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Homes and Community Renewal

Unified Funding Common Application Flaws

Technical Services Unit
Issued November 2007
UF 2008


Common Underwriting Application Flaws

1. DHCR Reserve Requirements Not Met (CPM Sections 2.01.04.A , 5.06 (iii), and 5.07.06 (iii) )

HTF/HOME projects

LIHC/SLIHC Only Projects

2. Insufficient or Inconsistent Operating Budget Documentation (CPM Section 5.06 iii)

3. Rents Do Not Support Operating & Maintenance Budget (CPM Section 5.06 ii)

4. Market Not Documented or Supported (CPM Section 5.06 i)

5. Insufficient Capital Funds (CPM Section 5.06 iv)

6. Separate Residential/Commercial/Community Service Facility (CSF) Budgets Not Submitted (CPM Section 5.06 ii & HTF/HOME Project Application I- General Instructions for Exhibits 3 and 5)

7. Other Application Flaws


Common Design Flaws

1. Non-compliance with Section 5.03, Site Suitability, of the Capital Programs Manual

2. Non-compliance with Section 4 of the Design Handbook

3. Non-compliance with Building Codes, Regulations & Laws (Design Handbook Section 4.02)

Common deficiencies:

4. Inadequate preliminary design submission (Design Handbook Section 3.01.01)

5. Construction Cost (Design Handbook Section 3.01.01)

6. Local and Government Approvals (Design Handbook Section 4.02)

7. Physical Needs Assessment (Attachment E7)

8. Green Building Initiative


Common Environmental Submission Flaws

  1. Exhibit 3 - Development Budgets/Funding sources: Failure to include costs for environmental investigations and remediation.

  2. Exhibit 8 - Site and Building Information: Sections A and B incomplete, failure to fully describe site characteristics and existing building information.

  3. Attachment A2 - Zoning Compliance: Failure to provide documentation that the project site is or will be properly zoned for the proposed project.

  4. Attachment A3 - Public Approvals: Failure to provide documentation of all required local approvals, such as site plan approval and subdivision approval, that have been obtained or are in the process of being obtained.

  5. Attachment A4 - SHPO Submission: Incomplete submission information for SHPO Consultation. Copy of final "Determination" letter not submitted with application.

  6. Attachment A5 - State Environmental Quality Review (SEQR) Submissions:

    • Failure to submit signed, SEQR Short Environmental Assessment Form (EAF).

    • Failure to include pertinent information and documentation of previously completed or on-going SEQR or NEPA (National Environmental Policy Act) determination completed by other entities having jurisdiction.

    • Failure to adequately describe the entire scope of project activities, e.g. site work, demolition, or if the project is a component of a larger action.

    • Failure to include documents regarding asbestos and lead based paint surveys, removals and clearance certifications for work completed prior to application.

    • Failure to include an entire copy of any Phase I reports that was completed in the previous year.

  7. Attachment A6 - Environmental Approvals: Failure to provide documentation that all required environmental approvals, such as a wetlands or SPDES permit, have been obtained or are in the process of being obtained.

  8. Attachment B1 - Outline Specifications: Failure to include sufficient information regarding scope of work in Section 2, Site Work; i.e. demolition, site preparation.

  9. Attachment B3: Failure to include a preliminary Site Plan.

  10. Attachment B-5: Failure to include a map accurately showing the location of the project site.

  11. Attachment B-6: Failure to include a Floodplain letter stating FIRM panel # and date.

  12. Failure to address identifiable site concerns, ie:

    • Archaeological
    • Historic properties
    • Location in a 100-year Floodplain/Waterfront/Coastal Zone
    • Wetlands and Stormwater
    • Noise
    • Hazardous Materials (underground storage tanks, contaminated soil, asbestos, lead based paint, etc.)
    • Agricultural Districts/Farmland Protection
    • Endangered species letter from Natural Heritage and FWS

NOTE: Applicants should refer to section 5.01 thru 5.03 of the current Capital Programs Manual for further information and clarification of the environmental review process.

Davis Bacon

Common Davis-Bacon Application Flaws

  1. Failure to include costs for Davis Bacon. All "unified funded projects" financing 12 or more units with HOME funds (obtained from any source), including Seed Money, the Leveraged Loan Program or administered by Local Program Administrators must comply with Davis Bacon Related Acts & Federal Labor Standards Reporting. Project Based Voucher projects have a similar 9 or more unit reporting threshold.

  2. Exhibit 1: Failure to identify Davis-Bacon Wage Rates on Section H, Project Costs.

  3. Exhibit 3 and Attachment E-1 (Construction Cost Estimate):

    • Failure to budget appropriate labor and associated costs.
    • Failure to request labor wage rate lock-in if general contractor has been preselected.
    • Failure to distinguish between "Residential" rates (for buildings with four or fewer stories) or "Building" rates (for buildings with five or more stories, as defined by US Dept. of Labor, or buildings that contain commercial space).

Last updated on 11/07/07