Agenda packet, joint meeting — Glendale City Council, May 5, 2026 (part 7 of 8)

17-VI.F. HOUSING SEARCH AND LEASING
Initial Voucher Term
Unlike the standard HCV program, which requires an initial voucher term of at least 60 days, SV vouchers must have an initial search term of at least 120 days. PHA policies on extensions as outlined in Section 5-II.E. will apply.

Pre-Inspections
To expedite the leasing process, PHAs may pre-inspect available units that SV families may be interested in leasing in order to maintain a pool of eligible units.

Initial Lease Term
Unlike in the standard the HCV program, SV voucher holders may enter into an initial lease that is for less than 12 months, regardless of the PHA policy in Section 9-I.E., Term of Assisted Tenancy.

Exhibit 2
867 of 1125

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Portability
The normal HCV portability procedures and requirements outlined in Chapter 10 generally apply to SVs. Exceptions are addressed below.
• Under SV, applicant families may move under portability even if the family did not have legal residency in the jurisdiction of the initial PHA when they applied, regardless of PHA policy in Section 10-II.B.
• A receiving PHA cannot refuse to assist an incoming SV family, regardless of whether the PHA administers SVs under its own ACC.
• If the SV family moves under portability to another PHA that administers SVs under its own ACC:
- The receiving PHA may only absorb the incoming SV family with an SV (assuming it has an SV voucher available to do so).
- If the PHA does not have an SV available to absorb the family, it must bill the initial PHA. The receiving PHA must allow the family to lease the unit with SV assistance and may not absorb the family with a regular HCV when the family leases the unit. - Regardless of whether the receiving PHA absorbs or bills the initial PHA for the family’s SV assistance, the SV administration of the voucher is in accordance with the receiving PHA’s SV policies.
• If the SV family moves under portability to another PHA that does not administer SVs under its own ACC, the receiving PHA may absorb the family into its regular HCV program or may bill the initial PHA.

Family Briefing
In addition to the applicable family briefing requirements at 24 CFR 982.301(a)(2) as to how portability works and how portability may affect the family’s assistance, the initial PHA must inform the family how portability may impact the special SV services and assistance that may be available to the family.

The initial PHA is required to help facilitate the family’s portability move to the receiving PHA and inform the family of this requirement in writing, taking reasonable steps to ensure meaningful access for persons with limited English proficiency (LEP).

Exhibit 2
868 of 1125

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17-VI.G. PAYMENT STANDARDS
Overview
For the SV program, HUD has waived the regulation requiring a single payment standard for each unit size. Instead, the PHA may, but is not required to, establish separate higher payment standards for SVs. Lower SV payment standards are not permitted. If the PHA is increasing the regular HCV payment standard, the PHA must also increase the SV payment standard if it would be otherwise lower than the new regular HCV payment standard. The separate SV payment standard must comply with all other HCV requirements with the exception of the alternative requirements discussed below.

Further, if the PHA chooses to establish higher payments standards for SVs, HUD has provided other regulatory waivers:
• Defining the “basic range” for payment standards as between 90 and 120 percent of the published Fair Market Rent (FMR) for the unit size (rather than 90 to 110 percent). • Allowing a PHA that is not in a designated Small Area FMR (SAFMR) area or has not opted to voluntarily implement SAFMRs to establish exception payment standards for a ZIP code area above the basic range for the metropolitan FMR based on the HUD-published SAFMRs.

All rent reasonableness requirements apply to SV units, regardless of whether the PHA has established an alternative or exception SV payment standard.

Increases in Payment Standards
The requirement that the PHA apply increased payment standards at the family’s first regular recertification on or after the effective date of the increase does not apply to SV. The PHA may, but is not required to, establish an alternative policy on when to apply the increased payment standard, provided the increased payment standard is used to calculate the HAP no later than the effective date of the family’s first regular reexamination following the change.

Exhibit 2
869 of 1125

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17-VI.H. PROJECT-BASED UNITS
All tenant-based SV awards can be converted to project-based vouchers (PBV) at any time after award without HUD approval provided all the established PBV regulations and requirements are followed.

All PBV requirements in 24 CFR Part 983 and in Chapter 17 apply to project-based SVs with the exception of 24 CFR 983.251(c)(1), which requires PHAs to select families for project-based units from its HCV or PBV waiting list. HUD is waiving this requirement and establishing an alternative requirement that PHAs receive SV referrals from CoC partners for vouchers as well as project-based assistance.

Exhibit 2
870 of 1125

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EXHIBIT 17-1: SAMPLE STABILITY VOUCHER (SV)
HOMELESS PROVIDER’S CERTIFICATION
Stability Voucher (SV)

HOMELESS CERTIFICATION
SV Applicant Name: ____________________________________________________________ ☐ Household without dependent children (complete one form for each adult in the household) ☐ Household with dependent children (complete one form for household) Number of persons in the household: ______________
This is to certify that the above named individual or household meets the following criteria based on the check mark, other indicated information, and signature indicating their current living situation Check only one box and complete only that section
Living Situation: place not meant for human habitation (e.g., cars, parks, abandoned buildings, streets/sidewalks)
☐ The person(s) named above is/are currently living in (or, if currently in hospital or other institution, was living in immediately prior to hospital/institution admission) a public or private place not designed for, or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus station, airport, or campground.

Description of current living situation:
______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Homeless Street Outreach Program Name: ___________________________________________ This certifying agency must be recognized by the local Continuum of Care (CoC) as an agency that has a program designed to serve persons living on the street or other places not meant for human habitation. Examples may be street outreach workers, day shelters, soup kitchens, Health Care for the Homeless sites, etc.

Authorized Agency Representative Signature: ________________________________________ Date: ________________________________
Exhibit 2
871 of 1125

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Living Situation: Emergency Shelter
☐ The person(s) named above is/are currently living in (or, if currently in hospital or other institution, was living in immediately prior to hospital/institution admission) a supervised publicly or privately operated shelter as follows:

Emergency Shelter Program Name: _________________________________________________ This emergency shelter must appear on the CoC’s Housing Inventory Chart submitted as part of the most recent CoC Homeless Assistance application to the U.S. Department of Housing and Urban Development (HUD) or otherwise be recognized by the CoC as part of the CoC inventory (e.g., newly established Emergency Shelter).

Authorized Agency Representative Signature: ________________________________________ Date: ________________________________

Living Situation: Recently Homeless
☐ The person(s) named above is/are currently receiving financial and supportive services for persons who are homeless. Loss of such assistance would result in a return to homelessness (e.g., households in rapid rehousing programs, residents of permanent supportive housing programs participating in Moving On, etc.)
Authorized Agency Representative Signature: ________________________________________ Date: ________________________________
This referring agency must appear on the CoC’s Housing Inventory Chart submitted as part of the most recent CoC Homeless Assistance application to HUD or otherwise be recognized by the CoC as part of the CoC inventory.

Immediately prior to entering the household’s current living situation, the person(s) named above was/were residing in:
☐ Emergency shelter OR ☐ A place unfit for human habitation Authorized Agency Representative Signature: ________________________________________ Date: ________________________________
Exhibit 2
872 of 1125

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EXHIBIT 17-2: SAMPLE VICTIM SERVICE PROVIDER’S CERTIFICATION Stability Voucher (SV)

SAMPLE CERTIFICATION FOR SURVIVORS OF DOMESTIC VIOLENCE, DATING

VIOLENCE, SEXUAL ASSAULT, STALKING, AND/OR HUMAN TRAFFICKING Use of this Optional Form:

Service providers may utilize this form to certify a family’s eligibility for SV to document households who are fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, and/or human trafficking. In response to this request, the service provider may complete this form and submit it to the Public Housing Agency (PHA) to certify eligibility for the U.S. Department of Housing and Urban Development’s (HUD) Stability Voucher program.

Confidentiality:

All information provided during the referral process concerning the incident(s) of domestic violence, dating violence, dating violence, sexual assault, stalking, and human trafficking shall be kept confidential and such details shall not be entered into any shared database. Employees of the PHA will not have access to these details, and such employees may not disclose this information to any other entity or individual, except to the extent that disclosure is: (i) consented to by you in writing in a time-limited release; (ii) required for use in an eviction proceeding or hearing regarding termination of assistance; or (iii) otherwise required by applicable law.

TO BE COMPLETED ON BEHALF OF SURVIVORS OF DOMESTIC VIOLENCE,

DATING VIOLENCE, SEXUAL ASSAULT, STALKING, AND/OR HUMAN

TRAFFICKING
SV Applicant Name: ____________________________________________________________ The applicant named above is a survivor of (please check from the list all that apply):
☐ Domestic Violence
☐ Dating Violence
☐ Sexual Assault
☐ Stalking
☐ Human Trafficking
Exhibit 2
873 of 1125

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This certifies that the above named individual or household meets the definition for persons who are fleeing, or attempting to flee domestic violence, dating violence, sexual assault, stalking and/or human trafficking as these terms are defined under 34 U.S.C. Section 12291 of the Violence Against Women Act1 and 22 U.S.C. Section 7102(11) of the Trafficking Victims Protection Act.2
I acknowledge that submission of false information could jeopardize program eligibility and could be the basis for denial of admission, termination of assistance, or eviction.

Authorized Agency Representative Signature: ________________________________________ Date: ________________________________

1 The Violence Against Women Act protects applicants, tenants, and program participants in certain HUD programs from being evicted, denied housing assistance, or terminated from housing assistance based on acts of domestic violence, dating violence, sexual assault, or stalking against them. VAWA protection is available to victims of domestic violence, dating violence, sexual assault, and stalking, regardless of sex, gender identity, or sexual orientation.
2 The Victims of Trafficking and Violence Protection Act of 2000 provides assistance to victims of trafficking making housing, educational health care, job training and other federally-funded social service programs available to assist victims in rebuilding their lives.

Exhibit 2
874 of 1125

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EXHIBIT 17-3: SAMPLE SV MEMORANDUM OF UNDERSTANDING3
[** This sample document demonstrates the Memorandum of Understanding requirements for the administration of Stability Vouchers. Unless otherwise noted, all elements are required. **] Memorandum of Understanding – Stability Vouchers
This Memorandum of Understanding (MOU) has been created and entered on [Insert execution date] by [insert PHA name and address] and [insert CoC/VSP name and address].

I. Introduction and Goals
The [insert PHA name] and [insert CoC/VSP name] through the Stability Voucher (SV) Program seek to prevent and end homelessness among individuals and families who are experiencing or at-risk of homelessness, those fleeing or attempting to flee domestic violence dating violence, sexual assault, stalking, and human trafficking, and veterans and families that include a veteran family member that meets one of the proceeding criteria.

The Consolidated Appropriations Act, 2021 (Public Law 116-260) (2021 Act), makes available $43,343,000 for new incremental voucher assistance under Section 8(o) of the United States Housing Act of 1937 for use by individuals and families experiencing or at-risk of homelessness; those fleeing or attempting to flee domestic violence, dating violence, sexual assault, and stalking; and veterans and families that include a veteran family member that meets one of the proceeding criteria.

The Further Consolidated Appropriations Act, 2022 (Public Law 117-103 (2022 Act) further provides that HUD may waive certain statutory and regulatory provisions to administer the SVs (except for requirements related to tenant rights and protections, rent setting, fair housing, nondiscrimination, labor standards and the environment) upon a finding that any such waivers or alternative requirements are necessary to facilitate the use of funds made available for SVs.

This Memorandum of Understanding (MOU) outlines the collaboration and commitment between [insert PHA name] and [insert CoC/VSP name] to pair Stability Vouchers with CoC- funded supportive services; and to collaborate with the CoC/VSP and other stakeholders to develop a prioritization plan for these vouchers.

Lead Agency Liaisons:

Name and title of PHA staff position:

Name and title CoC and/or VSP staff position:

3 If PHA policy in Section 17-VI.B. of this administrative plan states that a copy of the MOU will be attached at the end of this chapter as Exhibit 17-3, you may either fill in the language shown here or replace the text with the PHA’s own MOU, then delete the word sample. If the PHA does not wish to attach its own MOU to the chapter, this statement should be removed from the policy in Section 17-VI.B.

Exhibit 2
875 of 1125

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II. Individuals and Families Eligibility under the Qualifying Categories In order to be eligible for an SV, an individual or family must meet one of four eligibility categories:
• Homeless
• At risk of homelessness
• Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking
• Veterans
III. SV Roles and Responsibilities
A. PHA Roles and Responsibilities [**The following responsibilities are listed for example purposes. **]

1. Coordinate and consult with the CoC in developing the services and assistance to be offered under the SV services fee.

2. Accept direct referrals for eligible individuals and families through the CoC Coordinated Entry System.

3. Commit a sufficient number of staff and necessary resources to ensure that the application, certification, and voucher issuance processes are completed in a timely manner.

4. Commit a sufficient number of staff and resources to ensure that inspections of units are completed in a timely manner.

5. Designate a staff to serve as the lead SV liaison.

6. Comply with the provisions of this MOU.

B. CoC Roles and Responsibilities [**The following responsibilities are listed for example purposes. **]

1. Designate and maintain a lead SV liaison to communicate with the PHA.

2. Refer eligible individuals and families to PHA using the community’s coordinated entry system.

3. Support eligible individuals and households in completing and applying for supportive documentation to accompany admissions application to the PHA (i.e., self-certifications, birth certificate, social security card, etc.).

4. Attend SV participant briefings when needed.

Exhibit 2
876 of 1125

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5. Assess all households referred for SV for mainstream benefits and supportive services available to support eligible individuals and families through their transition.

6. Identify and provide supportive services to SV families. (While SV participants are not required to participate in services, the CoC should assure that services are available and accessible.)

7. Comply with the provisions of this MOU.

IV. CoC-funded supportive services that will be paired with SVs CoCs are encouraged to outline any existing partnerships with health and behavioral health care providers and agencies, state Medicaid agencies and agencies and organizations that may be leveraged to provide ongoing tenancy and wrap-around supportive services for those that may benefit from such services to maintain housing stability. All services provided by the CoC must be outlined in the MOU with the CoC and should demonstrate the community’s strategy to coordinate assistance through available resources. HUD recommends that PHAs and partnering CoCs seek a diverse range of supportive services by partnering with organizations trusted by people experiencing homelessness.

V. PHA Adopted Waivers and Alternative Requirements
Notice PIH 2022-24 provides [insert PHA name] with authority to adopt certain statutory and regulatory requirements and alternative requirements for Stability Vouchers. [insert PHA name] and [insert CoC/VSP name] have agreed to adopt the following waivers and alternative requirements:
[List all waivers and alternative requirements discussed, agreed upon by the PHA and CoC for the administration of SVs]
VI. PHA Permissive Prohibition Policies agreed upon by the PHA and CoC [Insert PHA name] in consultation with [insert CoC/VSP name] have agreed to adopt the following permissive prohibitions for the Stability Voucher program:
[List any permissive prohibition policies agreed upon by the PHA and CoC] Exhibit 2
877 of 1125

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VII. Program Evaluation
[Insert PHA name] and [insert CoC /VSP] agree to cooperate with HUD, provide requested data to HUD or HUD-approved contractor delegated the responsibility of program evaluation protocols established by HUD or HUD-approved contractor.

Signed By:
________________________________________ ____________________ Public Housing Agency Executive Director Date ________________________________________ ____________________ CoC/VSP Executive Director Date
Exhibit 2
878 of 1125

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Chapter 18
EMERGENCY HOUSING VOUCHERS (EHVs)

INTRODUCTION
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARP) (P.L. 117-2). Section 3202 of the ARP appropriated $5 billion for the creation, administration, and renewal of new incremental emergency housing vouchers (EHVs) and other eligible expenses related to COVID-19.

On May 5, 2021, HUD issued Notice PIH 2021-15, which described HUD’s process for allocating approximately 70,000 EHVs to eligible PHAs and set forth the operating requirements for PHAs who administer them. Based on criteria outlined in the notice, HUD notified eligible PHAs of the number of EHVs allocated to their agency, and PHAs were able to accept or decline the invitation to participate in the program.

PHAs may not project-base EHVs; EHVs are exclusively tenant-based assistance.

All applicable nondiscrimination and equal opportunity requirements apply to the EHV program, including requirements that the PHA grant reasonable accommodations to persons with disabilities, effectively communicate with persons with disabilities, and ensure meaningful access for persons with limited English proficiency (LEP).

This chapter describes HUD regulations and PHA policies for administering EHVs. The policies outlined in this chapter are organized into seven sections, as follows:

Part I: Funding
Part II: Partnering Agencies
Part III: Waiting List Management
Part IV: Family Eligibility
Part V: Housing Search and Leasing
Part VI: Use of Funds, Reporting, and Financial Records Except as addressed by this chapter and as required under federal statute and HUD requirements, the general requirements of the HCV program apply to EHVs.

Exhibit 2
879 of 1125

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PART I: FUNDING

18-I.A. FUNDING OVERVIEW
The American Rescue Plan Act of 2021 (ARP) provides administrative fees and funding for the costs of administering emergency housing vouchers (EHVs) and other eligible expenses defined in Notice PIH 2021-15. These fees may only be used for EHV administration and other eligible expenses and must not be used for or applied to other PHA programs or vouchers. The PHA must maintain separate financial records from its regular HCV funding for all EHV funding.

Housing Assistance Payments (HAP) Funding
ARP funding obligated to the PHA as housing assistance payments (HAP) funding may only be used for eligible EHV HAP expenses (i.e., rental assistance payments). EHV HAP funding may not be used for EHV administrative expenses or for the eligible uses under the EHV services fee.

The initial funding term will expire December 31, 2022. HUD will provide renewal funding to the PHA for the EHVs on a calendar year (CY) basis commencing with CY 2023. The renewal funding allocation will be based on the PHA’s actual EHV HAP costs in leasing, similar to the renewal process for the regular HCV program. EHV renewal funding is not part of the annual HCV renewal funding formula; EHVs are renewed separately from the regular HCV program.

All renewal funding for the duration of the EHV program has been appropriated as part of the ARP funding.

Administrative Fee and Funding
The EHV program provides administrative fee funding to PHAs for expenses that are not normally eligible under the HCV program, as well as fees designated for the cost of administering the EHV program generally. The following types of fees and funding are allocated as part of the EHV program:
• Preliminary fees support immediate start-up costs that the PHA will incur in implementing alternative requirements under EHV, such as outreach and coordination with partnering agencies:
- $400 per EHV allocated to the PHA, once the consolidated annual contributions contract (CACC) is amended.
- This fee may be used for any eligible administrative expenses related to EHVs. - The fee may also be used to pay for any eligible activities under EHV service fees (TPS- I.B).
• Issuing action fees are one-time fees once the voucher is initially leased:
- $100 for each EHV initially leased, if the PHA reports the voucher issuance date in Public Housing Information Center–Next Generation (PIC–NG) system within 14 days of voucher issuance or the date the system becomes available for reporting. - Issuing action fees only apply to the initial leasing of the voucher; they are not paid for family moves or to turnover vouchers.
- This fee may be used for any eligible administrative expenses related to EHVs.

Exhibit 2
880 of 1125

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• Placement fees support initial lease-up costs and the added cost and effort required to expedite leasing of EHVs:
- $500 for each EHV family placed under a HAP contract effective within four months of the effective date of the ACC funding increment; or
- $250 for each EHV family placed under a HAP contract effective after four months but less than six months after the effective date of the ACC funding increment. - HUD will determine placement fees in the event of multiple EHV allocations and funding increment effective dates.
- Placement fees only apply to the initial leasing of the voucher; they are not paid for family moves or to turnover vouchers.
- This fee may be used for any eligible administrative expenses related to EHVs. • Ongoing administrative fees, which are calculated in the same way as the standard HCV program:
- PHAs are allocated administrative fees using the full column A administrative fee amount for each EHV under contract as of the first day of each month. - Ongoing EHV administrative fees may be subject to proration in future years, based on available EHV funding.
- This fee may be used for any eligible administrative expenses related to EHVs. • Services fees, which are a one-time fee to support PHAs’ efforts to implement and operate an effective EHV services program in its jurisdiction (TPS-I.B):
- The fee is allocated once the PHA’s CACC is amended to reflect EHV funding. - The amount allocated is $3,500 for each EHV allocated. - This fee may be used for any of the eligible activities under the EHV service fee Exhibit 2
881 of 1125

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18-I.B. SERVICE FEES
Services fee funding must be initially used for defined eligible uses and not for other administrative expenses of operating the EHV program. Service fees fall into four categories:
• Housing search assistance
• Security deposit/utility deposit/rental application/holding fee uses • Owner-related uses
• Other eligible uses such as moving expenses or tenant-readiness services The PHA must establish the eligible uses and the parameters and requirements for service fees in the PHA’s administrative plan.

GHA Policy
The eligible uses for service fees include the programs listed below and are subject to the availability of funds:

Application fees/non-refundable administrative or processing fees/refundable application deposit assistance. The PHA may choose to assist the family with some or all these expenses.

Security deposit assistance. The PHA may provide security deposit assistance to the tenant. The amount of the security deposit assistance may not exceed the lesser of two months’ rent to owner, the maximum security deposit allowed under applicable state and/or local law, or the actual security deposit required by the owner and may not exceed $3500.00. If applicable the PHA will pay the security deposit assistance directly to the owner.

Utility deposit assistance/utility arrears. The PHA may provide utility deposit assistance for some or all of the family’s utility deposit expenses. Assistance can be provided for deposits (including connection fees) required for the utilities to be supplied by the tenant under the lease. The PHA may pay the utility deposit assistance directly to the utility company or may pay the assistance to the family. If paid to the family, the PHA will require documentation the family paid the utility deposit. In addition, some families may have large balances with gas, electric, water, sewer, or trash companies that will make it difficult if not impossible to establish services for tenant-supplied utilities.

The PHA may also provide the family with assistance to help address these utility arrears to facilitate leasing.

Owner recruitment and outreach for EHVs. The PHA may use the service fee funding to conduct owner recruitment and outreach specifically for EHVs. In addition to traditional owner recruitment and outreach, activities may include, expediting the inspection process, providing enhanced customer service, and offering owner incentive and/or retention payments.

Owner incentive and/or retention payments. The PHA may make incentive or retention payments to owners that agree to initially lease their unit to an EHV family and/or renew the lease of an EHV family.

Exhibit 2
882 of 1125

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Payments will be made as a single payment at the beginning of the assisted lease term (or lease renewal as a retention payment). Owner incentive and retention payments are not housing assistance payments, are not part of the rent to owner, and are not taken into consideration when determining whether the rent for the unit is reasonable.

The GHA has four incentive programs:

1. Welcome to the Section 8 Program: this is a one-time $3,000.00 bonus paid to an owner who is new to the Section 8 program or has been an inactive owner in the Section 8 program database for over 12 months.

2. Welcome back to the Section 8 Program: this is a one-time $2,000.00 bonus paid to an owner for reenrolling into the Section 8 program within 12 months after exiting the program.

3. Loyalty Program: $2,000.00 bonus paid to an existing Section 8 owner who leases up a new Section 8 tenant. This bonus will be capped at $6,000.00 per owner.

4. Inspection Holding Program: the GHA will pay up to $1,000.00 bonus to an owner to cover the daily proration of the full agreed upon contract rent from the date the unit is available for inspection noted on the Request for Tenancy Approval (RFTA) to initial inspection. If the RFTA was submitted after the date the unit was available for inspection, the submitted date (date-stamped by the GHA) will be considered.

Moving expenses (including move-in fees and deposits). The PHA may provide assistance for some or all of the family’s reasonable moving expenses when they initially lease a unit with the EHV. The PHA will not provide moving expenses assistance for subsequent moves unless the family is required to move for reasons other than something the family did or failed to do (e.g., the PHA is terminating the HAP contract because the owner did not fulfill the owner responsibilities under the HAP contract or the owner is refusing to offer the family the opportunity to enter a new lease after the initial lease term, as opposed to the family choosing to terminate the tenancy in order to move to another unit), or a family has to move due to domestic violence, dating violence, sexual assault, or stalking.

Exhibit 2
883 of 1125

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Essential household items. The PHA may use services fee funding to assist the family with some or all of the costs of acquiring essential household items such as tableware, cooking equipment, beds or bedding, and essential sanitary products such as soap and toiletries.

Renter’s insurance if required by the lease. The PHA may choose to assist the family with some or all this cost.

Any services fee assistance that is returned to the PHA after its initial or subsequent use may only be applied to the eligible services fee uses defined in Notice PIH 2021-15 (or subsequent notice) or other EHV administrative costs. Any amounts not expended for these eligible uses when the PHA’s EHV program ends must be remitted to HUD.

Exhibit 2
884 of 1125

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PART II: PARTNERING AGENCIES
18-II.A. CONTINUUM OF CARE (CoC)
PHAs that accept an allocation of EHVs must work with community partners to determine the best use and targeting for EHVs along with other resources available in the community. PHAs are required to enter into a Memorandum of Understanding (MOU) with the Continuum of Care (CoC) to establish a partnership for the administration of EHVs.

GHA Policy
The PHA has entered into an MOU with the City of Glendale Continuum of Care (CoC) See Exhibit TPS-1 for a copy of the MOU.
18-II.B. OTHER PARTNERING ORGANIZATIONS
The PHA may, but is not required to, partner with other organizations trusted by persons experiencing homelessness, such as victim services providers (VSPs) and other community partners. If the PHA chooses to partner with such agencies, the PHA must either enter into an MOU with the partnering agency or the partnering agency may be added to the MOU between the PHA and CoC.
18-II.C. REFERRALS
CoC and Partnering Agency Referrals
The primary responsibility of the CoC under the MOU with the PHA is to make direct referrals of qualifying individuals and families to the PHA. The PHA must generally refer a family that is seeking EHV assistance directly from the PHA to the CoC or other referring agency for initial intake, assessment, and possible referral for EHV assistance. Partner CoCs are responsible for determining whether the family qualifies under one of the four eligibility categories for EHVs.

The CoC or other direct referral partner must provide supporting documentation to the PHA of the referring agency’s verification that the family meets one of the four eligible categories for EHV assistance.

Exhibit 2
885 of 1125

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GHA Policy
The CoC or partnering agency must establish and implement a system to identify EHV- eligible individuals and families within the agency’s caseload and make referrals to the PHA. The CoC or other partnering agency must certify that the EHV applicants they refer to the PHA meet at least one of the four EHV eligibility criteria. The PHA will maintain a copy of the referral or certification from the CoC or other partnering agency in the participant’s file along with other eligibility paperwork. Homeless service providers may, but are not required to use the certification form found in Exhibit 18-2 of this chapter.

Victim services providers may, but are not required to, use the certification form found in Exhibit 18-3 of this chapter when identifying eligible families who qualify as victims of human trafficking.

As part of the MOU, the GHA and CoC or other partnering agency will identify staff positions to serve as lead EHV liaisons. These positions will be responsible for transmission and acceptance of referrals. The CoC or partnering agency must commit sufficient staff and resources to ensure eligible individuals and families are identified and determined eligible in a timely manner.

The PHA liaison responsible for acceptance of referrals will receive criminal background forms from the CoC via email. The PHA liaison will notify the CoC and partnering agency liaison of the criminal background clearance. The partnering agency liaison will email the PHA liaison and the CoC a completed release form for each adult family member; a written certification for each referral indicating they are EHV-eligible, the housing application along with other supporting documents in regards to income, assets, etc. The PHA will issue a voucher once it has determined that the family is eligible.

Exhibit 2
886 of 1125

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Offers of Assistance with CoC Referral
Referrals for EHVs must come through the CoC’s Coordinated Entry (CE) system. However, the PHA may make an EHV available without a referral from the CoC or other partnering organization in order to facilitate an emergency transfer under VAWA in accordance with the PHA’s Emergency Transfer Plan (ETP) in Chapter 16.

The PHA must also take direct referrals from outside the CoC if:
• The CoC does not have a sufficient number of eligible families to refer to the PHA; or • The CoC does not identify families that may be eligible for EHV assistance because they are fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking or human trafficking.

In the latter two exceptions, the PHA must enter into a partnership to receive direct referrals from another entity (e.g., a homeless service provider, VSP, or anti-trafficking service provider if the CE system is not referring victims fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking). PHAs should work with the CoC to come up with an alternative referral system that allows for prioritization according to the standards set out in the MOU and the referring organization and that will transition easily to the CoC’s CE system when it comes online or is able to begin making referrals.

If at any time the PHA is not receiving enough referrals or is not receiving referrals in a timely manner from the CoC or other partner referral agencies (or the PHA and CoC cannot identify any such alternative referral partner agencies), HUD may permit the PHA on a temporary or permanent basis to take EHV applications directly from applicants and admit eligible families to the EHV program in lieu of or in addition to direct referrals in those circumstances.

Exhibit 2
887 of 1125

Page 18 ends

PART III: WAITING LIST MANAGEMENT
18-III. A. HCV WAITING LIST
The regulation that requires the PHA to admit applicants as waiting list admissions or special admissions in accordance with admission policies in Chapter 4 does not apply to PHAs operating the EHV program. Direct referrals are not added to the PHA’s HCV waiting list.

The PHA must inform families on the HCV waiting list of the availability of EHVs by, at a minimum, either by posting the information to their website or providing public notice in their respective communities in accordance with the requirements listed in Notice PIH 2021-15.

GHA Policy
The PHA will post information about the EHV program for families on the PHA’s HCV waiting list on their website. The notice will:

Describe the eligible populations to which EHVs are limited Clearly state that the availability of these EHVs is managed through a direct referral process
Advise the family to contact the CoC (or any other PHA referral partner, if applicable) if the family believes they may be eligible for EHV assistance The PHA will ensure effective communication with persons with disabilities, including those with vision, hearing, and other communication-related disabilities in accordance with Chapter 2. The PHA will also take reasonable steps to ensure meaningful access for persons with limited English proficiency (LEP) in accordance with Chapter 2. 18-III.B. EHV WAITING LIST
The HCV regulations requiring the PHA to operate a single waiting list for admission to the HCV program do not apply to PHAs operating the EHV program. Instead, when the number of applicants referred by the CoC or partnering agency exceeds the EHVs available, the PHA must maintain a separate waiting list for EHV referrals, both at initial leasing and for any turnover vouchers that may be issued prior to September 30, 2023.

Further, the EHV waiting list is not subject to PHA policies in Chapter 4 regarding opening and closing the HCV waiting list. The PHA will work directly with its CoC and other referral agency partners to manage the number of referrals and the size of the EHV waiting list.

Exhibit 2
888 of 1125

Page 18 ends

18-III.C. PREFERENCES
HCV Waiting List Preferences
If local preferences are established by the PHA for HCV, they do not apply to EHVs. However, if the PHA has a homeless preference or a VAWA preference for the HCV waiting list, the PHA must adopt additional policies related to EHVs in accordance with Notice PIH 2021-15.

GHA Policy
The PHA has a homeless and VAWA preference for the regular HCV program. The PHA will refer any applicant on the waiting list that indicated they qualified for the homeless or VAWA preference to the CoC.

EHV Waiting List Preferences
With the exception of a residency preference, the PHA may choose, in coordination with the CoC and other referral partners, to establish separate local preferences for EHVs. The PHA may, however, choose to not establish any local preferences for the EHV waiting list.

GHA Policy
No local preferences have been established for the EHV waiting list.

Exhibit 2
889 of 1125

Page 18 ends

PART IV: FAMILY ELIGIBILITY
18-IV.A. OVERVIEW
The CoC or referring agency determines whether the individual or family meets any one of the four eligibility criteria described in Notice PIH 2021-15 and then refers the family to the PHA.

The PHA determines that the family meets other eligibility criteria for the HCV program, as modified for the EHV program and outlined below.
18-IV.B. REFERRING AGENCY DETERMINATION OF ELIGIBILITY
In order to be eligible for an EHV, an individual or family must meet one of four eligibility criteria:
• Homeless as defined in 24 CFR 578.3;
• At risk of homelessness as defined in 24 CFR 578.3;
• Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking (as defined in Notice PIH 2021-15), or human trafficking (as defined in the 22 U.S.C. Section 7102); or
• Recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability as determined by the CoC or its designee in accordance with the definition in Notice PIH 2021-15.

As applicable, the CoC or referring agency must provide documentation to the PHA of the referring agency’s verification that the family meets one of the four eligible categories for EHV assistance. The PHA must retain this documentation as part of the family’s file.

Exhibit 2
890 of 1125

Page 18 ends

18-IV.C. PHA SCREENING
Overview
HUD waived 24 CFR 982.552 and 982.553 in part for the EHV applicants and established alternative requirement for mandatory and permissive prohibitions of admissions. Except where applicable, PHA policies regarding denials in Chapter 3 of this policy do not apply to screening individuals and families for eligibility for an EHV. Instead, the EHV alternative requirement listed in this section will apply to all EHV applicants.

The mandatory and permissive prohibitions listed in Notice PIH 2021-15 and in this chapter, however, apply only when screening the individual or family for eligibility for an EHV. When adding a family member after the family has been placed under a HAP contract with EHV assistance, the regulations at 24 CFR 982.551(h)(2) apply. Other than the birth, adoption, or court-awarded custody of a child, the PHA must approve additional family members and may apply its regular HCV screening criteria in Chapter 3 in doing so.

Mandatory Denials
Under alternative requirements for the EHV program, mandatory denials for EHV applicants include:
• 24 CFR 982.553(a)(1)(ii)(C), which prohibits admission if any household member has ever been convicted of drug-related criminal activity for manufacture or production of methamphetamine on the premises of federally assisted housing. • 24 CFR 982.553(a)(2)(i), which prohibits admission to the program if any member of the household is subject to a lifetime registration requirement under a state sex offender registration program.

The PHA must deny admission to the program if any member of the family fails to sign and submit consent forms for obtaining information as required by 24 CFR 982.552(b)(3) but should notify the family of the limited EHV grounds for denial of admission first.

GHA Policy
While the PHA will deny admission to the program if any adult member (or head of household or spouse, regardless of age) fails to sign and submit consent forms, the PHA will first notify the family of the limited EHV grounds for denial of admission as part of the notice of denial which will be emailed to the CoC partner agency liaison.

Exhibit 2
891 of 1125

Page 18 ends

Permissive Denial
Notice PIH 2021-15 lists permissive prohibitions for which the PHA may, but is not required to, deny admission to EHV families. The notice also lists prohibitions that, while allowable under the HCV program, may not be used to deny assistance for EHV families.

If the PHA intends to establish permissive prohibition policies for EHV applicants, the PHA must first consult with its CoC partner to understand the impact that the proposed prohibitions may have on referrals and must take the CoC’s recommendations into consideration.

GHA Policy
In consultation with the CoC, the PHA will apply permissive prohibition to the screening of EHV applicants. Determinations using permissive prohibitions will be made based on an individualized assessment of relevant mitigating information in accordance with policies in Section 3-III.E.

The PHA will establish the following permissive prohibitions:

If the PHA determines that any household member is currently engaged in, or has engaged in within the previous 12 months:

Violent criminal activity
Other criminal activity that may threaten the health, safety, or right to peaceful enjoyment of the premises by other residents or persons residing in the immediate vicinity
If any member of the family has committed fraud, bribery, or any other corrupt or criminal act in connection with any federal housing program within the previous 12 months.

If the family engaged in or threatened abusive or violent behavior toward PHA personnel within the previous 12 months.

The PHA will also deny assistance to household members already receiving assistance from another program in accordance with Section 9.h. of Notice PIH 2021-15.

Prohibitions based on criminal activity for the eligible EHV populations regarding drug possession will be considered apart from criminal activity against persons (i.e., violent criminal activity).

Exhibit 2
892 of 1125

Page 18 ends

In compliance with PIH 2021-15, the PHA will not deny an EHV applicant admission regardless of whether:

Any member of the family has been evicted from federally assisted housing in the last five years;
A PHA has ever terminated assistance under the program for any member of the family;
The family currently owes rent or other amounts to the PHA or to another PHA in connection with Section 8 or public housing assistance under the 1937 Act; The family has not reimbursed any PHA for amounts paid to an owner under a HAP contract for rent, damages to the unit, or other amounts owed by the family under the lease;
The family breached an agreement with the PHA to pay amounts owed to a PHA, or amounts paid to an owner by a PHA;
The family would otherwise be prohibited admission under alcohol abuse standards established by the PHA in accordance with 24 CFR 982.553(a)(3); The PHA determines that any household member is currently engaged in or has engaged in during a reasonable time before the admission, drug-related criminal activity.

Exhibit 2
893 of 1125

Page 18 ends

18-IV.D. INCOME VERIFICATION AT ADMISSION
Self-Certification at Admission
The requirement to obtain third-party verification of income in accordance with Notice PIH 2018-18 does not apply to the EHV program applicants at admission, and alternatively, PHAs may consider self-certification the highest form of income verification at admission. As such, PHA policies related to the verification of income in Section 7-I.B. do not apply to EHV families at admission. Instead, applicants must submit an affidavit attesting to their reported income, assets, expenses, and other factors that would affect an income eligibility determination.

Additionally, applicants may provide third-party documentation that represents the applicant’s income within the 60-day period prior to admission or voucher issuance but is not dated within 60 days of the PHA’s request.

GHA Policy
Any documents used for verification must be dated within the 120-day period prior to admission. The documents must not be damaged, altered, or in any way illegible.

Printouts from webpages are considered original documents.

Any family self-certifications must be made in a format acceptable to the PHA and must be signed by the family member whose information or status is being verified.

The PHA will incorporate additional procedures to remind families of the obligation to provide true and complete information in accordance with Chapter 14. The PHA will address any material discrepancies (i.e., unreported income or a substantial difference in reported income) that may arise later. The PHA may, but is not required to, offer the family a repayment agreement in accordance with Chapter 16. If the family fails to repay the excess subsidy, the PHA will terminate the family’s assistance in accordance with the policies in Chapter 12.

Exhibit 2
894 of 1125

Page 18 ends

Recently Conducted Income Determinations
PHAs may accept income calculations and verifications from third-party providers or from an examination that the PHA conducted on behalf of the family for another subsidized housing program in lieu of conducting an initial examination of income as long as:
• The income was calculated in accordance with rules outlined at 24 CFR Part 5 and within the last six months; and
• The family certifies there has been no change in income or family composition in the interim.

GHA Policy
The PHA will not accept income calculations and verifications from third-party providers.

The family certification must be made in a format acceptable to the PHA and must be signed by all adult family members whose information or status is being verified.

At the time of the family’s annual reexamination the PHA must conduct the annual reexamination of income as outlined at 24 CFR 982.516 and PHA policies in Chapter 11.

EIV Income Validation
Once HUD makes the EIV data available to PHAs under this waiver and alternative requirement, the PHA must:
• Review the EIV Income and Income Validation Tool (IVT) reports to confirm and validate family-reported income within 90 days of the PIC submission date; • Print and maintain copies of the EIV Income and IVT Reports in the tenant file; and • Resolve any income discrepancy with the family within 60 days of the EIV Income or IVT Report dates.

Prior to admission, PHAs must continue to use HUD’s EIV system to search for all household members using the Existing Tenant Search in accordance with PHA policies in Chapter 3.

If a PHA later determines that an ineligible family received assistance, the PHA must take steps to terminate that family from the program in accordance with Chapter 12.

Exhibit 2
895 of 1125

Page 18 ends

18-IV.E. SOCIAL SECURITY NUMBER AND CITIZENSHIP STATUS VERIFICATION For the EHV program, the PHA is not required to obtain and verify SSN documentation and documentation evidencing eligible noncitizen status before admitting the family to the EHV program. Instead, PHAs may adopt policies to admit EHV applicants who are unable to provide the required SSN or citizenship documentation during the initial eligibility determination. As an alternative requirement, such individuals must provide the required documentation within 180 days of admission to be eligible for continued assistance, pending verification, unless the PHA provides an extension based on evidence from the family or confirmation from the CoC or other partnering agency that the family has made a good-faith effort to obtain the documentation.

If a PHA determines that an ineligible family received assistance, the PHA must take steps to terminate that family from the program.

GHA Policy
The PHA will not admit EHV applicants who are unable to provide the required SSN or citizenship documentation during the initial eligibility determination. Instead, the PHA will make every effort to obtain the documentation with the assistance of the CoC agency.
18-IV.F. AGE AND DISABILITY VERIFICATION
PHAs may accept self-certification of date of birth and disability status if a higher level of verification is not immediately available. If self-certification is used, the PHA must obtain a higher level of verification within 90 days of admission or verify the information in EIV.

If a PHA determines that an ineligible family received assistance, the PHA must take steps to terminate that family from the program.

GHA Policy
The PHA will not accept self-certification of date of birth and disability status if a higher form of verification is not immediately available.

Exhibit 2
896 of 1125

Page 18 ends

18-IV.G. INCOME TARGETING
The PHA must determine income eligibility for EHV families in accordance with 24 CFR 982.201 and PHA policy in Chapter 3; however, income targeting requirements do not apply for EHV families. The PHA may still choose to include the admission of extremely low-income EHV families in its income targeting numbers for the fiscal year in which these families are admitted.

GHA Policy
The PHA will not include the admission of extremely low-income EHV families in its income targeting numbers for the fiscal year in which these families are admitted.

Exhibit 2
897 of 1125

Page 18 ends

PART V: HOUSING SEARCH AND LEASING
18-V.A. INITIAL VOUCHER TERM
Unlike the standard HCV program, which requires an initial voucher term of at least 60 days, EHV vouchers must have an initial search term of at least 120 days. PHA policies on extensions as outlined in Section 5-II.E. will apply.

GHA Policy
All EHVs will have an initial term of 120 calendar days.

The family must submit a Request for Tenancy Approval and proposed lease within the 120-day period unless the PHA grants an extension.
18-V.B. HOUSING SEARCH ASSISTANCE
The PHA must ensure housing search assistance is made available to EHV families during their initial housing search. The housing search assistance may be provided directly by the PHA or through the CoC or another partnering agency or entity.

At a minimum, housing search assistance must:
• Help individual families identify potentially available units during their housing search, including physically accessible units with features for family members with disabilities, as well as units in low-poverty neighborhoods;
• Provide transportation assistance and directions to potential units; • Conduct owner outreach;
• Assist with the completion of rental applications and PHA forms; and • Help expedite the EHV leasing process for the family
Exhibit 2
898 of 1125

Page 18 ends

GHA Policy
As identified in the MOU between the PHA and CoC, the following housing search assistance will be provided to each EHV family:

The PHA will:

Conduct owner outreach in accordance with policies in Chapter 13 Provide directions to potential units as part of the EHV briefing packet Expedite the EHV leasing process for the family to the extent practicable and in accordance with policies in this chapter
At least every 30 days, conduct proactive check-ins via email and telephone with families who are searching with an EHV and remind them of their voucher expiration date
Assign a dedicated owner liaison for EHV voucher families The CoC will:

Help families identify potentially available units during their housing search, including physically accessible units with features for family members with disabilities, as well as units in low-poverty neighborhoods Provide transportation assistance to potential units
Assist the family with the completion of rental applications and PHA forms
18-V.C. HQS PRE-INSPECTIONS
To expedite the leasing process, PHAs may pre-inspect available units that EHV families may be interested in leasing in order to maintain a pool of eligible units.

GHA Policy
The PHA will not pre-inspect units. Instead, the PHA will make every effort to fast-track the inspection process, including adjusting the normal inspection schedule for any required reinspections.

Exhibit 2
899 of 1125

Page 18 ends

18-V.D. INITIAL LEASE TERM
Unlike in the standard the HCV program, EHV voucher holders may enter into an initial lease that is for less than 12 months, regardless of the PHA policy in Section 9-I.E., Term of Assisted Tenancy.
18-V.E. PORTABILITY
The normal HCV portability procedures and requirements outlined in Chapter 10 generally apply to EHVs. Exceptions are addressed below.

Nonresident Applicants
Under EHV, applicant families may move under portability even if the family did not have legal residency in the jurisdiction of the initial PHA when they applied, regardless of PHA policy in Section 10-II.B.

Billing and Absorption
A receiving PHA cannot refuse to assist an incoming EHV family, regardless of whether the PHA administers EHVs under its own ACC.
• If the EHV family moves under portability to another PHA that administers EHVs under its own ACC:
- The receiving PHA may only absorb the incoming EHV family with an EHV (assuming it has an EHV voucher available to do so).
- If the PHA does not have an EHV available to absorb the family, it must bill the initial PHA. The receiving PHA must allow the family to lease the unit with EHV assistance and may not absorb the family with a regular HCV when the family leases the unit. - Regardless of whether the receiving PHA absorbs or bills the initial PHA for the family’s EHV assistance, the EHV administration of the voucher is in accordance with the receiving PHA’s EHV policies.
• If the EHV family moves under portability to another PHA that does not administer EHV under its own ACC, the receiving PHA may absorb the family into its regular HCV program or may bill the initial PHA.

Exhibit 2
900 of 1125

Page 18 ends

Family Briefing
In addition to the applicable family briefing requirements at 24 CFR 982.301(a)(2) as to how portability works and how portability may affect the family’s assistance, the initial PHA must inform the family how portability may impact the special EHV services and assistance that may be available to the family.

GHA Policy
In addition to following PHA policy on briefings in Chapter 5, as part of the briefing packet for EHV families, the PHA will include a written notice that the PHA will assist the family with moves under portability.

For limited English proficient (LEP) applicants, the PHA will provide interpretation services in accordance with the PHA’s LEP plan (See Chapter 2).

Coordination of Services
If the portability move is in connection with the EHV family’s initial lease-up, the receiving PHA and the initial PHA must consult and coordinate on the EHV services and assistance that will be made available to the family.

GHA Policy
For EHV families who are exercising portability, when the PHA contacts the receiving PHA in accordance with Section 10-II.B. Preapproval Contact with Receiving PHA, the PHA will consult and coordinate with the receiving PHA to ensure there is no duplication of EHV services and assistance, and ensure the receiving PHA is aware of the maximum amount of services fee funding that the initial PHA may provide to the receiving PHA on behalf of the family.

Exhibit 2
901 of 1125

Page 18 ends

Services Fee
Standard portability billing arrangements apply for HAP and ongoing administrative fees for EHV families.

For service fees funding, the amount of the service fee provided by the initial PHA may not exceed the lesser of the actual cost of the services and assistance provided to the family by the receiving PHA or $1,750, unless the initial PHA and receiving PHA mutually agree to change the $1,750 cap. Service fees are paid as follows:
• If the receiving PHA, in consultation and coordination with the initial PHA, will provide eligible services or assistance to the incoming EHV family, the receiving PHA may be compensated for those costs by the initial PHA, regardless of whether the receiving PHA bills or absorbs.
• If the receiving PHA administers EHVs, the receiving PHA may use its own services fee and may be reimbursed by the initial PHA, or the initial PHA may provide the services funding upfront to the receiving PHA for those fees and assistance. • If the receiving PHA does not administer EHVs, the initial PHA must provide the services funding upfront to the receiving PHA. Any amounts provided to the receiving PHA that are not used for services or assistance on behalf of the EHV family must promptly be returned by the receiving PHA to the initial PHA.

Placement Fee/Issuance Reporting Fee
If the portability lease-up qualifies for the placement fee/issuance reporting fee, the receiving PHA receives the full amount of the placement component of the placement fee/issuing reporting fee. The receiving PHA is eligible for the placement fee regardless of whether the receiving PHA bills the initial PHA or absorbs the family into its own program at initial lease-up. The initial PHA qualifies for the issuance reporting component of the placement fee/issuance reporting fee, as applicable.

Exhibit 2
902 of 1125

Page 18 ends

18-V.F. PAYMENT STANDARDS
Payment Standard Schedule
For the EHV program, HUD has waived the regulation requiring a single payment standard for each unit size. Instead, the PHA may, but is not required to, establish separate higher payment standards for EHVs. Lower EHV payment standards are not permitted. If the PHA is increasing the regular HCV payment standard, the PHA must also increase the EHV payment standard if it would be otherwise lower than the new regular HCV payment standard. The separate EHV payment standard must comply with all other HCV requirements with the exception of the alternative requirements discussed below.

Further, if the PHA chooses to establish higher payments standards for EHVs, HUD has provided other regulatory waivers:
• Defining the “basic range” for payment standards as between 90 and 120 percent of the published Fair Market Rent (FMR) for the unit size (rather than 90 to 110 percent). • Allowing a PHA that is not in a designated Small Area FMR (SAFMR) area or has not opted to voluntarily implement SAFMRs to establish exception payment standards for a ZIP code area above the basic range for the metropolitan FMR based on the HUD published SAFMRs.

The PHA may establish an exception payment standard up to 120 percent (as opposed to 110 percent) of the HUD published Small Area FMR for that ZIP code area. The exception payment standard must apply to the entire ZIP code area. - The PHA must notify HUD if it establishes an EHV exception payment standard based on the SAFMR.

GHA Policy
The PHA may establish a higher payment standard amount for EHVs.

Rent Reasonableness
All rent reasonableness requirements apply to EHV units, regardless of whether the PHA has established an alternative or exception EHV payment standard.

Increases in Payment Standards
The requirement that the PHA apply increased payment standards at the family’s first regular recertification on or after the effective date of the increase does not apply to EHV. The PHA may, but is not required to, establish an alternative policy on when to apply the increased payment standard, provided the increased payment standard is used to calculate the HAP no later than the effective date of the family’s first regular reexamination following the change.

GHA Policy
The PHA will not establish an alternative policy for increases in the payment standard.

PHA policy in Section 11-III.B. governing increases in payment standards will apply to EHV.

Exhibit 2
903 of 1125

Page 18 ends

18-V.G. TERMINATION OF VOUCHERS
After September 30, 2023, a PHA may not reissue EHVs when assistance for an EHV-assisted family ends. This means that when an EHV participant (a family that is receiving rental assistance under a HAP contract) leaves the program for any reason, the PHA may not reissue that EHV to another family unless it does so no later than September 30, 2023.

If an applicant family that was issued the EHV is unsuccessful in finding a unit and the EHV expires after September 30, 2023, the EHV may not be reissued to another family.

All EHVs under lease on or after October 1, 2023, may not under any circumstances be reissued to another family when the participant leaves the program for any reason.

An EHV that has never been issued to a family may be initially issued and leased after September 30, 2023, since this prohibition only applies to EHVs that are being reissued upon turnover after assistance to a family has ended. However, HUD may direct PHAs administering EHVs to cease leasing any unleased EHVs if such action is determined necessary by HUD to ensure there will be sufficient funding available to continue to cover the HAP needs of currently assisted EHV families.

As explained in Notice 2023-14, issued on June 29, 2023, HUD is identifying whether a voucher issuance is a turnover voucher or a voucher that has never been leased by counting the number of cumulative EHV lease-ups. (Note that cumulative leased vouchers is equal to all households leased since the start of the EHV program—this includes households that have left the program.) Once a PHA’s total cumulative leased EHV count reaches their total EHV allocation of the consolidated annual contributions contract (EHV-CACC), any EHV issuance is considered a reissuance. PHAs that have reached their cumulative EHV lease-up count may not reissue any EHV voucher after September 30, 2023.

If a PHA has not reached its EHV-CACC in cumulative leased vouchers, the PHA may continue to issue vouchers to eligible households after September 30, 2023, until the cumulative leased vouchers equal the number of EHVs currently under the PHA’s EHV- CACC, or until directed by HUD to stop issuing EHVs. If a PHA is reallocated additional EHVs, these EHVs are considered never leased and may be issued.

PHAs must adjust their EHV voucher issuances according to their most recent EHV success rate, i.e., the likelihood that the voucher-holder will successfully secure an EHV lease. PHAs can consider evaluating their success rate similar to the EHV dashboard that provides a 180-day lease rate. For example, the PHA calculates that 50 percent of recent EHV voucher holders successfully establish an EHV lease in 180 days; therefore, their EHV 180-day success rate is 50 percent.

Exhibit 2
904 of 1125

Page 18 ends

EXAMPLES

1. As of October 1, 2023, a PHA has cumulatively leased 60 of its 100 EHV allocation under their EHV-CACC. The PHA may continue to issue and lease the remaining 40 EHVs that have never been leased.

2. As of October 1, 2023, a PHA has cumulatively leased 80 of its 100 EHV allocation and has a success rate of 50 percent. Therefore, the PHA may have no more than 40 families with a voucher searching for a unit, which – considering a 180-day success rate – would equate to 20 new leases, and thus a fully leased program. If these voucher holders do not equate to 20 new leases, the PHA may continue to issue vouchers, (considering a 180-day success rate) until the EHV-CACC limit is reached.

EHV participants may still move (including under portability) after September 30, 2023. The termination of vouchers upon turnover provision does not impact an individual or family’s ability to move within the PHA’s jurisdiction or their ability to move under the portability procedures to another PHA’s jurisdiction.

Exhibit 2
905 of 1125

Page 18 ends

PART VI: USE OF FUNDS, REPORTING, AND FINANCIAL RECORDS EHV funds allocated to the PHA for HAP (both funding for the initial allocation and HAP renewal funding) may only be used for eligible EHV HAP purposes. EHV HAP funding obligated to the PHA may not be used for EHV administrative expenses or the other EHV eligible expenses under this notice. Likewise, EHV administrative fees and funding obligated to the PHA are to be used for those purposes and must not be used for HAP.

The appropriated funds for EHVs are separate from the regular HCV program and may not be used for the regular HCV program but may only be expended for EHV eligible purposes. EHV HAP funds may not roll into the regular HCV restricted net position (RNP) and must be tracked and accounted for separately as EHV RNP. EHV administrative fees and funding for other eligible expenses permitted by Notice PIH 2021-15 may only be used in support of the EHVs and cannot be used for regular HCVs. EHV funding may not be used for the repayment of debts or any amounts owed to HUD by HUD program participants including, but not limited to, those resulting from Office of Inspector General (OIG), Quality Assurance Division (QAD), or other monitoring review findings.

The PHA must comply with EHV reporting requirements in the Voucher Management System (VMS) and Financial Data Schedule (FDS) as outlined in Notice PIH 2021-15.

The PHA must maintain complete and accurate accounts and other records for the program and provide HUD and the Comptroller General of the United States full and free access to all accounts and records that are pertinent the administration of the EHVs in accordance with the HCV program requirements at 24 CFR 982.158.

Exhibit 2
906 of 1125

Page 18 ends

Exhibit 18-1: MEMORANDUM OF UNDERSTANDING (MOU)

MEMORANDUM OF UNDERSTANDING BETWEEN THE HOUSING

AUTHORITY OF THE CITY OF GLENDALE
AND

THE GLENDALE CONTINUUM OF CARE RELATING TO THE

EMERGENCY HOUSING VOUCHER PROGRAM

This Memorandum of Understanding is made and entered into by and between the Housing Authority of the City of Glendale, a municipal corporation, hereinafter called the Authority, and the City of Glendale Continuum of Care, recognized by the U.S. Department of Housing and Urban Development as one (1) of thirteen (13) Continuum of Cares that participate in regional efforts to prevent and end homelessness in Southern California, hereinafter called the CoC. This memorandum sets forth the obligations of the parties in conducting the Emergency Housing Voucher Program (EHV) and funding as authorized by the American Rescue Plan Act (ARPA) of 2021 (Public Law No: 117-2). The EHVs are provided to help assist individuals and families who are (1) homeless, (2) at risk of homelessness (3) fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking, or (4) recently homeless. The program shall be administered by the Authority in partnership with the CoC and its established Coordinated Entry System (CES). This memorandum is executed as of July 1, 2021.

WHEREAS, the Authority desires to engage the CoC to provide the following services under EHV; and
NOW THEREFORE, the Authority and the CoC agree as follows:

1. Term:

The term of this MOU shall commence July 1, 2021 and shall continue until September 30, 2023. Unless otherwise determined by future Housing and Urban Development Guidance, the MOU will end when either of the following occurs, whichever comes first: 1) the Authority is not permitted to reissue any of its remaining EHVs as determined by HUD, and the Authority no longer has any EHV individuals or families under lease; or 2) by September 30, 2035 when the funds appropriated for the EHV program are canceled as a matter of law. Any changes to this term require a written amendment to the MOU.

2. Program:

Exhibit 2
907 of 1125

Page 18 ends

A. The Authority was determined eligible for 225 new
EHVs and funding as authorized by ARPA. The EHVs are tenant-based rental assistance under section 8(0) of the United States Housing Act of 1037 (42 U.S.C. 1437f(o)). The
ARPA further provides that Department of Housing and Urban Development (HUD) may waive any provision of any statute or regulation used to administer the amounts made available under section 3202 (except for requirements related to fair housing, nondiscrimination, labor standards and the environment) upon a finding that any such waivers or alternative requirements are necessary to expedite or facilitate the use of amounts made available for EHVs. The administrative policies adopted in the Authority's written Administrative Plan apply to the EHVs unless such local policy conflicts with the requirements of the ARP, or the policy conflicts with the requirements or waivers of the PIH Notice 2021-15.

3. Scope of Services:

A. The Authority is responsible for all administrative
responsibilities for EHV in accordance with all program requirements outlined in HUD PIH 2021-15 (HA), subsequently issued or modified PIH Notices, and the applicable Housing Choice Voucher (HCV) program regulations, inducing but not limited to: Designating a staff to serve as the lead EHV liaison between the Authority and the CoC's Coordinated Entry System (CES); accepting direct referrals for eligible individua]s through the CES; accepting and reviewing applications for EHV; certification of program eligibility; conducting annual recertification's for continued eligibility; determining whether units meet Housing Quality Standards and approving units for leasing and contracts; determining amount and paying Housing Assistance Payments to the landlords on behalf of the participants, explaining and providing information about program policies and procedures to current and prospective landlords and participants; and monitoring program performance and compliance of participants and owners.

B. The CoC Service Providers/ or direct partner referral agencies are responsible for all administrative responsibilities for EHV in accordance with all program requirements outlined in HUD PIH 2021-15 (HA), subsequently issued or modified PIH Notices following and the CoC CES policies and procedures, including but not limited to: providing eligibility documentation to include Homeless Certification and EHV Program Referral Form (Attachment 1 or 2 and Attachment 3) from the PIH Notice 2021-15 as applicable and certifying that the EHV referral meets the Authority's criteria and at least one of the four EHV eligibility criteria (refer to Section 3 of this MOU); designating and maintaining a lead EHV liaison to communicate with the Authority ; screening and selection of eligible persons; supporting applicants in completing applications and obtaining necessary backup documentation to support referrals and applications for assistance; while aiding households in addressing barriers; supporting the Authority in ensuring appointment Exhibit 2
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notifications to eligible applicants and participants, and assisting eligible households in getting to meetings with the Authority; establishing windows of time for EHV applicants to complete intake interviews for EHV; providing housing search assistance for eligible applicants and; providing counseling on compliance with rental lease requirements; assessing applicants who may require referrals for assistance on security deposits, utility hook-up fees, and utility deposits; and assessing and referring applicants to benefits and supportive services where applicable; and providing ongoing support for case management services.

C. The Authority will be allocated a one-time Services Fee to support its efforts in implementing and operating an effective EHV program. The fee will be allocated to the Authority once the Authority's Consolidated Annual Contributions Contract (CACC) is amended to reflect the EHV funding obligation. The amount allocated to the Authority will be equal to $3,500 for each EHV allocated to the Authority. The Authority agrees to allocate the services fee to the CoC Service Providers for eligible services fee uses defined by PIH Notice 2021-15 or subsequent notice.

4. Program Evaluation:

A. The Authority shall establish a formal process for terminating assistance to any individual or family. That process shall recognize the rights of the individuals affected, and shall include an administrative hearing.

B. The CoC shall establish and maintain program policies and procedures including grievance policies to address program participants' complaints. Policy documentation shall be available for review upon request.

C. The Authority, CoC and the CoC Service Providers agree to cooperate with HUD, provide requested data to HUD or HUD -approved contractor delegated the responsibility of program evaluation protocols established by HUD or HUD-approved contractor, including possible random assignment procedures.

5. Eligible Populations:

A. Eligible populations for referral from the CoC will be compliant with the ARP and as outlined in conformance with PIH Notice 2021-15 published May 5, 2021 and as subsequently updated by HUD. All eligible populations outlined below are subject to HUD revision and or modification of approving legislation:

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• Homeless;
• At risk of homelessness;
• Fleeing, or attempting to flee domestic violence, dating violence; sexual assault, stalking, or human trafficking;
• Were recently homeless or have a high risk of housing instability; • Individuals and families who are identified for services by the City Homeless Outreach Team who works in conjunction with the contracted CoC lead agency; or
• Other City administered Tenant Based Rental Assistance program participants or participants in City temporary housing programming.

In general, issuance of a EHV will be a result of either:
a. The direct referral process from the CES or other partnering organization, or
b. A situation where the Authority makes an EHV available in order to facilitate an emergency transfer in accordance with the Violence Against Women Act (VAWA) as outlined in the Authority's Emergency Transfer Plan.

7. Goals:

A. Authority and CoC are committed to administering EHVs in accordance with all the requirements. Standards of success include:
(1) PHA and CoC's commitment to administering the EHVs in accordance with all program requirements
(2) Timely referrals (referrals need to be made within 10 days of notification from Authority of EHV vacancy rate)

(3) Utilization rate (85%)
(4) PHA goals and standard of success in administering the program
(5) Identification of staff position at the PHA and CoC who will serve as the lead EHV liaisons.

Lead EHV Liaison:

Arthur Bolbolian
Housing Supervisor
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Arsine Isayan
Sr. Administrative Analyst

8. Nondiscrimination in Services.

A. In accordance with federal law, all parties to this MOU, as well as all parties involved in the administration of the EHV program shall not discriminate in providing Program services under this MOU because of race, color, religion, national origin, ancestry, sex, age or physical or mental disability as identified in Section 109 of the Act, Section 504 of the Rehabilitation Act, the Age Discrimination Act of 1975, the Americans with Disabilities Act of 1990, and 24 CFR § 570.602. In addition, all parties to this MOU, as well as all parties involved in the administration of the EHV program shall not discriminate in providing Program services under this MOU because of religious belief, creed, medical condition, blindness, sexual orientation, gender identity, gender expression, marital status, pregnancy, parenthood, citizenship, domestic partner status, or AIDS or HN status. All parties to this MOU, as well as all parties involved in the administration of the EHV program shall not inquire about sexual orientation or gender identity of an applicant for, or occupant of, a dwelling unit or housing assistance.

B. The Authority, CoC and the CoC Service Providers shall establish, maintain, and make available to Program participants written procedures by which any person applying for or receiving Program services under this MOU may seek resolution with respect to complaints in regards to any alleged discrimination in the provision of services by EHV program personnel.

9. Nondiscrimination in Employment.

A. In accordance with federal law, all parties to this MOU, as well as all parties involved in the administration of the EHV program certify that they will not discriminate against any employee or person who is employed or compensated in whole or in part using Funds provided under this MOU because of race, color, creed, religion, religious belief, national origin, ancestry, citizenship, age, sex, sexual orientation, gender identity, gender expression, marital status, pregnancy, parenthood, medical condition, physical or mental disability, domestic partner status, or AIDS or HN status.

B. All parties to this MOU, as well as all parties involved in the administration of the EHV program shall take affirmative action to ensure that all employment practices are free from discrimination. Employment practices include, but are not limited to, the following: hiring, upgrading, promotion, demotion, transfer, recruitment, recruitment advertising, layoff, termination, rates of pay or other forms of Exhibit 2
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compensation, and selection for training, including apprenticeship as specified under Executive Order 11246, "Part II - Nondiscrimination in Employment by Government Contractors and Subcontractors," and the regulations issued under (41 CFR chapter 60), and as amended. Evidence of discrimination is sufficient cause for termination of this MOU.

C. Nothing contained in this MOU constitutes a waiver of Contractor's rights or exemptions as a religious institution in accordance with federal or State law, including the First Amendment to the United States Constitution; Section I, Section 4 of the California Constitution; Title VII of the Federal Civil Rights Act 42 USC Section 2000e-1(a); California Fair Employment & Housing Act, Government Code §§ 12922, 12926(d), and 12926.2; 24 CFR § 5.109 of the Equal Participation of Faith-Based Organizations Final Rule; and 24 CFR § 570.2000) of the Housing and Community Development Act of 1974, as amended.

10. Program Accessibility.

A. All parties under the MOU shall operate all facilities accessible by Program participants and potential Program participants so that, when viewed in its entirety, it is accessible to and usable by individuals with disabilities, in compliance with Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990. Methods of achieving Program accessibility may include any one or more of the following actions:

A. Locating programs and services in accessible facilities; B. Assigning aides to assist Program beneficiaries;
C. Conducting home visits (adhering to social distancing norms and using personal protective gear to minimize risk from COVID-19);
D. Adding or redesigning equipment or furnishings;
E. Changing management policies or procedures;
F. Acquiring or building new facilities; or
G. Selectively altering existing facilities.

B. Contact Information. The Authority and the CoC designate the following contact persons, street address or place, telephone number, and facsimile number or email address for giving notice. At any time, by providing notice to the other Party, the Authority or the CoC may change the contact information:

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City/Authority: Housing Authority
Community Development & Housing
114 N. Glendale Avenue, Room 202
Glendale, CA 91206
Attn: Peter Zovak, Assistant Director

CoC: Community Services & Parks Dept.
613 E. Broadway, Rm. 120
Glendale, CA 91206
Attn: Onnig Bulanikian, Director

11. Successors and Assigns.

This MOU binds and benefits the Parties and their respective permitted successors and assigns.

12. Modifications.

The Parties may modify this MOU, or any part of it, by a written amendment with the Authority's and the CoC Service Provider's signature.

13. Entire MOU.

This MOU, together with all Attachments and Exhibits, constitutes the entire MOU between the Parties, and the Parties acknowledged that no other promises or representations have been made, or are relied upon, by either Party in entering into this MOU.

14. Force Majeure.

A Party will not be considered in default in its performance of an obligation under this MOU, if the obligation was prevented or delayed by any cause, existing or future, beyond the reasonable control of the Party, which includes, but is not limited to, acts of God, labor disputes or civil unrest, or global health emergencies. Any delays beyond the control of either Party automatically extends the time schedule as set forth in this MOU by the period of any such delay.

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15. Digital Signatures.

The Parties deem a copy of this MOU, or any amendment to it, that bears a digital signature as having the same legal effect, for all purposes, as delivery of a signed original of this MOU or the amendment, and each digital signature will have the same legal force and effect as a handwritten signature.

16. Representations - The Parties represent that:

A. They have read this MOU, fully understand its contents, and have received a copy of it;
B. Through their duly authorized representative, they are authorized to sign this MOU, and they are bound by its terms; and
C. They have executed this MOU on the date opposite their signature.

Executed at Glendale, California.

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CITY OF GLENDALE HOUSING AUTHORITY:

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Exhibit 18-2: HOMELESS PROVIDER’S CERTIFICATION
Attachment 3 of Notice PIH 2021-15 Example of a Homeless Provider’s Certification Emergency Housing Voucher (EHV)

HOMELESS CERTIFICATION
EHV Applicant Name:

Household without dependent children (complete one form for each adult in the household)

Household with dependent children (complete one form for household)

Number of persons in the household:

This is to certify that the above named individual or household meets the following criteria based on the check mark, other indicated information, and signature indicating their current living situation-
Check only one box and complete only that section
Living Situation: place not meant for human habitation (e.g., cars, parks, abandoned buildings, streets/sidewalks)

The person(s) named above is/are currently living in (or, if currently in hospital or other institution, was living in immediately prior to hospital/institution admission) a public or private place not designed for, or ordinarily used as a regular sleeping accommodation for h uman beings, including a car, park, abandoned building, bus station, airport, or camp ground.

Description of current living situation:

Homeless Street Outreach Program
Name:

This certifying agency must be recognized by the local Continuum of Care (CoC) as an agency that has a program designed to serve persons living on the street or other places not meant for human habitation. Examples may be street outreach workers, day shelters, soup kitchens, Health Care for the Homeless sites, etc.

Authorized Agency Representative Signature:

Date:

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Living Situation: Emergency Shelter

The person(s) named above is/are currently living in (or, if currently in hospital or other institution, was living in immediately prior to hospital/institution admission) a supervised publicly or privately operated shelter as follows:

Emergency Shelter Program Name:

This emergency shelter must appear on the CoC’s Housing Inventory Chart submitted as part of the most recent CoC Homeless Assistance application to HUD or otherwise be recognized by the CoC as part of the CoC inventory (e.g., newly established Emergency Shelter).

Authorized Agency Representative Signature: Date
:

Living Situation: Recently Homeless

The person(s) named above is/are currently receiving financial and supportive services for persons who are homeless. Loss of such assistance would result in a return to homelessness (ex. Households in Rapid Rehousing Programs, residents of Permanent Supportive Housing Programs participating in Moving On, etc.)
Authorized Agency Representative Signature:

This referring agency must appear on the CoC’s Housing Inventory Chart submitted as part of the most recent CoC Homeless Assistance application to HUD or otherwise be recognized by the CoC as part of the CoC inventory.

Immediately prior to entering the household’s current living situation, the person(s) named above was/were residing in:

emergency shelter OR a place unfit for human habitation

Authorized Agency Representative Signature:

Date:

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Exhibit 18-3: EXAMPLE OF A VICTIM SERVICES PROVIDER’S CERTIFICATION Attachment 4 of Notice PIH 2021-15: Example of a Victim Services Provider’s Certification Emergency Housing Voucher (EHV)

SAMPLE HUMAN TRAFFICKING CERTIFICATION
Purpose of Form:

The Victims of Trafficking and Violence Protection Act of 2000 provides assistance to victims of trafficking making housing, educational health care, job training and other Federally -funded social service programs available to assist victims in rebuilding their lives.

Use of This Optional Form:

In response to this request, the service provider may complete this form and submit it to the Public Housing Agency (PHA) to certify eligibility for EHV assistance.

Confidentiality: All information provided to the service provider concerning the incident(s) of human trafficking shall be kept confidential and such details shall not be entered into any shared database.

Employees of the PHA will not have access to these details, and such employees may not disclose this information to any other entity or individual, except to the extent that disclosure is: (i) consented to by you in writing in a time-limited release; (ii) required for use in an eviction proceeding or hearing regarding termination of assistance; or (iii) otherwise required by applicable law.

TO BE COMPLETED ON BEHALF OF HUMAN TRAFFICKING SURVIVOR

EHV Applicant Name:

This is to certify that the above named individual or household meets the definition for persons who are fleeing or attempting to flee human trafficking under section 107(b) of the Trafficking Victims Protection Act of 2000.

Immediately prior to entering the household’s current living situation, the person(s) named above was/were residing in:

This is to certify that the information provided on this form is true and correct to the best of my knowledge and recollection, and that the individual(s) named above is/has been a victim of human trafficking. I acknowledge that submission of false information could jeopardize program eligibility and could be the basis for denial of admission, termination of assistance, or eviction.

Authorized Agency Representative Signature: Date:

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GL-1

GLOSSARY
A. ACRONYMS USED IN THE HOUSING CHOICE VOUCHER (HCV) PROGRAM ACC Annual contributions contract
ADA Americans with Disabilities Act of 1990
AIDS Acquired immune deficiency syndrome
BR Bedroom
CDBG Community Development Block Grant (Program)
CFR Code of Federal Regulations (published federal rules that define and implement laws; commonly referred to as “the regulations”)
CPI Consumer price index (published monthly by the Department of Labor as an inflation indicator)
EIV Enterprise Income Verification
FDIC Federal Deposit Insurance Corporation
FHA Federal Housing Administration (HUD Office of Housing) FHEO Fair Housing and Equal Opportunity (HUD Office of) FICA Federal Insurance Contributions Act (established Social Security taxes) FMR Fair market rent
FR Federal Register
FSS Family Self-Sufficiency (Program)
FY Fiscal year
FYE Fiscal year end
GAO Government Accountability Office
GR Gross rent
HA Housing authority or housing agency
HAP Housing assistance payment
HCV Housing choice voucher
HIP Housing Information Portal
HOTMA Housing Opportunity through Modernization Act of 2016 HQS Housing quality standards
HUD Department of Housing and Urban Development
HUDCLIPS HUD Client Information and Policy System
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GL-2
IPA Independent public accountant
IRA Individual retirement account
IRS Internal Revenue Service
IVT Income Validation Tool
JTPA Job Training Partnership Act
LBP Lead-based paint
LEP Limited English proficiency
MSA Metropolitan statistical area (established by the U.S. Census Bureau) MTW Moving to Work
NOFA Notice of funding availability
NSPIRE National Standards for the Physical Inspection of Real Estate OGC HUD's Office of General Counsel
OIG HUD’s Office of Inspector General
OMB Office of Management and Budget
PASS Plan to Achieve Self-Support
PBV Project-based voucher
PHA Public housing agency
PIH (HUD Office of) Public and Indian Housing
PS Payment standard
QC Quality control
RAD Rental Assistance Demonstration Program
REAC (HUD) Real Estate Assessment Center
RFP Request for proposals
RFTA Request for tenancy approval
RIGI Regional inspector general for investigation (handles fraud and program abuse matters for HUD at the regional office level)
RVI Remote Video Inspection
SEMAP Section 8 Management Assessment Program
SRO Single room occupancy
SSA Social Security Administration
SSI Supplemental security income
SWICA State wage information collection agency
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TANF Temporary assistance for needy families
TPV Tenant protection vouchers
TR Tenant rent
TTP Total tenant payment
UA Utility allowance
UFAS Uniform Federal Accessibility Standards
UIV Upfront income verification
URP Utility reimbursement payment
VAWA Violence Against Women Act
VCA Voluntary Compliance Agreement
VMS Voucher Management System
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GL-4
B. GLOSSARY OF SUBSIDIZED HOUSING TERMS
Abatement. Stopping HAP payments to an owner with no potential for retroactive payment.

Absorption. In portability (under subpart H of this part 982): the point at which a receiving PHA stops billing the initial PHA for assistance on behalf of a portability family. The receiving PHA uses funds available under the receiving PHA consolidated ACC.

Accessible. The facility or portion of the facility can be approached, entered, and used by persons with disabilities.

Adjusted income. Annual income, less allowable HUD deductions and allowances.

Administrative fee. Fee paid by HUD to the PHA for administration of the program. See §982.152.

Administrative plan. The plan that describes PHA policies for administration of the tenant-based programs. The Administrative Plan and any revisions must be approved by the PHA’s board and included as a supporting document to the PHA Plan. See §982.54.

Admission. The point when the family becomes a participant in the program. The date used for this purpose is the effective date of the first HAP contract for a family (first day of initial lease term) in a tenant-based program.

Affiliated individual. With respect to an individual, a spouse, parent, brother, sister, or child of that individual, or an individual to whom that individual stands in loco parentis (in the place of a parent), or any individual, tenant, or lawful occupant living in the household of that individual
Amortization payment. In a manufactured home space rental: The monthly debt service payment by the family to amortize the purchase price of the manufactured home.

Annual. Happening once a year.

Annual contributions contract (ACC). The written contract between HUD and a PHA under which HUD agrees to provide funding for a program under the 1937 Act, and the PHA agrees to comply with HUD requirements for the program.

Prior to PHA implementation of HOTMA 102/104: Annual income. The anticipated total income of an eligible family from all sources for the 12-month period following the date of determination of income, computed in accordance with the regulations.

Upon PHA implementation of HOTMA 102/104: Annual income. All amounts not specifically excluded in 24 CFR 5.609(b), received from all sources by each member of the family who is 18 years of age or older or is the head of household, spouse or cohead, plus unearned income by or on behalf of each dependent who is under 18 years of age.

Applicant (applicant family). A family that has applied for admission to a program but is not yet a participant in the program.

Area exception rent. An amount that exceeds the published FMR. See 24 CFR 982.504(b).

As-paid states. States where the welfare agency adjusts the shelter and utility component of the welfare grant in accordance with actual housing costs.

Assets. (See net family assets.)
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GL-5
Authorized voucher units. The number of units for which a PHA is authorized to make assistance payments to owners under its annual
Auxiliary aids. Services or devices that enable persons with impaired sensory, manual, or speaking skills to have an equal opportunity to participate in, and enjoy the benefits of, programs or activities receiving federal financial assistance.

Biennial. Happening every two years.

Bifurcate. With respect to a public housing or Section 8 lease, to divide a lease as a matter of law such that certain tenants can be evicted or removed while the remaining family members’ lease and occupancy rights are allowed to remain intact.

Budget authority. An amount authorized and appropriated by the Congress for payment to PHAs under the program. For each funding increment in a PHA program, budget authority is the maximum amount that may be paid by HUD to the PHA over the ACC term of the funding increment.

Building. A structure with a roof and walls that contains one or more dwelling units.

Child. A member of the family other than the family head or spouse who is under 18 years of age.

Childcare expenses. Amounts anticipated to be paid by the family for the care of children under 13 years of age during the period for which annual income is computed, but only where such care is necessary to enable a family member to actively seek employment, be gainfully employed, or to further their education and only to the extent such amounts are not reimbursed. The amount deducted shall reflect reasonable charges for childcare. In the case of childcare necessary to permit employment, the amount deducted shall not exceed the amount of employment income that is included in annual income.

Citizen. A citizen or national of the United States.

Cohead. An individual in the household who is equally responsible for the lease with the head of household. A family may have a cohead or spouse but not both. A cohead never qualifies as a dependent. The cohead must have legal capacity to enter into a lease.

Common space. In shared housing, the space available for use by the assisted family and other occupants of the unit.

Computer match. The automated comparison of databases containing records about individuals.

Confirmatory review. An on-site review performed by HUD to verify the management performance of a PHA.

Consent form. Any consent form approved by HUD to be signed by assistance applicants and participants to obtain income information from employers and SWICAs; return information from the Social Security Administration (including wages, net earnings from self- employment, and retirement income); and return information for unearned income from the IRS. Consent forms expire after a certain time and may authorize the collection of other information to determine eligibility or level of benefits.

Congregate housing. Housing for elderly persons or persons with disabilities that meets the HQS for congregate housing. A special housing type: see 24 CFR 982.606–609.

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Contiguous MSA. In portability (under subpart H of part 982): An MSA that shares a common boundary with the MSA in which the jurisdiction of the initial PHA is located.

Continuously assisted. An applicant is continuously assisted under the 1937 Act if the family is already receiving assistance under any 1937 Housing Act program when the family is admitted to the voucher program.

Contract authority. The maximum annual payment by HUD to a PHA for a funding increment.

Cooperative (term includes mutual housing). Housing owned by a nonprofit corporation or association, and where a member of the corporation or association has the right to reside in a particular apartment, and to participate in management of the housing. A special housing type (see 24 CFR 982.619).

Covered families. Statutory term for families who are required to participate in a welfare agency economic self-sufficiency program and who may be subject to a welfare benefit sanction for noncompliance with this obligation. Includes families who receive welfare assistance or other public assistance under a program for which federal, state or local law requires that a member of the family must participate in an economic self-sufficiency program as a condition for the assistance.

Dating violence. Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim; and where the existence of such a relationship shall be determined based on a consideration of the following factors:
- The length of the relationship
- The type of relationship
- The frequency of interaction between the persons involved in the relationship Day laborer. An individual hired and paid one day at a time without an agreement that the individual will be hired or work again in the future.

De minimis error. An error that results in a difference in the determination of a family’s adjusted income of $30 or less per month.

Dependent. A member of the family (except foster children and foster adults) other than the family head or spouse, who is under 18 years of age, or is a person with a disability, or is a full-time student.

Dependent child. In the context of the student eligibility restrictions, a dependent child of a student enrolled in an institution of higher education. The dependent child must also meet the definition of dependent as specified above.

Disability assistance expenses. Reasonable expenses that, when combined with health and medical care expenses, exceed 10 percent of annual income and are anticipated, during the period for which annual income is computed, for attendant care and auxiliary apparatus for a disabled family member, and that are necessary to enable a family member (including the disabled member) to be employed, provided that the expenses are neither paid to a member of the family nor reimbursed by an outside source.

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Disabled family. A family whose head, cohead, spouse, or sole member is a person with disabilities; two or more persons with disabilities living together; or one or more persons with disabilities living with one or more live-in aides.

Disabled person. See person with disabilities.

Disallowance. Exclusion from annual income.

Displaced family. A family in which each member, or whose sole member, is a person displaced by governmental action, or a person whose dwelling has been extensively damaged or destroyed as a result of a disaster declared or otherwise formally recognized pursuant to federal disaster relief laws.

Domestic violence. Felony or misdemeanor crimes committed by a current or former spouse or intimate partner of the victim under the family or domestic violence laws of the jurisdiction receiving grant funding, and in the case of victim services, includes the user or attempted use of physical abuse or sexual abuse, or a pattern of any other coercive behavior committed, enabled, or solicited to gain or maintain power and control over a victim, including verbal, psychological, economic, or technological abuse that may or may not constitute criminal behavior, by a person who is:
- The current or former spouse or intimate partner of the victim, or person similarly situated to a spouse or intimate partner of the victim
- A person who is cohabitating or has cohabitated with the victim as a spouse or intimate partner
- A person with whom the victim shares a child in common - A person who commits acts against a youth or adult victim who is protected from those acts under the domestic or family violence laws of the jurisdiction Domicile. The legal residence of the household head or spouse as determined in accordance with state and local law.

Drug-related criminal activity. The illegal manufacture, sale, distribution, or use of a drug, or the possession of a drug with intent to manufacture, sell, distribute, or use the drug.

Earned income. Income or earnings from wages, tips, salaries, other employee compensation, and net income from self-employment. Earned income does not include any pension or annuity, transfer payments (meaning payments made or income received in which no goods or services are being paid for, such as welfare, social security, and governmental subsidies for certain benefits), or any cash or in-kind benefits.

Economic abuse. Behavior that is coercive, deceptive, or unreasonably controls or restrains a person’s ability to acquire, use, or maintain economic resources to which they are entitle, including using coercion, fraud, and manipulation to:

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- Restrict a person’s access to money, assets, credit, or financial information - Unfairly use a person’s personal economic resources, including money, assets, and credit, for one’s own advantage
- Exert undue influence over a person’s financial and economic behavior or decisions, including forcing default on joint or other financial obligations, exploiting powers of attorney, guardianship, or conservatorship, or to whom one has a fiduciary duty Economic self-sufficiency program. Any program designed to encourage, assist, train or facilitate the economic independence of assisted families, or to provide work for such families. Can include job training, employment counseling, work placement, basic skills training, education, English proficiency, Workfare, financial or household management, apprenticeship, or any other program necessary to ready a participant to work (such as treatment for drug abuse or mental health treatment). Includes any work activities as defined in the Social Security Act (42 U.S.C. 607(d)). Also see 24 CFR 5.603(c).

Elderly family. A family whose head, cohead, spouse, or sole member is a person who is at least 62 years of age; two or more persons who are at least 62 years of age living together; or one or more persons who are at least 62 years of age living with one or more live-in aides.

Elderly person. An individual who is at least 62 years of age.

Eligible family A family that is income eligible and meets the other requirements of the 1937 Act and Part 5 of 24 CFR. See also family.

Employer identification number (EIN). The nine-digit taxpayer identifying number that is assigned to an individual, trust, estate, partnership, association, company, or corporation.

Evidence of citizenship or eligible status. The documents which must be submitted as evidence of citizenship or eligible immigration status. See 24 CFR 5.508(b).

Extremely low-income family. A family whose annual income does not exceed the federal poverty level or 30 percent of the median income for the area, whichever number is higher.

Area median income is determined by HUD, with adjustments for smaller and larger families. HUD may establish income ceilings higher or lower than 30 percent of median income if HUD finds such variations are necessary due to unusually high or low family incomes. See 24 CFR 5.603.

Fair Housing Act. Title VIII of the Civil Rights Act of 1968, as amended by the Fair Housing Amendments Act of 1988.

Fair market rent (FMR). The rent, including the cost of utilities (except telephone), as established by HUD for units of varying sizes (by number of bedrooms), that must be paid in the housing market area to rent privately owned, existing, decent, safe, and sanitary rental housing of modest (non-luxury) nature with suitable amenities. In the HCV program, the FMR may be established at the ZIP code level (see definition of Small Area Fair Market Rents), metropolitan area level, or nonmetropolitan county level.

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GL-9
Family. Includes but is not limited to the following, regardless of actual or perceived sexual orientation, gender identity, or marital status, and can be further defined in PHA policy.

Family includes a single person, who may be:
- An elderly person, displaced person, disabled person, near-elderly person, or any other single person;
- An otherwise eligible youth who has attained at least 18 years of age and not more than 24 years of age and who has left foster care, or will leave foster care within 90 days, in accordance with a transition plan described in section 475(5)(H) of the Social Security Act (42 U.S.C. 675(5)(H)), and is homeless or is at risk of becoming homeless at age 16 or older; or
Family also includes a group of persons residing together, and such group includes, but is not limited to:
- A family with or without children (a child who is temporarily away from the home because of placement in foster care is considered a member of the family); - An elderly family;
- A near-elderly family;
- A disabled family;
- A displaced family; and
- The remaining member of a tenant family.

Family rent to owner. In the voucher program, the portion of rent to owner paid by the family.

Family self-sufficiency program (FSS program). The program established by a PHA within its jurisdiction to promote self-sufficiency among participating families, including the coordination of supportive services to these families (24 CFR 984.103).

Family share. The portion of rent and utilities paid by the family. For calculation of family share, see 24 CFR 982.515(a).

Family unit size. The appropriate number of bedrooms for a family, as determined by the PHA under the PHA subsidy standards.

Federal agency. A department of the executive branch of the federal government.

Foster adult. A member of the household who is 18 years of age or older and meets the definition of a foster adult under state law. In general, a foster adult is a person who is 18 years of age or older, is unable to live independently due to a debilitating physical or mental condition, and is placed with the family by an authorized placement agency or by judgment, decree, or other order of any court of competent jurisdiction.

Foster child. A member of the household who meets the definition of a foster child under state law. In general, a foster child is placed with the family by an authorized placement agency (e.g., public child welfare agency) or by judgment, decree, or other order of any court of competent jurisdiction.

Exhibit 2
927 of 1125

GL-10
Foster childcare payment. A payment to eligible households by state, local, or private agencies appointed by the state to administer payments for the care of foster children.

Full-time student. A person who is attending school or vocational training on a full-time basis (carrying a subject load that is considered full-time for day students under the standards and practices of the educational institution attended). See 24 CFR 5.603.

Funding increment. Each commitment of budget authority by HUD to a PHA under the consolidated annual contributions contract for the PHA program.

Gender identity. Actual or perceived gender-related characteristics.

Gross rent. The sum of the rent to owner plus any utility allowance.

Group home. A dwelling unit that is licensed by a state as a group home for the exclusive residential use of two to twelve persons who are elderly or persons with disabilities (including any live-in aide). (A special housing type: see 24 CFR 982.610–614.) Handicap. Any condition or characteristic that renders a person an individual with handicaps. (See person with disabilities.)
HAP contract. The housing assistance payments contract. A written contract between the PHA and an owner for the purpose of providing housing assistance payments to the owner on behalf of an eligible family.

Head of household. The adult member of the family who is the head of the household for purposes of determining income eligibility and rent.

Health and medical care expenses. Any costs incurred in the diagnosis, cure, mitigation, treatment, or prevention of disease or payments for treatments affecting any structure or function of the body. Health and medical care expenses include medical insurance premiums and long-term care premiums that are paid or anticipated during the period for which annual income is computed.

Household. A household includes additional people other than the family who, with the PHA’s permission, live in an assisted unit, such as live-in aides, foster children, and foster adults.

Housing assistance payment. The monthly assistance payment by a PHA, which includes: (1) A payment to the owner for rent to the owner under the family's lease; and (2) An additional payment to the family if the total assistance payment exceeds the rent to owner.

Housing agency (HA). See public housing agency.

Housing quality standards (HQS). The minimum quality standards developed by HUD in accordance with 24 CFR 5.703 for the HCV program, including any variations approved by HUD for the PHA under 24 CFR 5.705(a)(3).

HUD. The U.S. Department of Housing and Urban Development.

Exhibit 2
928 of 1125

GL-11
Human trafficking. A crime involving the exploitation of a person for labor, services, or commercial sex. The Trafficking Victims Protection Act of 2000 and its subsequent reauthorizations recognize and define two primary forms of human trafficking:
- Sex trafficking is the recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purpose of a commercial sex act in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age. See 22 U.S.C. § 7102(11)(A). - Forced labor is the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery. See 22 U.S.C. § 7102(11)(B).

Imputed welfare income. An amount of annual income that is not actually received by a family as a result of a specified welfare benefit reduction, but is included in the family’s annual income and therefore reflected in the family’s rental contribution.

Income for eligibility. Annual income.

Independent contractor. An individual who qualifies as an independent contractor instead of an employee in accordance with the Internal Revenue Code Federal income tax requirements and whose earnings are consequently subject to the Self-Employment Tax. In general, an individual is an independent contractor if the payer has the right to control or direct only the result of the work and not what will be done and how it will be done.

Independent entity. The unit of general local government; however, if the PHA itself is the unit of general local government or an agency of such government, then only the next level of general local government (or an agency of such government) or higher may serve as the independent entity; or a HUD-approved entity that is autonomous and recognized under state law as a separate legal entity from the PHA. The entity must not be connected financially (except regarding compensation for services performed for PHA-owned units) or in any other manner that could result in the PHA improperly influencing the entity.

Individual with handicaps. See person with disabilities.

Upon PHA implementation of HOTMA 102/104: Inflationary index. An index based on the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) used to make annual adjustments to the deduction for elderly disabled families, the cap for imputing returns on assets, the restriction on net family assets, the amount of net assets the PHA may determine based on self-certification by the family, and the dependent deduction.

Exhibit 2
929 of 1125

GL-12
Initial PHA. In portability, the term refers to both: (1) A PHA that originally selected a family that later decides to move out of the jurisdiction of the selecting PHA; and (2) A PHA that absorbed a family that later decides to move out of the jurisdiction of the absorbing PHA.

Initial payment standard. The payment standard at the beginning of the HAP contract term.

Initial rent to owner. The rent to owner at the beginning of the HAP contract term.

Inside. Under NSPIRE, the inside of HUD housing (or “inside areas”) refers to the common areas and building systems that can be generally found within the building interior and are not inside a unit. Examples of “inside” common areas may include, basements, interior or attached garages, enclosed carports, restrooms, closets, utility rooms, mechanical rooms, community rooms, day care rooms, halls, corridors, stairs, shared kitchens, laundry rooms, offices, enclosed porches, enclosed patios, enclosed balconies, and trash collection areas.

Examples of building systems include those components that provide domestic water such as pipes, electricity, elevators, emergency power, fire protection, HVAC, and sanitary services.

Institution of higher education. An institution of higher education as defined in 20 U.S.C. 1001 and 1002. See Exhibit 3-2 in this Administrative Plan.

Jurisdiction. The area in which the PHA has authority under state and local law to administer the program.

Landlord. Either the owner of the property or their representative, or the managing agent or their representative, as shall be designated by the owner.

Lease. A written agreement between an owner and a tenant for the leasing of a dwelling unit to the tenant. The lease establishes the conditions for occupancy of the dwelling unit by a family with housing assistance payments under a HAP contract between the owner and the PHA.

Life-Threatening deficiency. Under NSPIRE, the life-threatening category includes deficiencies that, if evident in the home or on the property, present a high risk of death or severe illness or injury to a resident.

Live-in aide. A person who resides with one or more elderly persons, or near-elderly persons, or persons with disabilities, and who:
- Is determined to be essential to the care and well-being of the persons; - Is not obligated for the support of the persons; and
- Would not be living in the unit except to provide the necessary supportive services.

Local preference. A preference used by the PHA to select among applicant families.

Low deficiency. Under NSPIRE, deficiencies critical to habitability but not presenting a substantive health or safety risk to resident.

Low-income family. A family whose income does not exceed 80 percent of the median income for the area as determined by HUD with adjustments for smaller or larger families, except that HUD may establish income limits higher or lower than 80 percent for areas with unusually high or low incomes.

Exhibit 2
930 of 1125

GL-13
Manufactured home. A manufactured structure that is built on a permanent chassis, is designed for use as a principal place of residence, and meets the HQS. (A special housing type: see 24 CFR 982.620 and 982.621.)
Manufactured home space. In manufactured home space rental: A space leased by an owner to a family. A manufactured home owned and occupied by the family is located on the space. See 24 CFR 982.622 to 982.624.

Minor. A member of the family household other than the family head or spouse, who is under 18 years of age.

Mixed family. A family whose members include those with citizenship or eligible immigration status, and those without citizenship or eligible immigration status.

Moderate deficiency. Under NSPIRE, this includes deficiencies that, if evident in the home or on the property, present a moderate risk of an adverse medical event requiring a healthcare visit; cause temporary harm; or if left untreated, cause or worsen a chronic condition that may have long-lasting adverse health effects; or that the physical security or safety of a resident or their property could be compromised.

Monthly adjusted income. One twelfth of adjusted income.

Monthly income. One twelfth of annual income.

Mutual housing. Included in the definition of cooperative.

National. A person who owes permanent allegiance to the United States, for example, as a result of birth in a United States territory or possession.

National Standards for the Physical Inspection of Real Estate. HUD’s housing inspection approach. NSPIRE is a single inspection standard for all units under the Public Housing, HCV, Multifamily, and Community Planning and Development (CPD) programs. NSPIRE’s focus is on the areas that impact residents the most, such as the dwelling unit.

Near-elderly family. A family whose head, spouse, or sole member is a person who is at least 50 years of age but below the age of 62; or two or more persons, who are at least 50 years of age but below the age of 62, living together; or one or more persons who are at least 50 years of age but below the age of 62 living with one or more live-in aides.

Prior to PHA implementation of HOTMA 102/104: Net family assets. (1) Net cash value after deducting reasonable costs that would be incurred in disposing of real property, savings, stocks, bonds, and other forms of capital investment, excluding interests in Indian trust land and excluding equity accounts in HUD homeownership programs. The value of necessary items of personal property such as furniture and automobiles shall be excluded. - In cases where a trust fund has been established and the trust is not revocable by, or under the control of, any member of the family or household, the value of the trust fund will not be considered an asset so long as the fund continues to be held in trust. Any income distributed from the trust fund shall be counted when determining annual income under §5.609.
- In determining net family assets, PHAs or owners, as applicable, shall include the value of any business or family assets disposed of by an applicant or tenant for less than fair market value (including a disposition in trust, but not in a foreclosure or bankruptcy sale) Exhibit 2
931 of 1125

GL-14
during the two years preceding the date of application for the program or reexamination, as applicable, in excess of the consideration received therefore. In the case of a disposition as part of a separation or divorce settlement, the disposition will not be considered to be for less than fair market value if the applicant or tenant receives important consideration not measurable in dollar terms.

Upon PHA implementation of HOTMA 102/104: Net family assets. The net cash value of all assets owned by the family, after deducting reasonable costs that would be incurred in disposing real property, savings, stocks, bonds, and other forms of capital investment. In determining net family assets, PHAs or owners, as applicable, must include the value of any business or family assets disposed of by an applicant or tenant for less than fair market value (including a disposition in trust, but not in a foreclosure or bankruptcy sale) during the two years preceding the date of application for the program or reexamination, as applicable, in excess of the consideration received therefor. In the case of a disposition as part of a separation or divorce settlement, the disposition will not be considered to be for less than fair market value if the applicant or tenant receives consideration not measurable in dollar terms. Negative equity in real property or other investments does not prohibit the owner from selling the property or other investments, so negative equity alone would not justify excluding the property or other investments from family assets.

Noncitizen. A person who is neither a citizen nor national of the United States.

Notice of funding availability (NOFA). For budget authority that HUD distributes by competitive process, the Federal Register document that invites applications for funding.

This document explains how to apply for assistance and the criteria for awarding the funding.

Office of General Counsel (OGC). The General Counsel of HUD.

Outside. Under NSPIRE, outside of HUD housing (or “outside areas”) refers to the building site, building exterior components, and any building systems located outside of the building or unit. Examples of “outside” components may include fencing, retaining walls, grounds, lighting, mailboxes, project signs, parking lots, detached garage or carport, driveways, play areas and equipment, refuse disposal, roads, storm drainage, non-dwelling buildings, and walkways. Components found on the exterior of the building are also considered outside areas, and examples may include doors, attached porches, attached patios, balconies, car ports, fire escapes, foundations, lighting, roofs, walls, and windows.

Overcrowded. A unit that does not have at least one bedroom or living/sleeping room for each two persons.

Owner. Any person or entity with the legal right to lease or sublease a unit to a participant.

PHA-owned unit. A dwelling unit in a project that is: (A) Owned by the PHA (including having a controlling interest in the entity that owns the project); (B) Owned by an entity wholly controlled by the PHA; or (C) Owned by a limited liability company or limited partnership in which the PHA (or an entity wholly controlled by the PHA) holds a controlling interest in the managing member or general partner. A controlling interest is: (A) Holding more than 50 percent of the stock of any corporation; (B) Having the power to appoint more than 50 percent of the members of the board of directors of a non-stock corporation (such as a nonprofit corporation); (C) Where more than 50 percent of the members of the board of directors of any corporation also serve as directors, officers, or employees of the PHA; (D) Exhibit 2
932 of 1125

GL-15
Holding more than 50 percent of all managing member interests in an LLC; (E) Holding more than 50 percent of all general partner interests in a partnership; or (F) Equivalent levels of control in other ownership structures.

PHA Plan. The annual plan and the 5-year plan as adopted by the PHA and approved by HUD.

PHA’s quality control sample. An annual sample of files or records drawn in an unbiased manner and reviewed by a PHA supervisor (or by another qualified person other than the person who performed the original work) to determine if the work documented in the files or records conforms to program requirements. For minimum sample size see CFR 985.3.

Participant (participant family). A family that has been admitted to the PHA program and is currently assisted in the program. The family becomes a participant on the effective date of the first HAP contract executed by the PHA for the family (first day of initial lease term).

Payment standard. The maximum monthly assistance payment for a family assisted in the voucher program (before deducting the total tenant payment by the family).

Person with disabilities. For the purposes of program eligibility. A person who has a disability as defined under the Social Security Act or Developmental Disabilities Care Act, or a person who has a physical or mental impairment expected to be of long and indefinite duration and whose ability to live independently is substantially impeded by that impairment but could be improved by more suitable housing conditions. This includes persons with AIDS or conditions arising from AIDS but excludes persons whose disability is based solely on drug or alcohol dependence. For the purposes of reasonable accommodation. A person with a physical or mental impairment that substantially limits one or more major life activities, a person regarded as having such an impairment, or a person with a record of such an impairment.

Portability. Renting a dwelling unit with a Section 8 housing choice voucher outside the jurisdiction of the initial PHA.

Premises. The building or complex in which the dwelling unit is located, including common areas and grounds.

Private space. In shared housing, the portion of a contract unit that is for the exclusive use of an assisted family.

Project owner. The person or entity that owns the housing project containing the assisted dwelling unit.

Public assistance. Welfare or other payments to families or individuals, based on need, which are made under programs funded, separately or jointly, by federal, state, or local governments.

Public housing agency (PHA). Any state, county, municipality, or other governmental entity or public body, or agency or instrumentality of these entities, that is authorized to engage or assist in the development or operation of low-income housing under the 1937 Act.

Qualified census tract. With regard to certain tax credit units, any census tract (or equivalent geographic area defined by the Bureau of the Census) in which at least 50 percent of households have an income of less than 60 percent of Area Median Gross Income (AMGI), Exhibit 2
933 of 1125

GL-16
or where the poverty rate is at least 25 percent, and where the census tract is designated as a qualified census tract by HUD.

Upon PHA implementation of HOTMA 102/104: Real property. Real property has the same meaning as that provided under the law of the state in which the property is located.

Reasonable rent. A rent to owner that is not more than rent charged: (1) For comparable units in the private unassisted market; and (2) For comparable unassisted units in the premises.

Reasonable accommodation. A change, exception, or adjustment to a rule, policy, practice, or service to allow a person with disabilities to fully access the PHA’s programs or services.

Receiving PHA. In portability: A PHA that receives a family selected for participation in the tenant-based program of another PHA. The receiving PHA issues a voucher and provides program assistance to the family.

Recertification. Sometimes called reexamination. The process of securing documentation of total family income used to determine the rent the tenant will pay for the next 12 months if there are no additional changes to be reported.

Remaining member of the tenant family. The person left in assisted housing who may or may not normally qualify for assistance on their own circumstances (i.e., an elderly spouse dies, leaving widow age 47 who is not disabled).

Rent to owner. The total monthly rent payable to the owner under the lease for the unit (also known as contract rent). Rent to owner covers payment for any housing services, maintenance, and utilities that the owner is required to provide and pay for.

Request for Tenancy Approval (RTA). A form (Form HUD-52517) submitted by or on behalf of a family to a PHA once the family has identified a unit that it wishes to rent using tenant- based voucher assistance.

Residency preference. A PHA preference for admission of families that reside anywhere in a specified area, including families with a member who works or has been hired to work in the area (See residency preference area).

Residency preference area. The specified area where families must reside to qualify for a residency preference.

Responsible entity. For the public housing and the Section 8 tenant-based assistance, project- based voucher assistance, and moderate rehabilitation programs, the responsible entity means the PHA administering the program under an ACC with HUD. For all other Section 8 programs, the responsible entity means the Section 8 owner.

Secretary. The Secretary of Housing and Urban Development.

Section 8. Section 8 of the United States Housing Act of 1937.

Section 8 covered programs. All HUD programs which assist housing under Section 8 of the 1937 Act, including Section 8 assisted housing for which loans are made under Section 202 of the Housing Act of 1959.

Section 8 Management Assessment Program (SEMAP). A system used by HUD to measure PHA performance in key Section 8 program areas. See 24 CFR Part 985.

Exhibit 2
934 of 1125

GL-17
Section 214. Section 214 of the Housing and Community Development Act of 1980, as amended.

Section 214 covered programs. The collective term for the HUD programs to which the restrictions imposed by Section 214 apply. These programs are set forth in 24 CFR 5.500.

Security deposit. A dollar amount (maximum set according to the regulations) which can be used for unpaid rent or damages to the owner upon termination of the lease.

Seasonal worker. An individual who is hired into a short-term position and the employment begins about the same time each year (such as summer or winter). Typically, the individual is hired to address seasonal demands that arise for the particular employer or industry.

Set-up charges. In a manufactured home space rental, charges payable by the family for assembling, skirting, and anchoring the manufactured home.

Severe deficiency. Under NSPIRE, the severe category includes deficiencies that, if evident in the home or on the property, present a high risk of permanent disability, or serious injury or illness, to a resident; or the physical security or safety of a resident or their property would be seriously compromised.

Sexual assault. Any nonconsensual sexual act proscribed by federal, tribal, or state law, including when the victim lacks capacity to consent (42 U.S.C. 13925(a)).

Sexual orientation. Homosexuality, heterosexuality or bisexuality.

Shared housing. A unit occupied by two or more families. The unit consists of both common space for shared use by the occupants of the unit and separate private space for each assisted family. (A special housing type: see 24 CFR 982.615–982.618.) Single person. A person living alone or intending to live alone.

Single room occupancy housing (SRO). A unit that contains no sanitary facilities or food preparation facilities, or contains either, but not both, types of facilities. (A special housing type: see 24 CFR 982.602–982.605.)
Small Area Fair Market Rents (SAFMRs). FMRs established for ZIP code areas.

Small rural public housing agency (PHA). Section 38 defines the term “small public housing agency” as a public housing agency “for which the sum of the number of public housing dwelling units administered by the agency and the number of vouchers under section 8(o) administered by the agency is 550 or fewer” and “that predominantly operates in a rural area, as described in section 1026.35(b)(2)(iv)(A) of title 12, Code of Federal Regulations.” After consideration of the public comments discussed above, HUD is interpreting “predominantly operates in a rural area” to mean a small PHA that:
(1) Has a primary administrative building with a physical address in a rural area as described in 12 CFR 1026.35(b)(2)(iv)(A); or
(2) more than 50 percent of its combined public housing units and voucher units under section 8(o) are in rural areas as described in 12 CFR 1026.35(b)(2)(iv)(A). HUD also clarifies that voucher units under section 8(o) include those in the tenant-based Housing Choice Voucher (HCV) program and the Project-Based Voucher (PBV) program.

Exhibit 2
935 of 1125

GL-18
Social security number (SSN). The nine-digit number that is assigned to a person by the Social Security Administration and that identifies the record of the person’s earnings reported to the Social Security Administration. The term does not include a number with a letter as a suffix that is used to identify an auxiliary beneficiary.

Special admission. Admission of an applicant that is not on the PHA waiting list or without considering the applicant’s waiting list position.

Special housing types. See subpart M of part 982. Subpart M states the special regulatory requirements for: SRO housing, congregate housing, group homes, shared housing, cooperatives (including mutual housing), and manufactured homes (including manufactured home space rental).

Specified welfare benefit reduction. Those reductions of welfare benefits (for a covered family) that may not result in a reduction of the family rental contribution. A reduction of welfare benefits because of fraud in connection with the welfare program, or because of welfare sanction due to noncompliance with a welfare agency requirement to participate in an economic self-sufficiency program.

Spouse. The marriage partner of the head of household.

Stalking. To follow, pursue, or repeatedly commit acts with the intent to kill, injure, harass, or intimidate; or to place under surveillance with the intent to kill, injure, harass, or intimidate another person; and in the course of, or as a result of, such following, pursuit, surveillance, or repeatedly committed acts, to place a person in reasonable fear of the death of, or serious bodily injury to, or to cause substantial emotional harm to (1) that person, (2) a member of the immediate family of that person, or (3) the spouse or intimate partner of that person.

State wage information collection agency (SWICA). The state agency, including any Indian tribal agency, receiving quarterly wage reports from employers in the state, or an alternative system that has been determined by the Secretary of Labor to be as effective and timely in providing employment-related income and eligibility information.

Subsidy standards. Standards established by a PHA to determine the appropriate number of bedrooms and amount of subsidy for families of different sizes and compositions.

Suspension. The term on the family’s voucher stops from the date the family submits a request for PHA approval of the tenancy, until the date the PHA notifies the family in writing whether the request has been approved or denied. This practice is also called tolling.

Tax credit rent. With regard to certain tax credit units, the rent charged for comparable units of the same bedroom size in the building that also receive the low-income housing tax credit but do not have any additional rental assistance (e.g., tenant-based voucher assistance).

Technological abuse. An act or pattern of behavior that occurs within domestic violence, dating violence, sexual assault, or stalking and is intended to harm, threaten, intimidate, control, stalk, harass, impersonate, exploit, extort, or monitor another person, except as otherwise permitted by law, that occurs using any form of technology, including but not limited to:

Exhibit 2
936 of 1125

GL-19
- Internet enabled devices
- Online spaces and platforms
- Computers
- Mobile devices
- Cameras and imaging programs
- Apps
- Location tracking devices
- Communication technologies
- Any other emergency technologies
Tenancy addendum. For the housing choice voucher program, the lease language required by HUD in the lease between the tenant and the owner.

Tenant. The person or persons (other than a live-in aide) who executes the lease as lessee of the dwelling unit.

Tenant-paid utilities. Utilities and services that are not included in the rent to owner and are the responsibility of the assisted family, regardless of whether the payment goes to the utility company or the owner. The utilities and services are those necessary in the locality to provide housing that complies with HQS. The utilities and services may also include those required by HUD through a Federal Register notice after providing opportunity for public comment.

Tenant rent to owner. See family rent to owner.

Term of lease. The amount of time a tenant agrees in writing to live in a dwelling unit.

Total tenant payment (TTP). The total amount the HUD rent formula requires the tenant to pay toward rent and utilities.

Unearned income. Any annual income, as calculated under 24 CFR 5.609, that is not earned income.

Unit. Under NSPIRE, a unit (or “dwelling unit”) of HUD housing refers to the interior components of an individual unit. Examples of components included in the interior of a unit may include the balcony, bathroom, call-for-aid (if applicable), carbon monoxide devices, ceiling, doors, electrical systems, enclosed patio, floors, HVAC (where individual units are provided), kitchen, lighting, outlets, smoke detectors, stairs, switches, walls, water heater, and windows.

Utilities. Water, electricity, gas, other heating, refrigeration, cooking fuels, trash collection, and sewage services. Telephone service is not included.

Utility allowance. If the cost of utilities (except telephone) and other housing services for an assisted unit is not included in the tenant rent but is the responsibility of the family occupying the unit, an amount equal to the estimate made or approved by a PHA or HUD of the monthly cost of a reasonable consumption of such utilities and other services for the unit by an energy-conservative household of modest circumstances consistent with the requirements of a safe, sanitary, and healthful living environment.

Exhibit 2
937 of 1125

GL-20
Utility reimbursement. In the voucher program, the portion of the housing assistance payment which exceeds the amount of rent to owner.

Utility hook-up charge. In a manufactured home space rental: Costs payable by a family for connecting the manufactured home to utilities such as water, gas, electrical and sewer lines.

Very low-income family. A low-income family whose annual income does not exceed 50 percent of the median income for the area, as determined by HUD, with adjustments for smaller and larger families. HUD may establish income limits higher or lower than 50 percent of the median income for the area on the basis of its finding that such variations are necessary because of unusually high or low family incomes. This is the income limit for the housing choice voucher program.

Veteran. A person who has served in the active military or naval service of the United States at any time and who shall have been discharged or released therefrom under conditions other than dishonorable.

Violence Against Women Act (VAWA). Prohibits denying admission to the program to an otherwise qualified applicant or terminating assistance on the basis that the applicant or program participant is or has been a victim of domestic violence, dating violence, sexual assault, stalking, or human trafficking.

Violent criminal activity. Any illegal criminal activity that has as one of its elements the use, attempted use, or threatened use of physical force against the person or property of another.

Voucher (housing choice voucher). A document issued by a PHA to a family selected for admission to the housing choice voucher program. This document describes the program and the procedures for PHA approval of a unit selected by the family. The voucher also states obligations of the family under the program.

Voucher holder. A family holding a voucher with an unexpired term (search time).

Voucher program. The housing choice voucher program.

Waiting list. A list of families organized according to HUD regulations and PHA policy who are waiting for a unit to become available.

Waiting list admission. An admission from the PHA waiting list.

Welfare assistance. Income assistance from federal or state welfare programs, including assistance provided under TANF and general assistance. Does not include assistance directed solely to meeting housing expenses, nor programs that provide health care, child care or other services for working families. For the FSS program (24 CFR 984.103), welfare assistance includes only cash maintenance payments designed to meet a family’s ongoing basic needs.

Does not include nonrecurring short term benefits designed to address individual crisis situations, work subsidies, supportive services such as child care and transportation provided to families who are employed, refundable earned income tax credits, contributions to and distributions from Individual Development Accounts under TANF, services such as counseling, case management, peer support, child care information and referral, financial empowerment, transitional services, job retention, job advancement, and other employment- related services that to not provide basic income support, amounts solely directed to meeting housing expenses, amounts for health care, Supplemental Nutrition Assistance Program (SNAP) and emergency rental and utilities assistance, SSI, SSDI, or social security, and Exhibit 2
938 of 1125

GL-21
child-only or non-needy TANF grants made to or on behalf of a dependent child solely on the basis of the child’s need and not the need of the child’s current non-parental caretaker.

Exhibit 2
939 of 1125

Exhibit 2
940 of 1125

© Copyright 2025 Nan McKay & Associates Admin Plan 6/1/2026 Unlimited copies may be made for internal use
Appendix-1
HOTMA 102/104 Appendix to the
Administrative Plan
Purpose of the Appendix
HUD published a final rule on February 14, 2023, revising regulations related to income, assets, adjusted income, verification, and reexams (among others) to implement Sections 102 and 104 of HOTMA. While the new regulations were effective January 1, 2024, HUD has delayed the full compliance date for HOTMA 102/104. Initially, Compliance with Sections 102 and 104 of HOTMA means not only applying HOTMA 102/104 regulations to affected programs but also reporting in HUD’s new Housing Information Portal (HIP) system. Currently, PHAs remain unable to fully comply with HOTMA 102/104 because compliance depends on transitioning from HUD’s IMS/PIC system (which is unable to accept HOTMA-compliant Form HUD-50058) to HUD’s new HIP system (which will be the only system that accepts HOTMA-compliant Form HUD-50058). PHAs cannot transition to HOTMA until HIP is in place, HOTMA-compliant, and accessible.

On December 18, 2024, HUD published Notice PIH 2024-38, which identifies provisions in HOTMA 102/104 that PHAs must comply with no later than July 1, 2025. The notice states that all transactions with an effective date on or after July 1, 2025, must be processed using requirements in the notice. The July 1, 2025, compliance deadline does not apply to other HOTMA 102/104 provisions not listed in the notice. Other provisions are still dependent on HIP implementation and may not be implemented yet.

The PHA must:
• Have stopped enrolling families into the EID as of 12/31/23; • Transition to the new Form HUD-9886-A no later than 2/1/25; • Apply HOTMA 102/104 income exclusions listed in 24 CFR 5.609(b) (including new requirements for student financial assistance) for all income examinations effective on or after 7/1/25;
• Apply provisions related to de minimis errors; and
• Use these new HOTMA 102/104 definitions listed in the regulations for all transactions effective on or after 7/1/25.

Exhibit 2
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© Copyright 2025 Nan McKay & Associates Admin Plan 6/1/2026 Unlimited copies may be made for internal use
Appendix-2
These definitions include:
• Earned income
• Unearned income
• Family
• Day laborer
• Independent contractor
• Dependent
• Foster child and foster adults
• Health and medical care expenses
• Minor
Further, PHAs may, but are not required to:
• Stop using the EIV Income Report during interim reexams. • Use Safe Harbor income determinations from means-tested federal assistance programs to verify a family’s income and assets.

Finally, in FAQs dated 2/22/24, HUD also stated PHAs may, but are not required to:
• Accept third-party verification dated within 120 days of the date received by the PHA (rather than 60 days of the reexam/PHA request date);
• Accept a statement dated within the appropriate benefit year for fixed income sources like Social Security; and
• Accept a self-certification of SSNs along with a third-party document as a last resort if an individual is not able to provide documentation of SSN.

More details about each of the above provisions can be found in Notice PIH 2023-27.

Other than what’s listed above, all other provisions of HOTMA 102/104 are on hold still. This means PHAs may not implement certain provisions of HOTMA yet. These include:
• All asset provisions, including the asset limitation; • All adjusted income provisions, with the exception of the definition of health and medical care expenses;
• Inflationary adjustments (although PHA may use the HUD-determined passbook rate); • The new verification hierarchy, which allows for EIV + self-certification; • Annuals using the previous 12-month period income;
• Interim reexam requirements; and
• Non-interim reexam transactions.

PHAs may not implement the above provisions because HUD has determined they depend on HIP implementation. PHAs should await further guidance from HUD on when these will be applicable.

Exhibit 2
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© Copyright 2025 Nan McKay & Associates Admin Plan 6/1/2026 Unlimited copies may be made for internal use
Appendix-3
HOTMA 102/104 Policies Not Yet Implemented
Chapter 00
No HOTMA 102/104 policies apply.

Chapter 1
No HOTMA 102/104 policies apply.

Chapter 2
No HOTMA 102/104 policies apply.

Chapter 3
Model policy section 3-II.D. FAMILY CONSENT TO RELEASE OF INFORMATION is amended to comply with section J.2 of Notice PIH 2023-27, Revocation of Consent Model Policy section III.C. RESTRICTION ON ASSISTANCE BASED ON ASSETS is added to comply with section A.1 of Notice PIH 2023-27, Asset Limitation HOTMA 102/104 policies related to the definition of family, foster children, and foster adults are applicable no later than July 1, 2025.

Chapter 4
No HOTMA 102/104 policies apply.

Chapter 5
No HOTMA 102/104 policies apply.

Chapter 6
Prior to the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 6.A (as updated for Notice PIH 2024-38).

Upon the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 6.B.

Chapter 7
Prior to the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 7.A (as updated for Notice PIH 2024-38).

Upon the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 7.B.

Exhibit 2
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© Copyright 2025 Nan McKay & Associates Admin Plan 6/1/2026 Unlimited copies may be made for internal use
Appendix-4
Chapter 8
No HOTMA 102/104 policies apply. However, prior to the NSPIRE compliance date, the PHA will follow policies in Chapter 8.A. Upon the NSPIRE compliance date, the PHA will follow policies in Chapter 8.B.

Chapter 9
No HOTMA 102/104 policies apply.

Chapter 10
No HOTMA 102/104 policies apply.

Chapter 11
Prior to the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 11.A.

Upon the PHA’s HOTMA compliance date, the PHA will follow policies in Chapter 11.B.

Chapter 12
Model policy section 12-I.D. MANDATORY TERMINATION OF ASSISTANCE is amended to comply with section J.2 of Notice PIH 2023-27, Revocation of Consent Model Policy section 12-I.E. MANDATORY POLICIES AND OTHER AUTHORIZED TERMINATIONS is added to comply with section A.1 of Notice PIH 2023-27, Asset Limitation
Chapter 13
No HOTMA 102/104 policies apply.

Chapter 14
HOTMA 102/104 policies related to de minimis errors are applicable no later than July 1, 2025.

Chapter 15
No HOTMA 102/104 policies apply.

Chapter 16
No HOTMA 102/104 policies apply.

Chapter 17
No HOTMA 102/104 policies apply.

Exhibit 2
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© Copyright 2025 Nan McKay & Associates Admin Plan 6/1/2026 Unlimited copies may be made for internal use
Appendix-5
Chapter 18
No HOTMA 102/104 policies apply.

Glossary
The following definitions are applicable no later than July 1, 2025:
• Annual income (revised)
• Day laborer
• De minimis error
• Earned income
• Family (revised)
• Foster child
• Foster adult
• Independent contractor
• Inflationary index
• Net family assets (revised)
• Real property
• Seasonal worker
• Unearned income
Exhibit 2
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Glendale Housing Authority
Section 8 Resident Advisory Board (RAB)
Meeting Minutes
Wednesday, February 25, 2026, 11:00AM
141 N. Glendale Ave., Glendale, CA 91206

1. Roll Call
The meeting started at 11:05 a.m.

RAB Members Present:

Karine Airapetian, Lilik Akhverdyan, Laura Avetisyan, Lida Babaian, Annette Cluff, Joseph Corday, Dina Cea, Susanna Gamanyan, Sarah Grigoryan, Vardkez Haghverdi, Robert Harutyunyan, Patricia Joyce, Ashot Kazanian, Rafik Khashadoorian, Amalia Minasyan City of Glendale Staff:

Arthur Bolbolian- Principal Housing Supervisor, Edgar Akopyan-Senior Housing Analyst, Irina Kassabian-Housing Supervisor, Hermineh Davidian-Senior Housing Advisor, Julieta Sayadyan- Senior Housing Advisor.

2. Introductions and Presentations
Staff introduced themselves and welcomed the RAB members.

3. Consent Items
The minutes of the February 20, 2025 Resident Advisory Board Meeting were reviewed and approved by consensus.

4. Resident Advisory Board Orientation
Staff provided an overview of the Resident Advisory Board (RAB), including its role in reviewing the PHA Annual Plan, Five-Year Plan, and Administrative Plan.

Staff explained that the RAB serves as a partnership between Section 8 participants and the Housing Authority and provides an opportunity for residents to offer input on program policies, identify community needs, and recommend improvements.

Staff also outlined the Housing Authority’s responsibilities, including providing advance notice of meetings, allowing sufficient time for review, providing relevant materials, and considering RAB feedback during the planning process.

5. Reports to Obtain Feedback from the Resident Advisory Board a. FY 2026–2027 Draft Annual Plan
Staff presented key components of the Annual Plan, including financial resources and the status of the Emergency Housing Voucher (EHV) program, which is expected to sunset earlier than anticipated due to federal funding constraints.

Exhibit 3
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2 Staff also provided a progress report on program goals, including leasing optimization, SEMAP performance, policy updates, revised payment standards, inspections, internal controls, training, and outreach.
b. 2026 Administrative Plan
Staff provided an overview of the Administrative Plan update, noting that it reflects recent HUD regulatory changes and includes no significant discretionary policy changes.

6. Resident Advisory Board Feedback
Staff received comments and questions from RAB members regarding program funding, rent determinations, rent increases, waiting list status, EHV program updates, and access to affordable housing.

Members expressed the need for continued focus on affordable housing in Glendale.

7. Adjournment
The meeting was adjourned at 11:43 AM.

Exhibit 3
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form HUD-50077-ST-HCV-HP (09/30/2027)Page 1 of 3Previous version is obsolete Status: Created
Certifications of Compliance with
PHA Plan and Related Regulations
(Standard, Troubled, HCV-Only, and
High Performer PHAs)
U.S. Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 09/30/2027
PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations including PHA Plan Elements that Have Changed
Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairperson or other authorized PHA official if there is no Board of Commissioners, I approve the submission of the 5-Year and/or X Annual PHA Plan, hereinafter referred to as "the Plan," of which this document is a part, and make the following certification and agreements with the Department of Housing and Urban Development (HUD) for the PHA fiscal year beginning 07/2026, in which the PHA receives assistance under 42 U.S.C. 1437f and/or 1437g in connection with the submission of the Plan and implementation thereof:

1. The Plan is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such strategy) for the jurisdiction in which the PHA is located (24 CFR § 91.2).

2. The Plan contains a signed certification by the appropriate State or local official (form HUD-50077-SL) that the Plan is consistent with the applicable Consolidated Plan, which includes any applicable fair housing goals or strategies, for the PHA's jurisdiction and a description of the way the PHA Plan is consistent with the applicable Consolidated Plan (24 CFR §§ 91.2, 91.225, 91.325, and 91.425).

3. The PHA has established a Resident Advisory Board or Boards, the membership of which represents the residents assisted by the PHA, consulted with this Resident Advisory Board or Boards in developing the Plan, including any changes or revisions to the policies and programs identified in the Plan before they were implemented, and considered the recommendations of the Resident Advisory Board (24 CFR 903.13). The PHA has included in the Plan submission a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the way the Plan addresses these recommendations.

4. The PHA provides assurance as part of this certification that:
i. The Resident Advisory Board had an opportunity to review and comment on the changes to the policies and programs before implementation by the PHA;
ii. The changes were duly approved by the PHA Board of Directors (or similar governing body); and iii. The revised policies and programs are available for review and inspection, at the principal office of the PHA during normal business hours. Where possible, PHAs should make documents available electronically, for public inspection upon request.

5. The PHA made the proposed Plan and all information relevant to the public hearing available for public inspection at least 45 days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the Plan and invited public comment. The PHA ensured all notices and meetings provided effective communication with persons with disabilities and further provided meaningful language access for persons with Limited English Proficiency (LEP).

6. The PHA certifies that it will carry out the public housing program of the agency in conformity with Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d-2000d-4), the Fair Housing Act (42 U.S.C. 3601-19), Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794), Title II of the Americans with Disabilities Act (42 U.S.C. 12101 et seq.), the Violence Against Women Act (34 U.S.C. § 12291 et seq.), and other applicable civil rights requirements, and that it will affirmatively further fair housing in the administration of all HUD programs. In addition, if it administers a Housing Choice V oucher Program, the PHA certifies that it will administer the program in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing Act, Section 504 of the Rehabilitation Act of 1973, Title II of the Americans with Disabilities Act, the Violence Against Women Act, and other applicable civil rights requirements, and that it will affirmatively further fair housing in the administration of all HUD programs.

7. The PHA will affirmatively further fair housing, in compliance with the Fair Housing Act, 24 CFR § 5.150 et seq., 24 CFR § 903.7(o), and 24 CFR § 903.15, which means that it will take meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living Exhibit 4
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form HUD-50077-ST-HCV-HP (09/30/2027)Page 2 of 3Previous version is obsolete patterns, transforming racially or ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws (24 CFR § 5.151). Pursuant to 24 CFR § 903.15(c)(2), a PHA's policies should be designed to reduce the concentration of tenants and other assisted persons by race, national origin, and disability. PHA policies should include affirmative steps stated in 24 CFR § 903.15(c)(2)(i) and 24 CFR § 903.15(c)(2)(ii). Furthermore, under 24 CFR § 903.7(o), a PHA must submit a civil rights certification with its Annual and 5-year PHA Plans, except for qualified PHAs who submit the Form HUD- 50077-CR as a standalone document. The PHA certifies that it will take no action that is materially inconsistent with its obligation to affirmatively further fair housing.

8. For PHA Plans that include a policy for site-based waiting lists:
• The PHA regularly submits required data to HUD's 50058 PIC/IMS Module and/or its successor system:
the Housing Information Portal (HIP) in an accurate, complete and timely manner (as specified in PIH Notice 2011-65);
•
The system of site-based waiting lists provides for full disclosure to each applicant in the selection of the development in which to reside, including basic information about available sites; and an estimate of the period of time the applicant would likely have to wait to be admitted to units of different sizes and types at each site;
•
Adoption of a site-based waiting list would not violate any court order or settlement agreement or be inconsistent with a pending complaint brought by HUD;
• The PHA shall take reasonable measures to assure that such a waiting list is consistent with affirmatively furthering fair housing; and
• The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights laws and certifications, as specified in 24 CFR 903.7(o)(1).

9. The PHA will comply with the prohibitions against discrimination based on age pursuant to the Age Discrimination Act of 1975.

10. In accordance with the Fair Housing Act, the PHA will not base a determination of eligibility for housing on marital status and will not otherwise discriminate because of sex.

11. The PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, 'Policies and Procedures for the Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped' for people with physical disabilities.

12. The PHA will comply with the requirements of Section 3 of the Housing and Urban Development Act of 1968, Employment Opportunities for Low-or Very-Low Income Persons, and with its implementing regulation at 24 CFR Part 135.

13. The PHA will comply with the acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 and implement the regulations at 49 CFR Part 24 as applicable.

14. The PHA will take appropriate affirmative action to award contracts to minority and women's business enterprises under 24 CFR 5.105(a).

15. The PHA will provide the responsible entity or HUD any documentation that the responsible entity or HUD needs to carry out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58 or Part 50, respectively.

16. With respect to public housing the PHA will comply with Davis-Bacon or HUD determined wage rate requirements under Section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act.

17. The PHA will keep records in accordance with 2 CFR 200.302 and facilitate an effective audit to determine compliance with program requirements.

18. The PHA will comply with the Lead-Based Paint Poisoning Prevention Act, the Residential Lead-Based Paint Hazard Reduction Act of 1992, and 24 CFR Part 35.

19. The PHA will comply with the policies, guidelines, and requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Financial Assistance, including but not limited to submitting the assurances required under 24 CFR §§ 1.5, 3.115, 8.50, and 107.25 by submitting an SF- 424, including the required assurances in SF-424B or D, as applicable.

20. The PHA will undertake only activities and programs covered by the Plan in a manner consistent with its Plan and will utilize covered grant funds only for activities that are approvable under the regulations and included in its Plan.

21. All attachments to the Plan have been and will continue to always be available at all locations that the PHA Plan is available for public inspection. All required supporting documents have been made available for public inspection along with the Plan and additional requirements at the primary business office of the PHA and at all other times and locations identified by the PHA in its PHA Plan and will continue to be made available at least at the primary Exhibit 4
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form HUD-50077-ST-HCV-HP (09/30/2027)Page 3 of 3Previous version is obsolete business office of the PHA and, where possible, should be made available for public inspection in an electronic format.

22. The PHA certifies that it is following all applicable Federal statutory and regulatory requirements, including the Declaration of Trust(s).

Housing Authority of the City of Glendale CA114
PHA Name PHA Number/HA Code
X Annual PHA Plan for Fiscal Year 2026
5-Year PHA Plan for Fiscal Years 20-20
I/We, the undersigned, certify under penalty of perjury that the information provided above is true and correct. WARNING: Anyone who knowingly submits a false claim or makes a false statement is subject to criminal and/or civil penalties, including confinement for up to 5 years, fines, and civil and administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 3802) Name of Executive Director: Roubik Golanian Name of Board Chairman: Robert Adjinian Signature: Date: Signature: Date:

This information is collected to ensure compliance with PHA Plan, Civil Rights, and related laws and regulations including PHA plan elements that have changed.

Public reporting burden for this information collection is estimated to average 0.16 hours per year per response, including the time for reviewing instructions, searching existing data sources, gathering, and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions to reduce this burden, to the Reports Management Officer, REE, Department of Housing and Urban Development, 451 7th Street, SW, Room 4176, Washington, DC 20410-5000. When providing comments, please refer to OMB Approval No. 2577-0226. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number.

Privacy Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality.

Form identification: CA114-Housing Authority of the City of Glendale form HUD-50077-ST-HCV-HP (Form ID -2189) for CY 2026 printed by Arthur Bolbolian in HUD Secure Systems/Public Housing Portal at 04/22/2026 12:13PM EST
Exhibit 4
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form HUD-50077-SL (09/30/2027)Page 1 of 1Previous version is obsolete Status: Created
Certification by State or Local U. S Department of Housing and Urban Development Official of PHA Plans Consistency Office of Public and Indian Housing with the Consolidated Plan or OMB No. 2577-0226
State Consolidated Plan Expires 09/30/2027
(All PHAs)
Certification by State or Local Official of PHA Plans
Consistency with the Consolidated Plan or State Consolidated Plan I, Michael Fortney , the Acting Assistant Director
Official's Name Official's Title
certify that the 5-Year PHA Plan for fiscal years 2026-2030 and/or Annual PHA Plan for fiscal year 2026 of the CA114 - Housing Authority of the City of Glendale is consistent with the PHA Name
Consolidated Plan or State Consolidated Plan including any applicable fair housing goals or strategies to:

CA114 - Housing Authority of the City of Glendale
Local Jurisdiction Name
pursuant to 24 CFR Part 91 and 24 CFR Part 903.15.

Provide a description of how the PHA Plan's contents are consistent with the Consolidated Plan or State Consolidated Plan.

The PHA Annual Plan aligns with the FY 2025–2030 Community Needs Assessment used in the Consolidated Plan. The target populations identified in the needs assessment are the same populations served by the Agency. Both the PHA Plan and the Consolidated Plan emphasize the need for more affordable housing, additional funding for HCV vouchers, and increased availability of HCV vouchers. They also highlight the most common housing challenges, including housing cost burden and overcrowded housing. The Annual Plan complies with the 2025–2030 Analysis of Impediments to Fair Housing Choice.

I/We, the undersigned, certify under penalty of perjury that the information provided above is true and correct. WARNING: Anyone who knowingly submits a false claim or makes a false statement is subject to criminal and/or civil penalties, including confinement for up to 5 years, fines, and civil and administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 3802).

Name of Authorized Official: Michael Fortney Title: Acting Assistant Director Signature: Date:

This information is collected to ensure consistency with the consolidated plan or state consolidated plan.

Form identification: CA114 - Housing Authority of the City of Glendale form HUD-50077-SL (Form ID - 6398) printed by Arthur Bolbolian in HUD Secure Systems/Public Housing Portal at 03/31/2026 07:41PM EST
Exhibit 5
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There has been a submission of the form Share Your Feedback through your Engage Glendale website.

Name
Mabel Wlodyka
Email
[email protected]
Provide your comment.

Putting out EHV recipients would be devastating to tenants and landlords. Please save these families from falling back into emergency situations again From: Engage Glendale
To: Akopyan, Edgar
Subject: Share Your Feedback Form Submission
Date: Saturday, April 11, 2026 8:38:06 PM
Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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Exhibit 6
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From: [email protected]
To: City Council; Akopyan, Edgar
Cc: DL Housing; Golanian, Roubik; DL City Clerk
Subject: Urgent Request for EHV Transition Protections, Hardship Review, and Written Plan for Glendale EHV Households Date: Friday, April 17, 2026 8:05:39 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Mayor, Members of the City Council, Mr. Akopyan, Mr.

Golanian, and Glendale Housing Authority staff,
My name is Daniel E. Warren, and I am writing because I am a current Glendale resident, a student at Glendale Community College, and a person at immediate risk of becoming homeless in roughly three months unless Glendale acts quickly and decisively.

I am asking for four specific actions:

1. Adopt HUD-authorized EHV-to-HCV transition preferences immediately.

2. Create a local no-new-homelessness bridge plan with
identified funding and partners.

3. Provide me with an individualized hardship review and a designated point of contact.

4. Publish Glendale’s concrete plan for all current EHV households, especially medically vulnerable residents, students, and households with pets.

Glendale’s own published Housing Authority materials state that the EHV program was originally projected through about 2030, that Glendale received 225 EHVs, that about 188
households are currently being served, and that updated Exhibit 6
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projections now point to depletion by fiscal year 2026. HUD’s PIH Notice 2025-19 separately tells PHAs to prepare for the wind-down of EHV funding and strongly encourages them to transition EHV families into the regular HCV program using waiting-list preferences where necessary so families do not lose assistance and face homelessness. HUD also states that PHAs with a closed HCV waiting list may open it only for families who qualify for an EHV preference, and that PHAs may adopt
multiple preferences to prioritize the most vulnerable
households first.

I was born in Glendale at Glendale Adventist Hospital, and I came back here because I love this city and wanted to rebuild my life in my hometown. I am currently pursuing two majors at Glendale Community College, Business & Economics and
Theatre Arts/Acting, and I am also leaning toward
Literature/Arts. I have a 4.0 GPA and I am very close to finishing. In the last year, I have published four books, and I plan to publish many more. My work focuses on social
inclusivity, diversity, education, and standing up for what is right. I am also a Christian and an ordained minister, although I am not currently serving at a church because school and medical issues have taken so much of my time.

The reason I was able to recover and stay in school at all is because I eventually received an Emergency Housing Voucher after a long wait of roughly seven months to nearly a year. I had come out of a relationship in which the other person went through serious mental-health instability that caused an abrupt personality change and abuse, and helping them get help upended my life financially and personally almost overnight.

When I was approved for housing assistance, I was told during the orientation/sign-up process by a staff member named Sharon, in front of multiple participants, that if we followed the Exhibit 6
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rules, reported what we needed to report, and stayed
compliant, we would be okay long-term. Later, when concerns about funding first surfaced, I was told there was at least a chance this would last until 2030. I built my life around that understanding. I came back to Glendale, enrolled in school, arranged my life around living near campus, and rebuilt based on the belief that if I did everything right, I would not suddenly be pushed off a cliff.

I have done everything I reasonably can to be worth helping. I live about two blocks from school so I can keep up with classes and medical appointments. I have maintained a 4.0 GPA
through severe instability and while undergoing more than 10 surgeries, with more still scheduled, including surgery related to breathing problems while living here and another surgery that I expect to need soon. Losing my housing during this period would mean trying to undergo treatment and recovery without stable shelter, which would severely jeopardize my health and make continued school and medical care extremely difficult. I have a dog who depends on me, and my dog also needs urgent surgery that I have been trying to save for. On top of that, after 18 years of driving without an accident, I switched my insurance down to liability only to save money, and within about a week another driver cut in front of me and braked suddenly. My car is now badly damaged. If I lose this housing, I would lose my housing stability, my schooling, my medical stability, my dog, and the foundation I have spent the last several years trying to rebuild.

This request is also about fairness, good faith, and cumulative hardship. During my time here, I have also dealt with account fraud, serious health crises, my stepfather’s death and funeral shortly after I moved back, and my sister nearly dying of sepsis last year. My stepfather died from COPD linked to his 9/11 Exhibit 6
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Ground Zero recovery work searching for survivors in the rubble. I have kept moving forward anyway. I have also kept a completely clean record. I have had police encounters in Glendale tied to mistaken reports and a medical episode, and I was later apologized to by leadership. I have not tried to turn every wrong into a fight or a lawsuit. I have tried to handle everything in good faith. What I am asking for now is the same good faith from Glendale.

Glendale has options if it chooses to use them. HUD’s PIH Notice 2025-19 gives PHAs a lawful path to adopt EHV
preferences, open a closed waiting list only for families qualifying for that preference, and prioritize the most vulnerable households first. Even Glendale’s own Housing Authority materials recognize that this issue requires active planning, because current conditions put EHV households at risk as funding runs out.

Glendale also has the capacity to coordinate a serious response.

The city’s FY 2025-26 General Fund Budget is $352.5 million.

Official city materials also show Glendale making substantial commitments to major projects, including the Central Park Block project, for which the city approved a $10 million General Fund allocation and whose latest cost estimate is $15–16 million, as well as Glendale Water & Power’s approximately $10 million fiber optic broadband project. I understand that not every dollar in Glendale’s system is interchangeable, and I am not asking Glendale to break funding rules. I am asking Glendale to treat preventing avoidable homelessness as a priority worthy of emergency-level coordination, creativity, and follow-through.

Housing stability has allowed me to become productive and move toward self-sufficiency. While living here, I have stayed in Exhibit 6
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school, maintained a 4.0 GPA, published books, and continued meaningful academic and creative work. I mention that not to ask for special treatment, but to show that this housing has done exactly what stable housing is supposed to do: it has allowed me to recover, contribute, and build toward standing fully on my own. Losing that stability now would be
devastating and would interrupt years of work, education, and recovery at the exact moment I am close to finishing what I started.

My requests are straightforward:

1. Adopt EHV-to-HCV transition preferences immediately under HUD guidance, including opening the waiting list only for current EHV households if needed and using priority tiers for the most vulnerable households.

2. Create an immediate local no-new-homelessness bridge plan for current EHV households, identify the available funding and partner channels Glendale can lawfully use, and provide a written timeline for implementation.

3. Provide me with an individualized hardship review right now and designate a point of contact for my case within the next seven days, given my medical history, my status as a student near graduation, my upcoming surgical needs, and my
imminent housing deadline.

4. Publish Glendale’s plan for all current EHV households and confirm what protections, transition options, and case- management supports will be available for medically vulnerable residents, students, and pet owners facing displacement.

I am not writing this as a threat. I am writing because there is still time to prevent something devastating and unnecessary. I Exhibit 6
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care deeply about telling the truth, and I want the truth about my hometown to be that Glendale stepped up when people
needed help most.

Please confirm receipt of this email, identify the person responsible for my case, and provide a written response outlining Glendale’s immediate next steps.

Respectfully,
Daniel E. Warren

661-219-5778
[email protected]
Exhibit 6
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Exhibit 6
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Public comment on the draft FY 2026–2027 Administrative Plan Submitted by: Ani Khash
Date: April 29th, 2026
To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])
CC: City Clerk ([email protected]); City Council ([email protected]) Re: Method of correction of material error on adopted LACAHSA resolution of appropriation

This comment is submitted during the noticed public comment period for the Glendale Housing Authority FY 2026–2027 PHA Annual Plan and Administrative Plan, closing May 4, 2026, with a public hearing on May 5, 2026. I request that this comment and any attachments be included in the formal record for the plan adoption. Please confirm receipt of this submission by reply email.

Statement of facts
At the December 16, 2025 joint City Council and Housing Authority meeting, the City adopted the FY 2025–26 LACAHSA Measure A budget via a resolution of appropriation. The resolution erroneously transposed the "Salary" and "Direct Assistance" figures, causing the adopted document to show approximately 65% of program funds allocated to city salaries rather than the actual approximately 10%.

At the April 28, 2026 joint meeting, Housing Division staff acknowledged the transposition error and stated it had been corrected. The erroneous resolution was part of the public record for approximately 133 days (December 16, 2025 to April 28, 2026).

The Glendale City Charter, Article VI, establishes procedures for the adoption and amendment of ordinances and resolutions. Section 8 provides that no ordinance shall be amended except by reenactment at length. The Charter does not appear to specify a procedure for correcting errors on adopted resolutions. The method by which such an error is corrected affects the legal status of the corrected document and any submissions derived from it, including the City's budget submission to LACAHSA.

The LACAHSA Measure A funds addressed in this comment are identified in the April 28, 2026 staff report (Report No. 26-89993) as part of the same $4.1 million EHV bridge package that includes $3,700,000 in federal HOME funds. The City's handling of the Measure A resolution of appropriation — including the 133-day period during which an erroneous version was the document of record, and the absence of a documented correction procedure — is relevant to the City's demonstrated capacity to administer the federal HOME component of the same bridge proposal.

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Exhibit 6
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Questions

1. What is the resolution number adopted on December 16, 2025 that contained the transposition error?

2. During the April 28, 2026 meeting, staff reported the error had been corrected. On what date was the error first identified, and by whom (name and title)?

3. Did the City Council take a subsequent vote or issue a new resolution to ratify the correction? If so, provide the date and resolution number. Article VI, section 8 of the Charter requires ordinances to be amended by reenactment at length. The Charter does not appear to address correction of adopted resolutions. Please explain the procedural basis for the correction.

4. If the correction was processed administratively as a clerical or scrivener's error, cite the specific authority under the City Charter or Municipal Code permitting administrative correction of adopted resolutions. Identify the official who authorized the correction and the date.

5. Did Glendale resubmit the corrected resolution or amended Measure A budget to LACAHSA? If so, on what date? Provide evidence of LACAHSA notification, such as correspondence, email, or LACAHSA meeting minutes reflecting receipt of the corrected submission. Under LACAHSA's Transitional Program Guidelines, amended budgets must be submitted to LACAHSA. If no resubmission has occurred, please state that.

6. The erroneous resolution was adopted December 16, 2025 and the error was publicly acknowledged April 28, 2026 — approximately 133 days. Was the erroneous version posted on the City's website or otherwise publicly available during that period? On what date was it replaced with the corrected version?

7. Where is the corrected document currently available on the public record? Please provide the URL or location.

8. Please provide a copy of the corrected resolution of appropriation for the FY 2025–26 LACAHSA Measure A budget, as well as a copy of the original (erroneous) version as adopted on December 16, 2025, for comparison.

I request that these questions be r
eflected in the public hearing record for the May 5, 2026 adoption. I reserve all rights under 24 CFR 903.23(b), 24 CFR 91.105, and the Ralph M. Brown Act.

Thank you and regards,
Ani Khash

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Exhibit 6
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Exhibit 6
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1 Public comment on the draft FY 2026–2027 Administrative Plan Submitted by: Ani Khash
Date: May 1, 2026
To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])

Re: Written comments submitted without written response as required by the Citizen Participation Plan

Statement of facts

Between February 18 and April 27, 2026, I submitted seventy-three (73) written questions to City staff and Council members concerning the EHV transition strategy, federal funds, LACAHSA/Measure A fund allocations, the RPHP expenditure timeline, the Gateways Hospital contract funding source, the HCV shortfall methodology, and related matters. These were submitted via email and public comment to the City Council and Housing Authority.

The Citizen Participation Plan (p. 16, section E.1) states: "A written response by letter or e-mail will be made to all written and e-mail comments within ten working days, acknowledging the written response was received and identifying a plan of action, if necessary."
As of this date, the substantial majority of these questions have not received any written response. The one question that was addressed — a 65%/10% salary allocation discrepancy on an adopted resolution — was addressed orally at the April 28, 2026 meeting and resulted in staff acknowledging a transposition error on an adopted resolution.

The CPP further requires (p. 17): "A record will be maintained of all complaints received that will include the nature of the complaint, City investigation of facts and evidences, referrals made, and the final disposition."

Questions

Exhibit 6
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2 1. How many of the seventy-three written questions submitted between February 18 and April 27, 2026 received a written acknowledgment within the 10 working days prescribed by the CPP?

2. How many received a complete written response within 10 working days?

3. The CPP directs written comments to the Community Services Manager at the CDBG Section (currently Maggie Kavarian, [email protected]). Were any of these questions routed to or received by the CDBG Section?

4. Does the City maintain a log or tracking system for written citizen comments and complaints as required by the CPP (p. 17)?

5. A chronological index of the seventy-three questions is attached. Will the City accept this index as a formal record submission for purposes of the CPP complaint and tracking requirements?

I request that these questions be reflected in the public hearing record for the May 5, 2026 adoption. I reserve all rights under 24 CFR 903.23(b), 24 CFR 91.105, 24 CFR

91.505, and the Ralph M. Brown Act.

Ani Khash
Glendale, California

Exhibit 6
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1 Chronological Record of Questions
Submitted to the City of Glendale Regarding EHV, HCV, funding February 18 – April 27, 2026

This comment is submitted during the noticed public comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan, closing May 4, 2026. I request that this comment and any attachments be included in the formal record for the plan adoption on May 5, 2026.

KEY
Yellow highlight = Answered or substantively answered by email Light highlight = Partially answered by email and/or addressed in April 28 staff report No highlight = Not answered by any source
Note: The April 28 staff report (Report 26-89993) was not a response to this correspondence. Where it contains overlapping information, that is noted, but it does not constitute a written response to questions submitted. The entire LACAHSA/RPHP thread of funding questions for allocations etc. (~30 questions) is absent from the staff report.

The 73 questions cluster into three categories: (1) federal pathway status and HUD documentation; (2) LACAHSA Measure A funding accounting and program structure; (3) process and transparency. The questions were submitted sequentially and refined based on responses received. Each cluster reflects an attempt to reconcile what the public record shows with what staff has communicated. To look for specific subjects, see here:

1. Federal pathway (PIH 2025-19, TPVs, PIH 2025-13, written HUD documentation): Q2, Q6–Q9, Q31, Q65–Q68

2. LACAHSA Measure A funding accounting and program structure (the $5.1M, the $1.4M, the $700K gap, GRASP , fund strings, RFP applications, reporting compliance, supplanting): Q10, Q14, Q21–Q29, Q33–Q39, Q40–Q53, Q56–Q61, Q69–Q71, Q73

3. Process and transparency (family communications, March 2 meeting, staff report timing, draft PHA Plan, Housing Authority meeting cadence): Q1, Q3–Q5, Q11–Q13, Q15–Q20, Q30, Q32, Q54–Q55, Q72 February 18, 2026 — 10:01 AM - Initial status check on federal pathway and family communications Q1–Q5
Email to Domenica Megerdichian, cc Arsine Isayan
Q1. [UNANSWERED] What developments have occurred since our February 10th conversation, including any advocacy efforts and internal updates?
Q2. [UNANSWERED] Whether the city has received HUD guidance on new funding opportunities, and whether there is a more concrete plan to adopt the HUD PIH 2025-19 EHV-to-HCV transition preference and/or submit the streamlined waiver to place current EHV holders on the Section 8 waitlist? Q3. [UNANSWERED] The status of the gap funding and resource efforts you mentioned during our side conversation?
Q4. [UNANSWERED] What communications, if any, have gone out to current Glendale EHV holders about the program’s end and their options?
Q5. [UNANSWERED] A realistic timeline for decisions, given that by March we are now approximately three-four months out from ~200 families losing their vouchers? February 18, 2026 — 2:02 PM - Federal mechanisms and gap funding (PIH 2025-19, TPVs, Measure A, Gateways) Q6–Q10
Exhibit 6
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2 Fourth email to Domenica Megerdichian, cc Arsine Isayan Q6. [UNANSWERED] What is going on with HUD guidance on the new funding, how it impacts Glendale here, state advocacy efforts, funding measures, and next steps? Q7. [UNANSWERED] Has Glendale adopted the EHV-to-HCV transition preference under HUD Notice PIH 2025-19?
Q8. [PARTIAL] Has the city pursued Tenant Protection Vouchers, which Congress funded in the FY26 spending bill specifically for EHV transitions? If not, and if it is not using PIH 2025-19 as a mechanism, what is the plan?
April 28 staff report: Confirms staff is pursuing TPVs as “the most promising federal replacement option” but no application has been filed. States staff does not yet know if the Housing Authority will receive any, how many, or when.

Q9. [UNANSWERED] Have EHV holders been notified about the funding timeline since January’s initial letter? Q10. [PARTIAL] What gap funding is being explored? What is going on with the Measure A funds and the Gateways pilot for some households, likely the most vulnerable 65+? What basis is being used to determine who is vulnerable and how?
Email response: April 14: “We do not have $5M available for EHVs. We have approximately $1.4M that can be used specifically for prevention. There are restrictions associated with Measure A funding, so the full allocation cannot be applied toward EHVs.” April 28 staff report: Identifies $4.1M in bridge funding ($3.7M HOME TBRA + $434K Homeless Services). Does not address RPHP allocation. Introduces four-tier vulnerability framework.

April 13, 2026 — 8:00 AM - Following up on March 3 verbal discussion (Admin Plan, PHA roundtable, $5M LACAHSA, Gateways, HUD confirmation, waitlist contradiction) Q11–Q17 Email to Arsine Isayan and Domenica Megerdichian
Q11. [ANSWERED] On our March 3rd call, Arsine, you mentioned that Edgar was working on changes to the Administrative Plan to include EHV transition language. I went through the draft and couldn’t find anything. Is it in there and I’m missing it, or is that still being worked on? Email response: April 14 (1:54 PM): “Should Council decide to include the EHV transition, the Administrative Plan will be updated accordingly. This determination will be made during the presentation when the report is brought before Council.” Q12. [PARTIAL] In your email right after our call on March 3rd, you mentioned a report to Council was being prepared for that week. Did it get rescheduled?
Email response: April 14 (11:53 AM): “We are finalizing a report to City Council/Housing Authority… we expect that item in early May.”
April 28 staff report: Answered by existence of April 28 staff report (Report 26-89993).

Q13. [PARTIAL] Did the countywide PHA roundtable happen? What came out of it? Email response: April 14 (1:54 PM): “She did attend the PHA roundtable, and at this time, the county cannot guarantee additional funding from LACAHSA.” Outcome notes not provided.

Q14. [PARTIAL] Has the meeting with LACAHSA on bridge funding happened? What came out of it? How much of the $5M is being directed toward the 188 EHV families? Email response: April 14 (1:54 PM): “We do not have $5M available for EHVs. We have approximately $1.4M that can be used specifically for prevention.” Whether the LACAHSA meeting occurred and amount directed to 188 households not answered.

April 28 staff report: Identifies different $4.1M pool (HOME + Homeless Services). Does not address LACAHSA bridge meeting or RPHP allocation.

Q15. [PARTIAL] Has the Gateways contract been finalized? Has the coordinated EHV client eligibility meeting kicked off?
Exhibit 6
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3 Email response: April 14 (1:54 PM): “Gateways is already providing services; anyone who is interested can get in touch with their housing advisor for a referral.” Whether any of the 188 EHV households are receiving services, and whether the coordinated meeting occurred, not answered.

Q16. [PARTIAL] Has HUD’s written confirmation of the funding extension come through? Have notification letters gone out to the 188 families?
Email response: April 14 (11:53 AM): “We have verbally communicated the extension in funding/programming to December 2026 and are awaiting the confirmation from HUD in writing.” Letters not yet sent.

April 28 staff report: Confirms still no written confirmation. States HUD’s estimate “could potentially” carry programs through CY 2026 and is “not guaranteed.”
Q17. [ANSWERED] How does Arsine’s “exiting these households is not an option” reconcile with the draft PHA Plan language stating the city “does not recommend” placing EHV families on the waitlist? Email response: April 14 (1:54 PM): “Staff did not say that existing families is not an option (we doesn’t make that call); we did say that we are doing everything we can to identify alternatives that would prevent families from exiting to the streets.” [Walk-back of March 3 statement.]
April 14, 2026 — 12:05 PM - March 2 Barger meeting transparency and staff report timing Q18–Q20 Reply to Domenica Megerdichian
Q18. [PARTIAL] [PRODUCIBLE DOCUMENT] Were there minutes taken at the March 2 joint meeting with Supervisor Barger? If not, why not?
Email response: April 14 (1:54 PM): “Our Department is tasked with drafting the minutes from joint meetings, and that’s underway.” Minutes not produced as of April 27.

Q19. [ANSWERED] Why was the March 2 meeting not broadcast or archived? Email response: April 14 (1:54 PM): “We do not usually broadcast joint meetings; both following regular past practices.” Q20. [PARTIAL] Will the staff report be available before May 4 so the public can review it and submit informed comments before the comment window closes?
April 28 staff report: Staff report posted April 24. Six days before the May 4 deadline, four days after the April 20 escalation containing 18 questions it does not address.

April 14, 2026 — 2:15 PM - LACAHSA funding accounting (the $700K gap, prevention commitments, Gateways funding source) Q21–Q24
Clarifying questions in reply to Domenica Megerdichian
Q21. [UNANSWERED] Does that mean the public will be commenting on a version of the Administrative Plan that does not yet include EHV transition language? Will the staff report be available for public review before the May 4 comment deadline?
Q22. [UNANSWERED] Is the difference between $2,105,698 RPHP allocation and $1.4M prevention figure the mandatory legal services and renter education minimums under LACAHSA rules? Q23. [UNANSWERED] The Council approved the LACAHSA budget on December 16. Has any of the $1.4M in prevention funding been committed to specific programs, providers, or households? When is that expected to come back to Council?
Q24. [UNANSWERED] Is the Gateways contract funded out of the $1.4M prevention allocation, or out of the separate $434,979 in County Measure A Local Solutions funds from the December 30 announcement? April 15, 2026 — 1:45 PM - LACAHSA RPHP allocation accounting, draft PHA Plan inconsistencies, December 16 commitments not fulfilled Q25–Q35 Exhibit 6
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4 Email to full City Council, City Manager Golanian, Edgar Akopyan, Arthur Bolbolian, Arsine Isayan, Domenica Megerdichian
Q25. [UNANSWERED] Where is the difference between $2,105,698 and $1.4M, and what has it been allocated to?
Q26. [UNANSWERED] Is any of the mandatory legal services portion ($421,140) being directed toward legal representation for EHV families who may face displacement? Q27. [UNANSWERED] Why has the $602,089 in PPO Flex funding not been mentioned in any staff communication as a potential resource for EHV families, given the LACAHSA Expenditure Plan identifies it as eligible for income assistance for extremely low-income households? Q28. [UNANSWERED] What is the GRASP program? Does it involve direct financial assistance to households? How does it relate to the $1.4M figure staff cited? ($879,191 of RPHP labeled “RPHP-GRASP” was appropriated to a Salaries account, not a Direct Assistance account.) Q29. [UNANSWERED] If the Gateways contract is funded from Local Solutions, it should not be counted against RPHP/PPO prevention. If it is being funded from RPHP , by how much does that reduce what is available for the 188 families?
Q30. [PARTIAL] The Draft PHA Annual Plan states placing EHV households on the waitlist “would adversely affect existing applicants” while the same document states “HUD has restricted the GHA from leasing new applicants from the waiting list. As a result, leasing activity has been halted.” How do these two statements reconcile?
April 28 staff report: Explains $700K shortfall prevents absorption and frames waitlist placement as providing no subsidy. Does not directly reconcile the contradictory language in the draft PHA Plan.

Q31. [PARTIAL] Why does the plan contain zero mention of HUD Notice PIH 2025-19, zero mention of Tenant Protection Vouchers, and zero mention of LACAHSA or Measure A funding as a resource for EHV families?
April 28 staff report: Now references PIH 2025-19 (attached as Attachment 4) and discusses TPVs. LACAHSA/RPHP remains absent from the transition framework.

Q32. [PARTIAL] Will the staff report be available before May 4? April 28 staff report: Staff report posted April 24. Six days before May 4.

Q33. [UNANSWERED] The December 16 staff report states “Each proposed action of spending Measure A programmatic funding will be brought before the City Council for approval prior to the expenditure.” No subproject spending approvals have appeared on any agenda since December 16. When are they coming? Q34. [UNANSWERED] The December 16 staff report states a TA spending plan would be presented in Q1.

Q1 ended March 31. No such plan has been presented. LACAHSA ’s Technical Assistance RFP closes April 20 at 5:00 PM. Is the city applying?
Q35. [UNANSWERED] The December 16 staff report states “RPHP and TA funds must be expended within 12 months of the date of obligation.” The clock is running. None have been committed. When will they be? April 16, 2026 — 7:15 PM - October 2025 LACAHSA RFP and April 2026 Technical Assistance RFP — did Glendale apply? Q36–Q39
Reply to full City Council, copying full distribution — re: October 2025 LACAHSA RFP Q36. [UNANSWERED] Did the City of Glendale or the Glendale Housing Authority submit a proposal to the LACAHSA Emergency Rental and Flexible Financial Assistance RFP by the November 19, 2025 deadline? Exhibit 6
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5 Q37. [UNANSWERED] Did city or GHA staff conduct a written evaluation of the RFP’s applicability to the EHV transition situation or to any other housing priority before the November 19 deadline? Q38. [UNANSWERED] Was the City of Glendale or the GHA named as a subcontractor or partner on any proposal submitted by a lead applicant to that RFP?
Q39. [UNANSWERED] Given the Technical Assistance RFP closes April 20 at 5:00 PM, please confirm whether the City is submitting a proposal. If not, please identify the decision-maker and the rationale.

April 17, 2026 - LACAHSA framework interpretation (what the Program Guidelines actually permit) Q40–Q55
Tyler Cash (Office of Supervisor Barger) forwards to Arsine Isayan and Seyron Yegparian — questions originally posed April 12–17
Q40. [UNANSWERED] The Program Guidelines (page 46) describe Temporary Rental Assistance as “step-down assistance to households exiting time-limited or permanent subsidy programs.” Would EHV qualify as a time-limited subsidy program under this provision? Q41. [UNANSWERED] On page 44, there’s an exclusion for households “currently enrolled or exiting a permanent or time limited subsidy program” from Emergency Rental and Flexible Financial Assistance, with an exception for HCV . Does that exclusion apply only while actively enrolled, or does it follow the household permanently after the subsidy has ended?
Q42. [UNANSWERED] On page 36, the Guidelines show minimum spending floors: 20% Legal Services, 40% ERFFA, 12.5% Program Administration, with the remaining portion at the jurisdiction’s discretion. Am I reading that correctly? Can the discretionary portion be directed toward any eligible RPHP use, including TRA? Q43. [UNANSWERED] You mentioned on April 12 that RPHP can be “deployed as step-down assistance for households exiting time-limited subsidy programs like EHVs.” Is that based on this same TRA provision, or a separate basis?
Q44. [UNANSWERED] (a) Are there any restrictions in the Program Guidelines or governing agreement that would prevent PPO Flex from being used for EHV households, whether their subsidy is currently active or has ended? (b) Are there any process prerequisites, such as LACAHSA technical assistance or pre-approval, that a jurisdiction would need to complete before deploying PPO Flex funds for rental assistance? Q45. [UNANSWERED] [PRODUCIBLE DOCUMENT] Is there an operative MOU or funding agreement between LACAHSA and the City of Glendale for FY 2025-26? If publicly posted, please share a link.

Q46. [UNANSWERED] The Expenditure Plan (page 16, footnote 12) references “additional allowances for administrative and direct costs… established and adopted by the Board in LACAHSA ’s Program Guidelines.” Are these the same September 2025 Transitional Program Guidelines, or is there a more recent version? Q47. [UNANSWERED] The Program Guidelines reference “100 percent of ADCs must be passed on to the subrecipient or the entity that is directly carrying out the activity.” If a jurisdiction administers an RPHP program with its own city staff rather than contracting with an outside provider, how does this requirement apply in practice?
Q48. [UNANSWERED] Can RPHP funds be used by a jurisdiction to fund staff positions previously funded from other sources (General Fund, HHAP , HOME, CDBG)? Are there provisions ensuring LACAHSA funds supplement rather than replace existing spending?
Q49. [UNANSWERED] The Program Guidelines and December 16 staff report both state RPHP and TA funds must be expended within 12 months of obligation. When did the 12-month clock start for Glendale’s FY 2025-26 allocation, and what happens to funds that aren’t deployed within that window? Exhibit 6
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6 Q50. [UNANSWERED] Has LACAHSA issued any waivers, extensions, or modifications to the 12-month expenditure requirement for any eligible jurisdiction this fiscal year? Q51. [UNANSWERED] What reporting does LACAHSA require from eligible jurisdictions on RPHP expenditures? Are those reports publicly available?
Q52. [UNANSWERED] What does LACAHSA ’s compliance monitoring process look like in practice? Who is responsible for verifying funds are being spent in accordance with the Guidelines? Q53. [UNANSWERED] [PRODUCIBLE DOCUMENT] The Program Guidelines (pages 63-64) reference biannual reporting: financial reports due November 14 and May 15, programmatic reports due February 14 and July 30. Has Glendale submitted its financial report (due November 14, 2025) and programmatic report (due February 14, 2026)?
Q54. [UNANSWERED] Diana confirmed on April 6 that the March 2 joint meeting with Glendale was not recorded. Has your office received any minutes from that meeting? Q55. [UNANSWERED] At the March 2 meeting, Supervisor Barger pledged county staff collaboration with Glendale on LACAHSA prevention resources for EHV families. Tyler’s April 12 email confirmed “ongoing conversations.” Is there a written record of what was specifically agreed to at that meeting? April 20, 2026 — 9:44 AM- Detailed reconciliation of Glendale's December 17, 2025 RPHP submission, federal pathway status, and supplanting concern Q56–Q73 Escalation to Arsine Isayan, copying Seyron Yegparian, Tyler Cash, Diana, Veronica, Ariana Q56. [UNANSWERED] The RPHP budget allocated $0 to Temporary Rental Assistance. Is this correct? Q57. [UNANSWERED] The RPHP budget allocated $0 to Short-Term Income Support. Is this correct? Q58. [UNANSWERED] The RPHP budget allocated $1,473,988 to Emergency Rental and Flexible Financial Assistance inclusive of Activity Delivery Cost (~70% of total, exceeding the 40% minimum floor by ~$631,709).

Is this correct?
Q59. [UNANSWERED] Is the fund-string allocation breakdown accurate? ($879,191 GRASP and $294,798 Actual Delivery Cost both appropriated to Account 41100 City Salaries; $210,570 Program Administration; $421,140 Legal Services to Local Grants; $300,000 LIFERAP to Direct Assistance. Total $1,174,989 to City Salaries.)
Q60. [UNANSWERED] [PRODUCIBLE DOCUMENT] Please provide the GRASP program: (a) guidelines document; (b) eligibility criteria including whether EHV-enrolled households are eligible; (c) maximum benefit amount and duration per household; (d) application and intake procedure; (e) launch date; (f) total households served as of April 20, 2026; (g) the LACAHSA category that “Income-Support Assistance” is funded under, given Short-Term Income Support was allocated $0; (h) the LACAHSA category that “Special Assistance” is funded under, given no LACAHSA category carries that name.

Q61. [UNANSWERED] Glendale’s December 17, 2025 RPHP submission states the City would file a waiver to the 20% legal services obligation and apply the waived amount to GRASP . Has that waiver been filed? Date and status?
Q62. [UNANSWERED] Page 47 authorizes TRA as “step-down assistance to households exiting time-limited or permanent subsidy programs.” Does the Department treat EHV as a time-limited subsidy program for purposes of this provision, such that the 188 EHV households would be eligible for TRA as they exit EHV in 2026? Q63. [UNANSWERED] Page 47 states households “currently enrolled or exiting a permanent or time limited subsidy program… are not eligible for Emergency Rental and Flexible Financial Assistance,” exception only for Exhibit 6
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7 rental arrears for HCV/PSH households. Are the 188 EHV households eligible for prospective rental assistance funded through the ERFFA allocation?
Q64. [UNANSWERED] If the Department has not yet formally established a position on Questions 62 or 63, please state that. If the position is set out in a staff report, memorandum, written guidance request to LACAHSA, or City Attorney memorandum, please identify the document and its date.

Q65. [ANSWERED] Has Glendale submitted a PIH 2025-19 waiver request to HUD via DocuSign, requesting authority to place EHV families on the HCV waiting list with a local preference? Email response: Confirmed declined in writing on January 28, 2026 (Bolbolian email).

April 28 staff report: Presents the waiver as Option 1 for Council direction. Confirms it has still not been submitted. Status unchanged over 68 days.

Q66. [UNANSWERED] Has Glendale applied for HCV HAP Set-Aside Category 1 shortfall funding under PIH Notice 2025-13, for which Glendale has been eligible since entering HUD-designated shortfall status in December 2024? Is Glendale currently working with HUD’s Shortfall Prevention Team regarding CY 2026 shortfall status?
Q67. [UNANSWERED] Under PIH 2025-13 Category H, HUD awards $1,000 per EHV family successfully transitioned to regular HCV and coded as “EHCV” on line 2n of HUD-50058, with transactions submitted to IMS/PIC by February 28, 2026. Has Glendale successfully transitioned any EHV households to regular HCV and coded them as “EHCV” by that deadline? If yes, how many, when, and HUD’s response? Q68. [PARTIAL] [PRODUCIBLE DOCUMENT] Please provide the written HUD notice, allocation methodology, award letter, or other written document that establishes Glendale’s anticipated federal funding for EHV preservation through December 2026. If no such written document exists, identify the HUD source of the oral or informal communication being relied on, including date and individual.

April 28 staff report: States HUD’s estimate is that funding “could potentially carry programs into approximately Calendar Year 2026” and is “not guaranteed.” Does not identify specific HUD source, date, or individual. Effectively confirms the basis is an informal oral estimate.

Q69. [UNANSWERED] As of April 20, 2026, what portion of the $2,105,698 RPHP allocation has been expended, and in what categories? Include LIFERAP , GRASP , Legal Services, and Program Administration expenditure detail.

Q70. [UNANSWERED] [PRODUCIBLE DOCUMENT] Has Glendale submitted its LACAHSA First Quarter financial report (due November 14, 2025) and Second Quarter report (due February 14, 2026)? Please provide copies.

Q71. [UNANSWERED] Is a budget amendment under preparation to reallocate RPHP funds toward Temporary Rental Assistance, in light of the 2026 EHV funding depletion? Q72. [UNANSWERED] Of six regular Housing Authority meetings posted between February 3 and April 21, only two occurred. For each cancelled or non-occurring meeting: (a) the date, the decision to cancel, the official who made it; (b) whether a special meeting under Government Code 54956 was considered or noticed; (c) the basis on which EHV was not added as an agenda item for the April 21 meeting, given the February 3 Board directive, the April 3 Bolbolian written confirmation that no action had been taken, and the May 4 comment deadline.

Q73. [UNANSWERED] [PRODUCIBLE DOCUMENT] The December 16 LACAHSA RPHP submission appropriated $1,174,989 across two fund strings to Account 41100 (City Salaries). Please identify: (a) each position title charged in whole or part to fund strings CDD01556AG or CDD01557AG for FY 25-26, the percentage of each position’s time allocated to LACAHSA-funded activity, and the basis for that percentage (time studies, direct timekeeping, or cost allocation plan); (b) the funding source for the same position titles in FY 2024-25, before the LACAHSA allocation existed; (c) for Housing Division and Homeless Services positions that received classification changes, reclassifications, or step/range changes between July 1, 2023 and April 1, Exhibit 6
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8 2026 — position title, date of each action, approving authority, and source of General Fund/HCV admin fee/CDBG/HOME/ESG/CoC funding supporting the change in each fiscal year; (d) the pre-merger and post-merger position control roster for the Homeless Services function, with funding source identified for each position in each fiscal year from FY 2020-21 through FY 2025-26; (e) whether any LACAHSA RPHP dollars in the FY 25-26 appropriation are being used to backfill positions or compensation increases previously supported by General Fund, HCV admin fees, or any other funding source.

Exhibit 6
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There has been a submission of the form Share Your Feedback through your Engage Glendale website.

Name
Mabel Wlodyka
Email
[email protected]
Provide your comment.

Exhibit 6
982 of 1125

Exhibit 6
983 of 1125

Exhibit 6
984 of 1125

Exhibit 6
985 of 1125

Exhibit 6
986 of 1125

Exhibit 6
987 of 1125

Exhibit 6
988 of 1125

Exhibit 6
989 of 1125

Mayor, Members of the City Council, Mr. Akopyan, Mr.

I am asking for four specific actions:

1. Adopt HUD-authorized EHV-to-HCV transition preferences immediately.

2. Create a local no-new-homelessness bridge plan with
identified funding and partners.

3. Provide me with an individualized hardship review and a designated point of contact.

4. Publish Glendale’s concrete plan for all current EHV households, especially medically vulnerable residents, students, and households with pets.

Glendale also has the capacity to coordinate a serious response.

The city’s FY 2025-26 General Fund Budget is $352.5 million.

Housing stability has allowed me to become productive and move toward self-sufficiency. While living here, I have stayed in Exhibit 6
993 of 1125

My requests are straightforward:

I am not writing this as a threat. I am writing because there is still time to prevent something devastating and unnecessary. I Exhibit 6
994 of 1125

care deeply about telling the truth, and I want the truth about my hometown to be that Glendale stepped up when people
needed help most.

Please confirm receipt of this email, identify the person responsible for my case, and provide a written response outlining Glendale’s immediate next steps.

Respectfully,
Daniel E. Warren

661-219-5778

[email protected]
Exhibit 6
995 of 1125

Exhibit 6
996 of 1125

Page 1 ends

Exhibit 6
997 of 1125

Questions

1. What is the resolution number adopted on December 16, 2025 that contained the transposition error?

2. During the April 28, 2026 meeting, staff reported the error had been corrected. On what date was the error first identified, and by whom (name and title)?

7. Where is the corrected document currently available on the public record? Please provide the URL or location.

I r
equest that these questions be reflected in the public hearing record for the May 5, 2026 adoption. I reserve all rights under 24 CFR 903.23(b), 24 CFR 91.105, and the Ralph M. Brown Act.

Thank you and regards,
Ani Khash

Page 2 ends

Exhibit 6
998 of 1125

From: Ani <[email protected]>
Sent: Friday, May 1, 2026 10:00 AM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Public comment - on use of federal funds flagged in internal audit(s)? CAUTION:

This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,

Please find attached a public comment submitted during the noticed comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan.

I request that this comment and its attachments be included in the formal record for the plan adoption on May 5, 2026.

Please confirm receipt.

Thank you,
Ani
999 of 1125

Public comment on the draft FY 2026–2027 Administrative Plan Submitted by: Ani Khash Date: May 3, 2026 To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])
CC: City Clerk ([email protected]); City Council ([email protected]) Re: Single Audit findings on the HOME program and relevance to the proposed HOME-funded EHV

bridge

This comment is submitted during the noticed public comment period for the Glendale Housing Authority

2026–2027

PHA

Annual

Plan

and

Administrative

Plan,

closing

May

2026,

with

public

hearing

May

2026.

request

that

this

comment

and

any

attachments

included

the

formal

record

for

the

plan

adoption.

Please

confirm

receipt

this

submission

email.

Statement of facts The City receives federal HOME funds (Assistance Listing 14.239) and is subject to 2 CFR Part 200

Single

Audit

requirements.

The

City's

Single

Audit

reports

are

published

the

Finance

Department

website.

The April 28, 2026 staff report (Report No. 26-89993, p. 12) proposes using $3,700,000 in HOME

funds

for

TBRA.

The

City's

demonstrated

capacity

administer

HOME-funded

activities

compliance

with

federal

requirements

directly

relevant.

Questions 1. For each fiscal year from FY 2019–2020 through the most recently completed audit, identify any

findings

the

HOME

program

(Assistance

Listing

14.239),

including:

(a)

finding

number;

(b)

classification

significant

deficiency

material

weakness;

(c)

brief

description;

and

(d)

whether

corrective

action

plan

was

filed

and

completed.

2. Are there any currently open or unresolved HOME program audit findings? 3. Has the HUD Los Angeles CPD Field Office conducted any monitoring review of Glendale's HOME

HOME-ARP

program

the

last

three

fiscal

years?

4. What is the current staffing level of the Internal Audit Division? Does the proposed FY 2026–2027

budget

maintain,

reduce,

eliminate

positions?

5. Has the Internal Audit Division conducted any audit engagement covering the HOME program,

the

HCV

program,

LACAHSA-funded

activities

since

2019–2020?

Page 1 ends

1000 of 1125

6. What internal controls and compliance monitoring framework does staff propose for the HOME

TBRA

program

ensure

compliance

with

24 CFR

Part

92 and

CPD

Notice

21-10?

I request that these questions be reflected in the public hearing record for the May 5, 2026 adoption.

reserve

all

rights

under

24 CFR

903.23(b),

24 CFR

91.105,

24 CFR

91.505,

and

the

Ralph

Brown

Act.

Ani Khash Glendale, California
The following attached screenshots
from

the

April

2026

staff

report

that

council

voted

pages

3-5:

Page 2 ends

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Page 3 ends

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Page 4 ends

1003 of 1125

Page 5 ends

1004 of 1125

From: Ani <[email protected]>
Sent: Friday, May 1, 2026 9:23 AM
To: Akopyan, Edgar <[email protected]>; City Council <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]> Subject: Public comment on draft admin plan - on bridge funding voted on in April that was already appropriated to Gateways contract in December
CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a public comment submitted during the noticed comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan.

I request that this comment and its attachments be included in the formal record for the plan adoption on May 5, 2026.

1005 of 1125

Please confirm receipt.

Thank you,
Ani
1006 of 1125

Public comment on the draft FY 2026–2027 Administrative Plan Submitted by: Ani Khash
Date: May 1, 2026
To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])

CC: City Clerk ([email protected]); City Council ([email protected]) Re: Potential double-counting of $434,000 in Measure A Local Solutions funds and the Gateways

Hospital

contract

This comment is submitted during the noticed public comment period for the Glendale Housing Authority

2026–2027

PHA

Annual

Plan

and

Administrative

Plan,

closing

May

2026,

with

public

hearing

May

2026.

request

that

this

comment

and

any

attachments

included

the

formal

record

for

the

plan

adoption.

Please

confirm

receipt

this

submission

email.

This public comment has significant relevance to the PHA Annual Plan.

The

April

28,

2026

staff

report

the

city

Glendale

(Report

No.

26-89993)

presents

the

$434,000

Measure

funds

part

the

same

$4.1

million

EHV

bridge

package

that

includes

$3,700,000

federal

HOME

funds.

The

bridge

package

the

Housing

Authority's

stated

alternative

adopting

the

PIH

2025-19

federal

waiver

for

EHV-to-HCV

transition.

The financial viability of that alternative, and therefore the adequacy of the

draft

Administrative

Plan's

approach

the

EHV

population,

depends

whether

the

funding

sources

identified

the

staff

report

are

actually

available,

unobligated,

and

eligible

for

the

proposed

use.

any

portion

the

$434,000

already

committed

existing

contract,

the

bridge

package

smaller

than

represented

Council

and

the

public,

and

the

draft

plan's

omission

EHV

transition

preference

rests

overstated

funding

base.

Statement of facts The December 16, 2025 joint meeting included a resolution appropriating $434,979 in County Measure A Local Solutions funds. The April 28, 2026 staff report (Report No. 26-89993, p. 12) identifies "$434,000 in Homeless Services" as part of the $4.1 million EHV bridge.

I submitted a written question in April 2026 asking whether the Gateways Hospital contract is funded

from

the

$1.4

million

RPHP

prevention

allocation

from

the

separate

$434,979

Local

Solutions.

That

question

has

not

been

answered.

Page 1 ends

1007 of 1125

If Gateways draws from RPHP, it reduces what is available for the 188 families. I f Gateways draws

from

Local

Solutions,

the

$434,000

the

bridge

pool

may

the

same

money

already

committed

December,

and

Council

should

know

whether

being

double-counted.

Questions 1. Is the $434,000 in the April 28 staff report the same $434,979 appropriated by the December 16,

2025

resolution?

And

that

shows

the

FY2026-2027

proposed

budget,

already

discussing

funds

spent?

2. Is any portion currently committed or obligated to the Gateways Hospital contract, the GRASP

program,

any

other

existing

commitment?

3. Does the Gateways contract draw from the $1.4 million RPHP allocation or from the $434,979 in

Local

Solutions?

4. What is the current unobligated balance of (a) the RPHP allocation and (b) the Local Solutions allocation?

5. Has LACAHSA been notified of the City's intent to use Local Solutions funds for the EHV bridge?

the

applicable

Measure

expenditure

guidelines

permit

this

use?

I request that these questions be reflected in the public hearing record for the May 5, 2026 adoption. I reserve all rights under 24 CFR 903.23(b), 24 CFR 91.105, 24 CFR 91.505, and the Ralph M. Brown Act.

Ani Khash
Glendale, California
The following attached screenshots
from

Dec.

2025

appropriated

resolution

LACHASA

funds,

April

2026

staff

report,

and

2026-2027

budget

proposal

for

Glendale.

Page 2 ends

1008 of 1125

Dec 2025:

April 2026 (continued on page 4, next):

Page 3 ends

1009 of 1125

Page 4 ends

1010 of 1125

Page 5 ends

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Page 6 ends

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Fiscal year 2026-2027 proposed budget:

Page 7 ends

1013 of 1125

This comment is submitted during the noticed public comment period for the Glendale Housing

Authority

2026–2027

PHA

Annual

Plan

and

Administrative

Plan,

closing

May

2026,

with

public

hearing

May

2026.

request

that

this

comment

and

any

attachments

included

the

formal

record

for

the

plan

adoption.

Please

confirm

receipt

this

submission

email.

The draft FY 2026–2027 PHA Annual Plan is being adopted in the context of the

Housing

Authority's

April

28,

2026

vote

"approve

the

deployment"

$3,700,000

HOME

funds

temporary

bridge

subsidy

for

188

Emergency

Housing

Voucher

households

facing

loss

assistance.

These

HOME

funds

originate

from

the

same

HOME-ARP

allocation

approved

Substantial

Amendment

March

21,

2023.

The

public's

ability

evaluate

the

proposed

bridge

strategy,

and

HUD's

ability

review

the

adopted

plan

the

context

that

strategy,

depends

access

the

foundational

allocation

documents

and

their

current

status

IDIS.

If the March 2023 Substantial Amendment is not publicly accessible, and if the current

commitment

and

disbursement

status

the

HOME-ARP

allocation

unknown,

then

neither

the

public

nor

HUD

can

assess

whether

the

proposed

TBRA

use

consistent

with

the

approved

allocation

whether

further

substantial

amendment

under

24 CFR

91.505

required

before

these

funds

can

deployed.

Statement of facts The City's CDBG webpage lists substantial amendments to Annual Action Plans from FY

2019–2020

and

2020–2021.

The

March

21,

2023

Substantial

Amendment

allocating

Page 1 ends

1014 of 1125

$5,109,346 in HOME-ARP funds for an affordable housing rental development project is not

listed

separately

posted

document.

The Citizen Participation Plan (p. 14, section C) requires "reasonable and timely access to

information

and

records

relating

the

Consolidated

Plan

documents

and

the

use

assistance

during

the

preceding

five

years."

The

CPP

states:

"Staff

will

respond

requests

for

information

within

10 working

days"

(p.

15).

The published legal notice (Beacon Media News, March 6, 2023) confirms the amendment

was

processed

and

adopted.

Questions 1. Is the as-approved text of the March 21, 2023 HOME-ARP Substantial Amendment currently

available

for

public

review?

so,

what

URL?

2. Was the HOME-ARP Allocation Plan accepted by HUD CPD Los Angeles in a written acceptance

letter?

so,

what

date,

and

that

letter

available?

3. Can staff provide a current IDIS activity summary showing all HOME-ARP activities, commitment

dates,

and

disbursement

status?

4. Why is the March 2023 amendment not posted on the CDBG document index? 5. Is the October 2025 HOME-ARP Substantial Amendment ($2,100,000 for transitional housing)

posted

for

public

review?

Please

provide

the

resolution

number

and

adoption

date.

I request that these questions be reflected in the public hearing record for the May 5, 2026

adoption.

reserve

all

rights

under

24 CFR

903.23(b),

24 CFR

91.105,

24 CFR

91.505,

and

the

Ralph

Brown

Act.

Ani Khash Glendale, California

Page 2 ends

1015 of 1125

From: Akopyan, Edgar
To: Simon, Jinette
Cc: Fortney, Mike; Bolbolian, Arthur; Kassabian, Irina; Jackson, Pamela; Zadoryan, Sipan Subject: FW: Public comment - on public access to the March 2023 HOME-ARP Substantial Amendment and related records/approved bridge funding prior commitments
Date: Friday, May 1, 2026 4:20:05 PM
Attachments: COG_120Anniversary_Signature_128.pnginline1 Comment_public access to the March 2023 HOME-ARP Substantial Amendment and related records.pdf Hi Jinette,

Please see attached. More to come.

Edgar Akopyan | Senior Housing Analyst
Community Development
141 N. Glendale Avenue, 2nd Level, Room 202, Glendale, CA 91206 P: +1 (818) 548-3230 | M: +1 (818) 858-3998
[email protected] | GlendaleCA.gov | Follow us! 120 Years of Service to Our Community
From: Ani <[email protected]>
Sent: Friday, May 1, 2026 1:37 PM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Public comment - on public access to the March 2023 HOME-ARP Substantial Amendment and related records/approved bridge funding prior commitments

CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a public comment submitted during the noticed comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan.

I request that this comment and its attachments be included in the formal record for the plan adoption on May 5, 2026.

Please confirm receipt.

Thank you,
Ani
1016 of 1125

1017 of 1125

From: Ani <[email protected]>
Sent: Friday, May 1, 2026 2:29 PM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Public comment - on 14-day comment period for HOME funds proposed as bridging funds CAUTION:

This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a public comment submitted during the noticed comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan.

I request that this comment and its attachments be included in the formal record for the plan adoption on May 5, 2026.

Please confirm receipt.

Thank you,
Ani
1018 of 1125

meet

the

requirements

the

Citizen

Participation

Plan

This comment is submitted during the noticed public comment period for the Glendale Housing Authority

2026–2027

PHA

Annual

Plan

and

Administrative

Plan,

closing

May

2026,

with

public

hearing

May

2026.

request

that

this

comment

and

any

attachments

included

the

formal

record

for

the

plan

adoption.

Please

confirm

receipt

this

submission

email.

The FY 2026–2027 PHA Annual Plan is being adopted at the same time the Housing Authority

proposes

redeploy

$3,700,000

HOME

funds

from

the

March

2023

HOME-ARP

allocation

for

Tenant-Based

Rental

Assistance

EHV

bridge

subsidy.

Any

such

redeployment

would

itself

constitute

substantial

amendment

under

24 CFR

91.505

and

the

City's

own

Citizen

Participation

Plan

(p.

12),

requiring

30-day

public

comment

period

before

implementation.

the

original

March

2023

allocation

was

itself

adopted

with

comment

period

that

did

not

meet

the

CPP's

30-day

requirement,

the

procedural

foundation

for

the

entire

HOME-ARP

allocation

question.

HUD's

review

the

adopted

plan

should

account

for

whether

the

underlying

allocation

which

the

proposed

bridge

strategy

depends

was

processed

accordance

with

the

City's

federally

required

citizen

participation

procedures.

Statement of facts On March 21, 2023, the City Council and Housing Authority approved a Substantial Amendment

the

2021–2022

Annual

Action

Plan

allocating

$5,109,346

HOME-ARP

funds

for

affordable

housing

rental

development

project.

The

published

legal

notice

(Beacon

Media

News,

March

2023)

stated

the

comment

period

would

run

March

6 to

March

20,

2023.

The

amendment

was

adopted

March

21,

one

day

after

the

comment

period

closed.

The comment period was fourteen (14) calendar days. The Citizen Participation Plan (p. 12, item i) requires: "Publish a notice of the 30-day public comment

period

the

proposed

amendment

the

adopted

Consolidated

Plan

and/or

Annual

Action

Plan."

24 CFR

91.105(k)

provides:

"The

jurisdiction

must

its

citizen

participation

plan."

Page 1 ends

1019 of 1125

The October 2025 Substantial Amendment ($2,100,000 for transitional housing) was published on

about

October

2025,

with

adoption

approximately

December

2025,

consistent

with

the

30-day

requirement.

The

City's

compliance

2025

demonstrates

awareness

the

requirement.

Questions 1. How many calendar days of public comment were provided for the March 2023 HOME-ARP Substantial

Amendment?

2. What provision of the CPP, federal regulation, or HUD waiver authorized fewer than 30 days?

the

City

relies

CPD

Notice

21-10

(section

V.B,

15-day

minimum

for

initial

HOME-ARP

plans),

explain

why

the

CPP

was

not

amended

reflect

this,

and

why

the

October

2025

amendment

used

30 days.

3. Was HUD CPD Los Angeles notified that the City provided fewer than 30 days? If so, provide the

date,

form

notification,

and

any

HUD

response.

4. Were any public comments received during March 6–20, 2023? If so, were they summarized and

attached

the

final

amendment

required

the

CPP

(p.

11,

item

iv)

and

24 CFR

91.105(c)(3)?

I request that these questions be reflected in the public hearing record for the May 5, 2026 adoption.

reserve

all

rights

under

24 CFR

903.23(b),

24 CFR

91.105,

24 CFR

91.505,

and

the

Ralph

Brown

Act.

Ani Khash Glendale, California

Page 2 ends

1020 of 1125

From: Ani <[email protected]>
Sent: Friday, May 1, 2026 3:30 PM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Public comment on draft admin plan - RAB procedural compliance CAUTION:

This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a public comment submitted during the noticed comment period for the Glendale Housing Authority's draft FY 2026–2027 PHA Annual Plan and Administrative Plan.

I request that this comment and its attachments be included in the formal record for the plan adoption on May 5, 2026.

Please confirm receipt.

Thank you,
Ani
1021 of 1125

Public comment on the draft FY 2026–2027 Administrative Plan Submitted by: Ani Khash Date: May 1, 2026 To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])
CC: City Clerk ([email protected]); City Council ([email protected]) Re: Resident Advisory Board procedural compliance with 24 CFR Part 903 This comment is submitted during the noticed public comment period for the Glendale Housing Authority FY 2026–2027 PHA Annual Plan and Administrative Plan, closing May 4, 2026, with a public hearing on May 5, 2026. I request that this comment and any attachments be included in the

formal

record

for

the

plan

adoption.

Please

confirm

receipt

this

submission

email.

Relevance to the draft Administrative Plan The PHA Annual Plan cannot be adopted and submitted to HUD without compliance with the Resident

Advisory

Board

requirements

24 CFR

903.13.

Under

24 CFR

903.13(c)(1),

the

PHA

must

include

the

Annual

Plan

submission

HUD

copy

the

recommendations

made

the

RAB"

and,

the

PHA

does

not

the

RAB's

recommendations,

description

the

PHA's

reasons

for

the

rejection."

The

HUD-50075-HCV

form,

Item

C.1(a),

requires

the

PHA

certify

whether

the

RAB

had

opportunity

examine

and

comment

the

plan.

These

are

affirmative

obligations

the

PHA,

and

the

burden

demonstrating

compliance

rests

with

the

Housing

Authority,

not

with

the

public.

Statement of facts The February 25, 2026 RAB meeting The Housing Authority provided the meeting minutes, agenda, orientation presentation, and sign-in

sheet

for

the

February

25,

2026

Resident

Advisory

Board

meeting.

Based

these

documents:

The meeting lasted 38 minutes (11:05 AM to 11:43 AM). During that time, staff conducted a RAB orientation

explaining

the

role

and

function

the

RAB,

presented

"key

components"

the

2026–2027

Draft

Annual

Plan,

provided

"an

overview"

the

Draft

Administrative

Plan,

and

received

questions

and

comments

from

RAB

members.

The

agenda

confirms

this

was

the

only

RAB

meeting

this

plan

cycle;

the

prior

meeting

referenced

the

consent

calendar

was

February

20,

2025,

over

twelve

months

earlier.

Page 1 ends

1022 of 1125

The meeting minutes record that "Members expressed the need for continued focus on affordable

housing

Glendale."

The

minutes

not

record

any

specific

written

recommendations

from

the

RAB

any

element

the

Annual

Plan

Administrative

Plan.

RAB composition and representation The Glendale Housing Authority administers approximately 1,592 Housing Choice Vouchers, 188

Emergency

Housing

Vouchers,

and

zero

public

housing

units.

Its

assisted

population

approximately

100%

tenant-based.

Under

24 CFR

903.13(b)(3),

when

tenant-based

assistance

families

constitute

than

20%

the

assisted

population,

they

must

represented

the

RAB.

The

sign-in

sheet

lists

15 RAB

members.

The

roster

does

not

indicate

which

members

represent

HCV,

EHV,

project-based

voucher

households,

and

unclear

from

the

available

documents

whether

any

EHV

households

were

represented

the

RAB

the

time

this

meeting.

Adequacy of review time and materials Under 24 CFR 903.13(a)(2), the PHA must provide "reasonable means" for the RAB to "become informed"

about

the

programs

covered

the

Plan.

Under

24 CFR

903.17(b),

the

plan

must

made

available

for

public

review

least

45 days

before

the

public

hearing.

The

RAB

orientation

presentation

states

that

"PHAs

must

give

the

RABs

sufficient

time

review

and

make

recommendations

the

Plan"

and

that

"RABs

should

also

provided

with

any

existing

documents

that

would

assist

them

make

productive

recommendations."
The available documents do not establish: (a) the date on which the full draft Annual Plan and draft

Administrative

Plan

were

provided

RAB

members;

(b)

whether

RAB

members

received

the

plans

advance

the

February

25 meeting

saw

them

for

the

first

time

the

meeting;

(c)

whether

the

38-minute

meeting,

which

included

orientation

for

new

members,

provided

sufficient

time

for

meaningful

review

multi-hundred-page

Administrative

Plan

and

draft

Annual

Plan

addressing

the

imminent

loss

188

Emergency

Housing

Vouchers.

HUD-50075-HCV certification sequencing The HUD-50075-HCV form associated with this plan cycle carries a certification date. If Item C.1(a)

was

certified

prior

the

February

25 RAB

meeting,

the

certification

that

the

RAB

had

opportunity

examine

and

comment

the

plan

would

predate

the

meeting

which

that

opportunity

was

provided.

the

form

has

been

updated

since

the

RAB

meeting

reflect

RAB

input,

the

updated

version

has

not

been

made

available

Engage

Glendale

for

public

review.

The RAB meeting minutes, agenda, orientation presentation, and sign-in sheet were not posted

Engage

Glendale,

the

City's

PrimeGov

meeting

portal,

the

City

Clerk's

Boards

and

Commissions

index,

any

other

publicly

accessible

location

during

the

public

comment

period.

These

documents

were

obtained

only

through

separate

records

request.

Under

24 CFR

903.17(a),

the

PHA

must

make

the

plan

and

supporting

documents

"available

for

examination

and

comment"

for

least

45 days

before

the

public

hearing.

The

RAB

meeting

the

only

documented

consultation

with

assisted

residents

during

this

plan

cycle.

the

public

cannot

access

the

records

that

consultation

without

filing

separate

request,

the

comment

period

operating

incomplete

record,

and

public

comment

cannot

meaningfully

address

whether

the

RAB

process

satisfied

24 CFR

903.13.

Page 2 ends

1023 of 1125

Questions 1. On what date were the full draft Annual Plan and full draft Administrative Plan provided to RAB

members?

Were

these

documents

provided

advance

the

February

25 meeting,

and

so,

how

many

days

advance?

2. The meeting minutes state that "Members expressed the need for continued focus on affordable

housing

Glendale."

Does

the

Housing

Authority

treat

this

written

RAB

recommendation

for

purposes

24 CFR

903.13(c)(1)?

so,

what

the

PHA's

written

response?

not,

does

the

Housing

Authority

have

any

written

RAB

recommendations

include

the

plan

submission

HUD?

3. The RAB orientation was conducted at the same meeting where the plans were presented for review.

Was

this

the

first

time

these

RAB

members

were

convened

for

this

plan

cycle?

so,

how

does

single

38-minute

meeting

that

includes

orientation,

plan

presentation,

and

open

discussion

satisfy

the

requirement

provide

"sufficient

time

review

and

make

recommendations"?

4. Which RAB members, if any, represent Emergency Housing Voucher households? Given that the

draft

Annual

Plan

addresses

the

imminent

depletion

EHV

funding

affecting

188

households,

were

EHV

participants

specifically

recruited

for

represented

the

RAB?

5. Was the HUD-50075-HCV form, Item C.1(a), certified before or after the February 25, 2026 RAB

meeting?

before,

what

basis

was

certified

that

the

RAB

had

opportunity

examine

and

comment

the

plan

prior

the

meeting

which

that

opportunity

was

first

provided?

6. Please provide a current roster of the Resident Advisory Board with the voucher program status

(HCV,

EHV,

project-based)

for

each

member,

required

demonstrate

compliance

with

24 CFR

903.13(b)(3).

7. The draft Annual Plan addresses the imminent depletion of EHV funding affecting 188 households.

Were

any

EHV

participants

consulted

during

the

RAB

process

any

other

point

during

the

plan

development?

not,

how

did

the

Housing

Authority

ensure

the

RAB

was

adequately

informed

about

program

covering

188

households

that

the

RAB

does

not

appear

include?

I request that these questions be reflected in the public hearing record for the May 5, 2026 adoption. I reserve all rights under 24 CFR 903.23(b), 24 CFR 903.13, 24 CFR 903.17, and the Ralph M. Brown Act. Ani Khash Glendale, California

Page 3 ends

1024 of 1125

From: Ani <[email protected]>
Sent: Friday, May 1, 2026 3:57 PM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Brotman, Daniel <[email protected]>; Asatryan, Elen <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Formal public challenge #1 to elements of the draft FY 2026-2027 PHA Annual Plan under 24 CFR 903.17 and 903.23(b)
CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a formal public challenge to elements of the draft FY 2026-2027 PHA Annual Plan, submitted pursuant to 24 CFR 903.17 and 903.23(b). This challenge must be attached to the plan, together with the PHA's written response, upon submission to HUD.

I note that this is being submitted on Friday afternoon. Considering the plan is scheduled for adoption discussion on Tuesday and commenting ends Monday, I expect this challenge to be included in the materials presented to all before the vote. I also intend to submit my prior public comments as formal challenges before the noon deadline on May 4 and will send those separately.

Please confirm receipt.
1025 of 1125

Thank you,
Ani
1026 of 1125

Formal public challenge to elements of the draft FY 2026–2027 PHA Annual Plan Pursuant to 24 CFR 903.17 and 903.23(b) Submitted by: Ani Khash Date: May 1, 2026 To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])
CC: City Clerk ([email protected]); City Council ([email protected]) Re: Proposed redeployment of HOME funds from rental development to TBRA without a substantial

amendment;

inconsistency

with

the

2025–2030

Consolidated

Plan

Pursuant to 24 CFR 903.17 and 903.23(b), this submission constitutes a formal challenge to the following

elements

the

draft

2026–2027

PHA

Annual

Plan:
(1) The financial resources element under 903.7(d), on the basis that the plan's associated bridge funding

strategy

relies

HOME

funds

that

the

City's

own

planning

documents

state

cannot

deployed

without

Consolidated

Plan

amendment

and

HUD

concurrence

that

have

not

been

initiated;
(2) The consistency with the Consolidated Plan under 903.23(a)(3), on the basis that the 2025–2030

Consolidated

Plan

states

the

City

"does

not

plan

utilize

HOME

funds

for

Tenant

Based

Rental

Assistance

(TBRA)"

and

Consolidated

Plan

amendment

has

been

adopted;
(3) The AFFH certification under 903.7(o), on the basis that the plan contains no transition mechanism

for

188

EHV

households

disproportionately

composed

disabled

individuals,

domestic

violence

survivors,

and

racial/ethnic

minorities.

I request that this challenge, and the PHA's written response, be attached to the plan upon submission

HUD

required

the

HUD-50075

form,

Section

C.4.

The Housing Authority's public notice for this plan cycle does not inform the public that plan elements

may

formally

challenged

under

24 CFR

903.23(b),

that

challenged

elements

must

attached

the

plan

upon

submission

HUD.

exercising

this

right

regardless.

Statement of facts The City's own planning documents confirm a Consolidated Plan amendment is required. The City's FY 2026–2027 Proposed Annual Action Plan (p. 10) lists "HOME Tenant-Based Rental Assistance – EHV Bridge Program: TBD" and states: "Implementation of this activity is contingent

upon

amendment

the

City's

2025–2030

Consolidated

Plan

and

concurrence

from

HUD's

Los

Angeles

Field

Office."
The same document (p. 11) further states: "The City will continue to evaluate opportunities to deploy

these

funds

accordance

with

HOME

program

requirements

and

expenditure

deadline,

Page 1 ends

1027 of 1125

including potential use for a Tenant-Based Rental Assistance program, contingent upon Consolidated

Plan

amendment.
"
The 2025–2030 Consolidated Plan states: "Given the limited funding, the City does not plan to utilize

HOME

funds

for

Tenant

Based

Rental

Assistance

(TBRA)."
Council voted to "approve the deployment" of funds that the City's own documents say require

process

that

has

not

been

initiated.

The April 28, 2026 staff report (Report No. 26-89993, p. 12) identifies $3,700,000 in "HOME Funds

–

Tenant

Based

Rental

Assistance

(TBRA)"

for

the

EHV

bridge.

Council

voted

"approve

the

deployment"

these

funds.

The

66-page

staff

report

does

not

mention

that

the

City's

own

Annual

Action

Plan

describes

this

activity

contingent

upon

Consolidated

Plan

amendment.

does

not

mention

24 CFR

91.505,

the

City's

Citizen

Participation

Plan,

the

30-day

public

comment

period

required

for

substantial

amendments.

The regulatory framework independently requires a substantial amendment. 24 CFR 91.505(a) requires a jurisdiction to amend its approved plan whenever it decides to: (1) change

allocation

priorities;

(2)

carry

out

activity

not

previously

described;

(3)

change

the

purpose,

scope,

location,

beneficiaries

activity.

The

City's

Citizen

Participation

Plan

(p.

12)

requires

amendment

whenever

decision

made

to:

(1)

carry

out

activity

not

previously

described;

(4)

substantially

change

the

purpose,

scope,

location,

beneficiaries.

The

proposed

HOME

TBRA

activity

satisfies

multiple

triggers

under

both.

The CPP requires a 30-day public comment period for substantial amendments (p. 12, item i). 24 CFR

91.105(c)(2)

independently

requires

not

less

than

30 calendar

days.

substantial

amendment

process

has

been

initiated.

Questions 1. What portion of the $3,700,000 identified as "HOME Funds" is HOME-ARP carryover from the

$5,109,346

approved

March

21,

2023,

and

what

portion

drawn

from

other

HOME

development

fund

balances?

2. What portion has been committed or disbursed in IDIS for any previously approved HOME

HOME-ARP

activity,

and

what

portion

remains

uncommitted?

3. Has staff determined whether the proposed HOME TBRA/EHV bridge activity requires a Consolidated

Plan

amendment,

the

City's

own

2026–2027

Proposed

Annual

Action

Plan

states?

so,

what

was

the

determination

and

basis?

staff's

position

differs

from

the

Annual

Action

Plan's

statement

that

implementation

"contingent

upon

amendment,"

please

explain

the

discrepancy.

4. Has the City initiated the Consolidated Plan amendment process referenced in its own Annual

Action

Plan?

so,

when

was

the

30-day

public

comment

period

published?

not,

when

does

staff

anticipate

initiating

it?

5. If staff's position is that no Consolidated Plan amendment or substantial amendment is required,

please

cite

the

specific

provision

the

CPP,

federal

regulation,

HUD

guidance

that

exempts

this

activity,

and

explain

how

that

position

reconciled

with:

(a)

the

City's

own

Annual

Action

Plan

language

stating

implementation

contingent

upon

such

Page 2 ends

1028 of 1125

amendment; and (b) the 2025–2030 Consolidated Plan's statement that the City does not plan to

utilize

HOME

funds

for

TBRA.

6. Can staff confirm that no HOME funds will be obligated or expended for TBRA until (a) any

required

Consolidated

Plan

amendment

and

substantial

amendment

process

completed;

(b)

HUD

Los

Angeles

Field

Office

concurrence

received,

the

Annual

Action

Plan

requires;

and

(c)

subsequent

appropriation

action

taken

Council?

Basis for HUD review Under 24 CFR 903.23(a), HUD may disapprove a plan that: (iii) is not consistent with any applicable

Consolidated

Plan

for

the

jurisdiction.

The

2025–2030

Consolidated

Plan

states

the

City

does

not

plan

utilize

HOME

funds

for

TBRA.

The

2026–2027

Annual

Action

Plan

states

the

HOME

TBRA

activity

contingent

upon

Consolidated

Plan

amendment

that

has

not

been

adopted.

The

plan

being

submitted

HUD

the

context

bridge

funding

strategy

that

the

City's

own

documents

say

cannot

implemented

without

process

that

has

not

begun.

I request that this challenge and the PHA's written response be reflected in the public hearing record

and

attached

the

plan

upon

submission

HUD.

reserve

all

rights

under

24 CFR

903.23(b),

24 CFR

91.105,

24 CFR

91.505,

and

the

Ralph

Brown

Act.

Ani Khash Glendale, California

Page 3 ends

Glendale City CouncilMay 5, 2026

Glendale City Council
May 5, 2026