATED THAT NO HOMEOWNER-PURCHASED APPRAISALS WOULD BE ACCEPTABLE TO HUD, BUT THAT RULE FINALLY CHANGED WITH ADVOCACY BY CHAT AND OTHERS.
NOTE THAT IT IS COMPLETELY ARBITRARY TO REJECT A HOMEOWNER PURCHASED FULL, CERTIFIED APPRAISAL THAT IS 21% HIGHER THAN THE INFERIOR TYPE OF EVALUATIONS CONDUCTED BY ROAD HOME, OFTEN WITH BLATANTLY POOR COMPARABLES, BUT TO ACCEPT ONE IF IT IS ONLY 20% HIGHER.
ABOUT THE WRITTEN DOCUMENTATION RULE DESCRIBED IN THE PRESS RELEASE, SOME APPLICANTS ARE GETTING COPIES OF THEIR FILES BUT MANY ARE REFUSED THIS INFORMATION, AND MANY ARE STILL GETTING THE UNTRACEABLE PHONE CALLS TO INFORM THEM OF MAJOR POLICY DECISIONS.
LASTLY, WE ARE HEARING OF APPLICANTS SUMMARILY TOLD RECENTLY THAT THEIR DISPUTE RESOLUTION OF MORE THAN ONE YEAR IN LIMBO WAS "RESOLVED" AGAINST THEIR FAVOR BUT WITH NO EXPLANATION. THIS IS INCONSISTENT WITH THE "DETAILS" PROMISED ABOUT DISPUTE RESOLUTION DECISIONS BELOW.
ARE THESE NEW OVERDUE NOTICES OF DISPUTE RESOLUTION WITH NO DETAILS ABOUT THE RESOLUTION, THE ATTEMPT OF ICF, WITH LRA'S APPROVAL, TO RETROACTIVELY MEET ITS AUG. 1 DEADLINE FOR NO DISPUTE RESOLUTION CASES GREATER THAN 2 MONTHS OLD. SEE OUR WEBSITE FOR THE DOCUMENTATION OF THOUSANDS OF DISAPPEARING DISPUTE RESOLUTION CASES JUST IN TIME FOR ICF TO AVOID A FINE?
http://page.thinknola.com/wiki/show/Citizens%27+Road+Home+Action+Team#improprieties
ICF'S DEADLINE TO PROVE THAT IT MET ITS BENCHMARK OF NO DISPUTE RESOLUTIONS MORE THAN 2 MONTHS OLD WAS EXTENDED MANY TIMES SINCE THAT AUG. 1 DATE. APPLICANTS ARE TREATED WITH MUCH LESS CONSIDERATION WHEN IT COMES TO THEIR APPEALS' DEADLINES TO FIX ROAD HOME'S MISTAKES.
NOTE THAT WHAT IS POSTED BELOW IS AN OLD PRESS RELEASE
Friday, December 21, 2007
MEDIA CONTACT:
Melissa Landry
Louisiana Recovery Authority
225 342 1788
melissa.landry at la.gov
LRA and OCD Highlight Changes to Assist Road Home Applicants
NEW ORLEANS (December 21, 2007) - Today the Louisiana Recovery Authority (LRA) and the Office of Community Development (OCD) highlighted two important changes that have recently been made to the Road Home program to assist applicants.
"These common-sense changes were requested by advocates and jointly drafted by the LRA and OCD staff as proposed by the LRA's Housing Task Force," said Walter Leger, Chair of the LRA Housing Task Force. "We believe that it's critical that ICF works quickly to make sure that every member of their staff is knowledgeable about these policies so they can give homeowners timely and accurate information."
FIELD REVIEW APPRAISALS
The Road Home program is now conducting Field Review Appraisals for applicants who provided their own post-storm appraisals that were not accepted by the Road Home. The Road Home estimates there are less than 200 homeowners that currently fall into this category. The Field Review Appraisal process is automatically triggered when a homeowner submits their own post-storm certified appraisal that exceeds 120% of the pre-storm value as determined by the Road Home program. Applicants with such appraisals should submit them to an ICF staff member in Dispute Resolution, who will schedule a field review appraisal by a Louisiana certified appraiser to validate the homeowner's certified appraisal. The change enables the Road Home to use independent Louisiana certified appraisers to review whether a homeowner's appraisal is valid as the pre-storm value for grant calculation.
In addition to this new procedure, for applicants who are currently in Appeals to dispute their pre-storm value, the Road Home program will now offer the option of having a full appraisal, known as a 1004 appraisal which is provided by the Road Home Program and conducted by a Louisiana certified appraiser.
This procedure is now in place and was effective as of November 9, 2007. All homeowners are being notified of this change and homeowners with questions are encouraged to contact a member of the dispute resolution staff of the Road Home.
WRITTEN DOCUMENTATION
In an effort to increase outreach to applicants and assist them to better understand their status in the Road Home program, this change provides a homeowner with written documentation at various stages of the Road Home process. Effective as of January 1, 2008, there are three key points of information that this change of communications will address:
The exact amount of grant awards under options 1, 2, and 3.
Details about dispute resolution status and outcomes.
Current status of the application and details about any information found to be missing from it.
The Road Home program will continue to provide homeowners with supporting documentation used to determine the following at all stages of the process.
Pre-storm value
Estimated Cost of Damages
The Road Home Program was designed by the LRA and is administered by the Division of Administration's Office of Community Development (OCD) and its contractor, ICF International.
"We fully support any effort to increase the homeowner's ability to make informed decisions about their grant awards," said Michael Taylor, director of the Disaster Recovery Unit, Office of Community Development.
"Homeowners can now expect to get all the data for determining their grant award and commitments from Road Home staff in writing, and they can expect to get independent appraisals on their homes, said Melanie Ehrlich, a member of the LRA's Housing Task Force and Co-Chairman of the Citizens' Road Home Action Team (CHAT). "These new policies are important, and we want to make sure that homeowners know that these changes are now in place."
3. A comparison of the latest and the previous policy document from Road Home. Thanks to CHAT member Laura LeBon!
http://road2la.org/Docs/policies/Homeowner_Program_Policies%20v5.2_5-6-08.pdf
In Version 5.2 of the Road Home Policy Document, see Description of Revisions.
Section 1: Eligibility Requirements to Apply for Program
Section 2: Ownership
This section appears to be new. It goes into great detail to explain what happens in each predictable situation (Doubles, condos, death of applicant, etc.).
Section 3: Eligibility Requirements to Receive Assistance
Section 4: Deadlines Established for the Road Home
This section is new.
Section 5: Withdrawn Applications
This section is new.
Section 6: Applicants Assistance Options
This section is new and contains information on the types of options each type of situation (single home, condo) can choose.
Section 7: Funding Assistance Options:
Mitigation grant info has been removed.
Section 8: Inputs Necessary for Calculation of Awards
This is Section 5 in Version 4.0. There is a new paragraph about SBA loans under 8.3 - Other Compensation. In a nutshell it says that SBA considers Road Home to be a duplication of their benefits and explains what to do.
Section 9: Single Unit Structures and Town Homes
This is Section 6 in Version 4.0. The big change here is in the second paragraph. In 4.0, RHP threw the post-storm appraisal out if it wasnt in their acceptable range of the BPO. In 5.2, RHP initiates the Field Review Appraisal to determine If the post-storm appraisal is valid if it is more than 20% higher than Road Homes pre-storm value. It is important to note that in no other section (doubles, condos, mobile homes) did this change take place.
In Pre-Storm Value before January 12, 2007" the 12th was changed to 14th in 5.2.
The Field Review Appraisal Process for Applicant Submitted Post-Storm Appraisals, Review of Pre-Storm Value during Resolution, Appealing Pre-Storm Value Determination paragraphs are new.
In Estimated Cost of Damage, the list of Other Compensation is new.
There are changes to Option 2 applicants.
Section 10: Double Unit Structures
This is Section 7 in Version 4.0.
Program Requirements has been removed.
The ECD paragraph Evaluation Type 1" is slightly different in calculation. It includes money for a house raising survey and 2% added for builders risk. Single Units and Town Homes had this included in 4.0.
Just as in the Single Units and Town Homes section, the Other Compensation paragraph has been added.
Section 11: Site Built Homes on Leased Land
This is Section 9 in Version 4.0. There appears to be less information here than was available in Version 4.0.
Section 12: Manufactured Housing (Moble Homes) on Owned Land
This was part of Section 10 in Version 4.0. Consider this entire section new and read through it. Version 4.0 dealt with these homes in much the same manner as Single Unit. This one has rules that apply to the type of structure it is.
Section 13: Manufactured Housing (mobile homes on leased land)
This was the other part of Section 10 in Version 4.0. This hasnt changed as much, but it does contain more structure-specific rules that Version 4.0.
Section 14: Condominiums
This was Section 8 in Version 4.0. This section really is completely new.
Section 15: Assignment
Section 16: Murphy Oil Spill
The wording of the last two paragraphs has changed. Im not sure why because it does not appear to have a significant impact on anything.
Section 13 from Version 4.0 is missing. This is the section that deals with Individual Mitigation Measures (IMM) Program.
Section 17: Benefit Selection Process
This is Section 14 in Version 4.0
The paragraph about the No Funding Letter now describes the inactive status of these applications.
The paragraph describing the Additional Mitigation Grant was removed.
Melanie Ehrlich
Co-Chairman, CHAT
http://chatushome.com
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