Backup Documents 03/24/2009 Item #10E
ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
Print on pink paper. Attach to original document. Original documr:nts should be hand delivered to the Board Office. The completed routing slip and original
documents are to be forwarded to the Board Oftice only after the Board has taken action on the item,)
10 E'1'
ROUTING SLIP
Complete routing lines#l through #4 as appropriate for additional signatures, dates, and/or infonnation needed. If the document is already complete with the
excention of the Chairman's sip-nature, draw a line throuph wutin,r lines # I throul1h #4, comnlcte the checklist, and forward to Sue Filson' (line #5).
Route to Ad~tessee(s) Office Initials Date
(List in routino order
I.Frank Ramsey Housing and Human Service --=rr-. 03/25/09
2. Chairman DOillla Fiala BCC
3.
4.
5. Sue Filson, Executive Manager Board of County Commissioners
6. Minutes and Records Clerk of Court's Office
PRIMARY CONTACT INFORMATION
(The primary contact is the holder oflhe original document pending Bee approval Normally the primary contact is the person who created/prepared the executive
summary. Primary contact information is needed in the event one nfttle nddressecs <lbove, inch.rling Sue Filson, need to cmtact statlfor additional or missing
information. All original documents needing the Bee Chairman's signature are [0 be delivered to the Bee office only after the BCe has acted to approve the
item)
Name of Primary Staff Frank Ramsey, Housing Manager Phone Number 252-2336
Contact
Agenda Date Item was 03/24/2009 Agenda Item Number 10E
Annroved bv me BCC
Type of Document Contract Number of Original 3
Attached Documents Attached
Initial the Yes column or mark "N/A" in the Not Applicable column, whichever is Yes N/A(Not
aoorooriate. (Initial) Aoolicable)
I. Original document has been signed/initialed for legal sufficiency, (All documents to be
signed by the Chainnan, with the exception of most letters, must be n:viewed and signed 7ft-
by the Office of the County Attorney. This includes signature pages from ordinances,
resolutions, etc. signed by the County Attorney's Office and signatuT<: pages from
contracts, agreements, etc. that have been fully executed by all parties except the BCC
Chainnan and Clerk to the Board and nossiblv State OtTicials,)
2. All handwritten strike-through and revisions have been initialed by the County Attorney's 71-
Office and all other oarties exceot the BCC Chaillnan and the Clerk to the Board
3. The Chainnan's signature line date has been entered as the date of BCC approval of the 7t-
document or the fmal ne.otiated contract date wbichever is annlicable.
4. "Sign here" tabs are placed on the appropriate pages indicating where the ehainnan's f-4{
si.nature and initials are renuired.
5. In most cases (some contracts are an exception), the original document and this routing slip ~
should be provided to Sue Filson in the BCC otTice within 24 hours of Bee approval.
Some documents are time sensitive and require fOlwarding to Tallahassee within a certain
time frame or the BCC's actions are nullified, Be aware ofvour deadlines!
6. The document was approved by the BCC on 03/24/2009 and all changes made during 11-
the meeting have been incorporated in the attached document. The County Attorney's
Office has reviewed the chan!!es, if aoolicablc.
INSTRUCTIONS & CHECKLIST
I: Forms/ County Forms/ Bee Forms! Original Documents Routing Slip WWS Origina19.03.04, Rcvised 1.26.05, Revised 2.24.05
lOEI1
FUNDING APPROVAL AND GRANT AGREEMENT FOR
NEIGHBORHOOD ST ABILIZA nON PROGRAM (NSP) FUNDS
AS AUTHORIZED AND APPROPRIATED UNDER THE
HOUSING AND ECONOMIC RECOVERY ACT OF 2008
(PUBLIC LAW 110-289, JULY 30, 2008)
NSP GRANTEE:
Collier County
NSP GRANT NUMBER:
B-08-UN-12-0003
NSP GRANT AMOUNT:
$7,306,755
NSP APPROVAL DATE:
January 30, 2009
This Grant Agreement between the Department of Housing and Urban Development (HUD) and
Collier County is made pursuant to the authority of sections 230 I - 2304 of the Housing and
Economic Recovery Act of 2008 (Public Law 110-289 (July 30, 2008)) (HERA). The program
established pursuant to section 2301-2304 is known as the "Neighborhood Stabilization
Program" or "NSP." The Notice of Allocations, Application Procedures, Regulatory Waivers
Granted to and Alternative Requirements for Redevelopment of Abandoned and Foreclosed
Homes Under the Housing and Economic Recovery Act, 2008 published at 73 FR 58330
(October 6, 2008) (Notice); HERA; the Grantee's submission for NSP assistance (Grantee
Submission); the HUD regulations at 24 CFR Part 570 (as modified by the Notice and as now in
effect and as may be amended from time to time) (Regulations); and this Funding Approval,
including any special conditions, constitute part of the Grant Agreement.
Subject to the provisions of this Grant Agreement, HUD will make NSP Grant Funds in the
amount of $7,306,755 available to the Grantee upon execution of this Grant Agreement by the
parties. The Grantee shall have 18 months from the date of HUD's execution of this Grant
Agreement to obligate the NSP Grant Amount pursuant to the requirements of HERA and the
Notice. The Grantee shall have 48 months from the date of HUD's execution of this Grant
Agreement to expend the NSP Grant Amount pursuant to the requirements of the Notice. The
NSP Grant Funds may be used to pay eligible costs arising from eligible uses incurred after the
NSP Approval Date provided the activities to which such costs are related are carried out in
compliance with all applicable requirements. Pre-award planning and general administrative
costs may not be paid with funding assistance except as permitted in the Notice; the Notice limits
such costs to those incurred on or after September 29, 2008. Other pre-award costs may not be
paid with funding assistance except as permitted by 24 CFR 570.200(h); for purposes of NSP,
such costs are limited to those incurred on or after the date that the NSP substantial amendment
was received by HUD.
210E
The Grantee agrees to assume all of the responsibilities for environmental review,
decisionmaking, and actions, as specified and required in regulations issued by the Secretary
pursuant to Section 104(g) of Title I of the Housing and Community Development Act, as
amended (42 U.S.c. 5304) and published in 24 CFR Part 58. The Grantee further acknowledges
its responsibility for adherence to the Grant Agreement by sub-recipient entities to which it
makes funding assistance hereunder available.
This Grant Agreement may be amended only with the prior written approval of HUD. In
considering proposed amendments to this Grant Agreement, HUD shall review, among other
things, whether the amendment is otherwise consistent with HERA, the Notice, and the
Regulations.
The Grantee may amend its Grantee Submission; however, such amendments, including
snbstantial amendments as defined in 24 CFR Part 91, will be subject to the requirements of 24
CFR Part 91 (or any successor regulation) and any revisions HUD may make to the Notice (or
any successor Notice or regulation).
The Grantee shall at all times maintain an up-to-date copy of its Grantee Submission, including
all amendments approved by HUD, on its Internet website as required by the Notice. Further,
the Grantee shall maintain information on all drawdowns, deposits, and expenditures of grant
funds and program income under this Funding Approval and Grant Agreement and any other
records required by 24 CFR 570.506, in its files and shall make such information available for
audit or inspection by duly authorized representati ves of HUD, HUD's Office of the Inspector
General, or the Comptroller General of the United States.
The Grantee shall submit information on performance measurement as established by the
Secretary for activities undertaken with NSP grant funds.
The Grantee is advised that providing false, fictitious or misleading information with respect to
NSP Grant Funds may result in criminal, civil or administrative prosecution under 18 USC
91001,18 USC 91343, 31 USC 93729, 31 USC 93801 or another applicable statute.
Close-out of this grant shall be subject to the provisions of 24 CFR 570.509 or such close-out
instructions as may hereafter be issued by HUD specifically for NSP grants.
Special Conditions are attached to this Grant Agreement.
This NSP Grant Agreement is binding with respect to HUD in accordance with its terms upon
the execution by HUD in the space provided above, subject to execution on behalf of the
Grantee.
The United States Department of
Housing and Urban Development
Collier County
N//JffjJf:f~
Signature of Authorized Official
d~~
'.."""~~1;"'i,#":'",
Signature of Authorized Offical
Maria R. Ortiz
Name of Authorized Official
LO'& FIAIA
Name of Authorized Official
Director. CPD
Title of Authorized Official
(}l.AIRMi\N
Title of Authorized Official
5-- y-() 9
MARf'H ?/', ?fXJJ
Date of Signature
Date of Signature
59-ffiXl558
Grantee Tax Identification Number
For HUD CFO Use Onlv
Current Balances
Increases/Decreases
Ending Balance
Date
Approved as to form & legal sufficiency
0(~~
Colleen Greene,
Assistant County Attorney
ATTEST:
DWIGHT E. BROCK. (;18r~,
ay,
Attest II
119ftlture 011..
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3
IDE
~
Special Conditions to Funding Approval and Grant Agreement For
Neighborhood Stabilization Program (NSP) Funds
as Authorized and Appropriated by under the
Housing and Economic Recovery Act of 2008
(Public Law 110-289, July 30, 2008)
NSP Grantee: Collier County
NSP Grant Number B-08-UN-12-0003
NSP Grant Amount: $7,306,755
NSP Approval Date: January 30, 2009
Special Conditions:
1. Pursuant to 24 CFR 85.12 (a)(l)(2)(4) or (5), a special condition applies to this Grant
Agreement due to past performance with the County's timeliness ratio in the CDBG
program. The County did not meet the CDBG timeliness requirement in FY 2008. The
County was required to have no more than 1.5 years offunding available in its CDBG
line of credit at the end of the 10lh month of its program year. The balance as of May 2,
2008 was $4,695,973 which represents 1.96 years of funding. lt appears that the County
not being able to draw down in a timely manner stems, in part, from undertaking several
ineligible activities and experiencing delays with approvals/reimbursements for other
County Departments. The County shall submit documentation describing how past
CDBG performance issues have been resolved or are now being resolved and explaining
how they will not impact the administration of the NSP program. If the County fails to
submit such documentation within 60 days from the date HUD signed this Grant
Agreement, HUD may thereafter withhold authority to incur additional obligations of
NSP Grant Funds or take other actions authorized under 24 CFR 85.12(b).
2. Pursuant to 24 CFR 85.12 (a)(3), a special condition applies to this Grant Agreement due
to the size of the NSP Grant Amount relative to your 2008 CDBG grant. Within 60 days
of the date HUD signed this grant agreement, the County must submit a management
plan that describes how it has determined that it possesses adequate staff and other
resources necessary to administer NSP grant funds. If the County fails to submit this plan
within 60 days, HUD may thereafter withhold authority to incur additional obligations of
NSP Grant Funds.
ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP 1 0 E \~W ,
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
Print on pink paper. Attach to original document. Original documents should be hand delivered to the Board Office. The completed routing slip and original
documents are 10 be forwarded to the Board Oflice only after the Board has taken action on the item.)
ROUTING SLIP
Complete routing lines #1 through #4 as appropriate for additional signatures. dates, and/or information needed. If the document is already complete with the
exception of the Chairman's signature, draw a line throUllh routim:! lines #1 throueh #4, conmlete the checklist, and forward to Sue Filson (line #5).
Route to Addressee(s) Office Initials Date
(List in routing order)
1. --------
2. ~
3. -----
./C---
4. Colleen M. Greene, Assistant County County Attorney Cf{l&- 03/26/09
Attorney
5. Sue Filson OMB
6. Minutes and Records Clerk of Court's Office
PRIMARY CONTACT INFORMATION
(The primary contact is the holder of the original document pending Bee approval. Normally thc primary contact is the person who created/prepared the executive
summary. Primary contact information is needed in the event one of the addressees above, including Sue Filson, need to contact staff for additional or missing
infonnation. All original documents needing the Bee Chainnan's signature are to be delivered to the Bee office only after the Bee has acted to approve the
item.)
Name of Primary Staff Frank Ramsey Phone Number 252-2336
Contact
Agenda Date Item was March 24, 2009 Agenda Item Number JOE
Approved by the BCC
Type of Document Administrative Plan Agreement- Number of Original 1
Attached Neighborhood Stabilization Program Documents Attached
INSTRUCTIONS & CHECKLIST
Initial the Yes column or mark "N/A" in the Not Applicable column, whichever is appropriate.
1.
Original document has been signed/initialed for legal sufficiency. (All documents to be signed by the
Chairman, with the exception of most letters, must be reviewed and signed by the Office of the
County Attorney. This includes signature pages from ordinances, resolutions, etc. signed by the
County Attorney's Office and signature pages from contracts, agreements, etc. that have been fully
executed by all parties except the BCC Chairman and Clerk to the Board and possibly State
Officials.
All handwritten strike-through and revisions have been initialed by the County Attorney's Office and
all other arties exee t the Bee Chairman and the Clerk to the Board
The Chairman's signature line date ha<; been entered as the date ofSCe approval of the document or
the final ne otiated contract date whichever is a licable.
"Sign here" tabs are placed on the appropriate pages indicating where the Chairman's signature and
initials are re uired.
In most cases (some contracts are an exception), the original document and this routing slip should be
provided to Sue Filson in the Bee office within 24 hours of Bee approval. Some documents are
time sensitive and require forwarding to Tallahassee within a certain time frame or the BCC's actions
are nullified. Be aware of our deadlines!
The document was approved by the BeC on 03/24/09 and all changes made during the meeting
have been incorporated in the attached document. The County Attorney's Office has reviewed
the chan es, if a licable.
Yes
Initial)
CMG
N/A (Not
A licable)
2.
3.
4.
5.
6.
N/A
CMG
CMG
N/A
CMG
I: Forms/ County Fonns/ Bee Fonns/ Original Documents Routing Slip WWS Original 9.03.04, Revised J .26.05, Revised 2.24.05
((matter _ numbem/((document_ number>>
tOE l~"
MEMORANDUM
Date:
March 27, 2009
To:
Frank Ramsey, Housing Manager
Housing & Human Services Department
From:
Martha Vergara, Deputy Clerk
Minutes & Records Department
Re:
Administrative Plan Agreement -
Neighborhood Stabilization Program
Enclosed please find one (1) copy of the document, as referenced above
(Agenda Item #lOE), which were approved by the Board of County
Commissioners on Tuesday, March 24, 2009.
The Minutes and Records Department has retained the original for
the Board's Records.
If you should have any questions, please contact me at 252-7240.
Thank you.
Enclosures
IDE "
Collier County
Housing and Human Services
3301 E Tamiami Trail
Building H - Suite 211
Naples, Florida 34112
(239) 252-4663
This Administrative Plan is a guide for operating the Collier
County Neighborhood Stabilization Program. This guide was
prepared by the Department of Housing and Human Services.
Grant Number
B-08-UN-12-0003
Grant Amount
$7,306,755
IDE
I. INTRODUCTION.................................................................................................................................................... 3
II. ACQUISITION OBJECTIVES AND POLICIES.............................................................................................................3
A. Objective(s) ...................................................................................................................................................... 3
B. Acquisition Policies.............. ............................................................................................................................. 3
C. Identifying Property......................................................................................................................................... 4
D. Acquisition Regulations.................................................................................................................................... 4
III. REHABILITATION OBJECTIVES AND POLICIES ................................................................................................... 4
A. Objective(s) ...................................................................................................................................................... 4
B. Rehabilitation Policies........................................................................................................................... ........... 4
C. Rehabilitation Regulations............................................................................................................................... 5
IV. DIRECT ASSISTANCE OBJECTIVES AND POLICIES ..............................................................................................5
A. Objective(s) ....................................................................... ............................................................................... 5
B. Direct Assistance Policies................................................................................................................................. 5
C. Direct Assistance Regulations .......................................................................................................................... 6
V. DEMOLITION OBJECTIVES AND POLICIES.............................................................................................................6
A. Objective(s) ...................................................................................................................................................... 6
B. Demolition Policies........................................................................................................................................... 6
C. Demolition Regulations.................................................................................................................................... 7
VI. LAND BANK OBJECTIVES AND POLICIES ........................................................................................................... 7
A. Objective(s) ...................................................................................................................................................... 7
B. Land Bank Policies ............................................................................................................................................ 7
C. La nk Bank Regu lations ......................................... ............................................................................................ 7
VII. TRANSFER PROPERTY OBJECTIVES AND POLICiES............................................................................................ 8
A. Objective(s) ...................................................................................................................................................... 8
B. Transfer Property Policies................................................................................................................................ 8
C. Transfer Property Regulations......................................................................................................................... 8
VIII. ACTIVITY PROCEDU RES .................................................................................................................................... 8
A. Genera I............................................................................................................................................................. 8
B. Acquisition of Real Property............................................................................................................................. 9
C. Rehabilitation................................................................................................................................................. 10
D. Direct Assistance ............................................................................................................................................ 10
E. Demol itio n............................................................................................................................. ......................... 11
F. Land Banking .................................................................................................................................................. 11
G. Tra nsfer of Property....................................................................................................................................... 11
IX. PROGRAM PROCEDURES................................................................................................................................ 12
A. General........................................................................................................................................................... 12
B. Environmental Review................................................................................................................................... 12
C. Cha nge Orders..... ._......................................................................................................................................... 12
D. Payment......................................................................................................................................................... 12
E. Final Inspection .............................................................................................................................................. 13
F. Monitoring County Owned Properties........................................................................................................... 13
G. Transfer of Property....................................................................................................................................... 13
X. PU RCHASING POLiCy.......................................................................................................................................... 13
XI. MARKET! NG PROGRAM.................................................................................................................................. 14
XII. RE PORTI NG............................................................. ........................................................................................ 14
XIII. PROGRAM I NCOM E....................................... _................................................................................................ 15
Page 2 of 15
I.
INTRODUCTION
10 E "\~ r'\
Title III of Division B of the Housing and Economic Recovery Act, 2008 (HERA) (Public Law 110-289, approved July
30,2008) appropriates $3.92 billion for redevelopment of abandoned and foreclosed homes and residential
properties. The grant program under Title III is commonly referred to as the Neighborhood Stabilization Program
(NSP).
The Department of Housing and Urban Development (HUD) required Collier County to submit a Substantial
Amendment to the 2008-2009 HUD One Year Action Plan no later than December 1, 2008. The required
Amendment was approved by the Collier County Board of County Commissioners on November 18, 2008 under
agenda item 16D3.
Collier County has been allocated $7,306,755.00 to assist with redevelopment of abandoned and foreclosed
homes and residential properties. Section 2301(c)(2) of HERA requires the County to distribute the funds to the
areas of greatest risk. Factors considered included percentage of home foreclosures, percentage of homes
financed by a subprime mortgage related loans, and those likely to face a significant rise in the rate of
foreclosures.
Collier County will focus efforts in three (3) geographic areas: East Naples (Zip Code 34112), Golden Gate City (Zip
Code 34116) and Golden Gate Estates (Zip Code 34120). However, Collier County will continue to monitor local
housing data and intends that the NSP Program be flexible to allow for timely reaction to any significant changes
in the local housing market.
This Administrative Plan is a guide for operating the Collier County Neighborhood Stabilization Program. The
major focus of this guide is on the following six (6) eligible activities: Acquisition, Rehabilitation, Direct Assistance,
Demolition, Land Banking and Property Transfer.
II. ACOUISITION OBIECTIVES AND POLICIES
A. Obiective(s)
Provide permanent residential structures that will be occupied by a household whose income is at or
below 120 percent of area median income.
B. Acquisition Policies
1. The average purchase price for the sum of all properties acquired shall be discounted at
least fifteen (15) percent from the current market appraised value. The minimum
discount is five (5) percent from the current market appraised value.
2. The current market appraisal will be made in conformity with the requirements of the
URA at 49 CFR 24.103 and completed within sixty (60) days prior to an offer to purchase is
made by Collier County or an approved housing partner.
3. All residential properties acquired must have been foreclosed, vacant for at least ninety
(90) days, and on the lender's list of current inventory.
4. All acquisitions shall be made pursuant to a written Agreement for Sale and Purchase and
in conformity with the procedures prescribed herein as section X - Purchasing Policy. In
the event of a conflict, Community Development Block Grant (CDBG) purchasing policies
sha II ta ke precedent.
5. All residential properties are eligible for acquisition. Examples include, but are not limited
to, single-family residential dwelling units, multi-family residential dwelling units and
residential condominium units.
6. Acquired property is subject to the minimum affordability period of the federal HOME
Investment Partnership Program.
Page 3 of 15
IOE
C. IdentifYing Property
Residential properties shall be targeted in the following three geographic areas: East Naples (Zip Code
34112), Golden Gate City (Zip Code 34116) and Golden Gate Estates (Zip Code 34120). Collier County will
seek to acquire residential properties suitable for resale to qualifying households, as well as residential
properties suitable for rental to qualifying households.
The Department of Housing and Human Services will partner with Real Property Management when
identifying properties to purchase. When identifying properties, Collier County may desire to acquire
residential properties that possess the following characteristics:
. Single-family dwelling units
. Multi-family dwelling units
. Requiring minimal structure rehabilitation
. Incorporated green building practices
Housing and Human Services, in partnership with Real Property Management, will work directly with
banks and other lenders, foreclosure servicers, realtors, or any other party with access to foreclosed
property of interest to Collier County. However, Agreements for Sale and Purchase for the acquisition of
property may only be made with the banks or other lenders holding title to the property.
All proposed acquisitions must be approved by the Director of Housing and Human Services, or his/her
designee, prior to entering into a purchase contract.
D. Acquisition Regulations
. Acquisition - 24 CFR 570.201(a)
. Uniform Relocation Act - 49 CFR 24.103
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.500(a)
. Environmental Reviews - 24 CFR part 58
. Resale of Property - Section 2301(d)(3) of HERA
. Affordability Period - 24 CFR 92.252(a), (c), (e) and (f), and 92.254
III. REHABILITATION OBIECTIVES AND POLICIES
A. Obiectivds)
Improve permanent residential structures that will be occupied by a household whose income is at or
below 120 percent of area median income.
B. Rehabilitation Policies
1. All rehabilitation work must conform to current Florida Building Code requirements, as
well as Environmental Health & Safety requirements.
2. All purchasing for services and goods, including capital equipment, shall be made by
purchase order or by a written contract and in conformity with the procedures prescribed
herein as Section X - Purchasing Policy.
3. Once complete, all rehabilitated properties must meet HUD Section 8 Minimum Housing
Quality Standards and applicable Florida Building Codes.
Page 4 of 15
IDE
4. Eligible rehabilitation activities shall be listed and documented by a Bid Specification
Report prepared by a Rehabilitation Specialist. The Bid Specification Report will serve as a
cost estimate for the work plan.
S. Any change(s) to the scope of the rehabilitation activities and/or cost of rehabilitation will
be in accordance with the provisions outlined in the Collier County Purchasing Policy as
relates to change orders.
6. HERA defines rehabilitation to include, but not limited to, improvements to increase the
energy efficiency or conservation of such homes and properties, to provide renewable
energy source or sources for such homes and properties. Furthermore, Collier County
desires to harden the homes against the threat of hurricane damage.
7. HUD strongly encourages Collier County to use NSP funds not only to stabilize
neighborhoods in the short-term, but to strategically incorporate modern, green building
and energy-efficiency improvements to provide for long-term affordability and increased
sustainability and attractiveness of housing and neighborhoods.
8. Rehabilitated property is subject to the minimum affordability period of the federal
HOME Investment Partnership Program.
C. Rehabilitation Regulations
. Rehabilitation - 24 CFR 570.202
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.s00(a)
. Environmental Reviews - 24 CFR part 58
. Affordability Period - 24 CFR 92.252(a), (c), (e) and (f), and 92.254
. 2005 Environmental Health & Safety
. 2004 Florida Building Code (includes Energy Efficient Code)
. 2004 Florida Building Code/Fuel Gas
. 2004 Florida Building Code/Mechanical
. 2004 Florida Building Code/Plumbing
. 2004 Florida Building Code/Americans with Disabilities
. 2005 National Electric Code
. 2002-01 Building Construction Administrative Code
IV. DIRECT ASSISTANCE OBIECTIVES AND POLICIES
A. Obiective{s)
Provide permanent residential structures that will be occupied by a household whose income is at or
below 120 percent of area median income.
B. Direct Assistance Policies
1. All households assisted must have income at or below 120 percent of area median
income.
2. All households must be qualified by the Department of Housing and Human Services prior
to entering into a purchase agreement.
3. The head of household(s) must be a U.S. citizen(s) or permanent resident alien(s).
4. Applicants will procure a fixed-rate mortgage through the Collier County Loan
Consortium, local banks, FHA or USDA. Restrictions on the features of the fixed-rate
mortgage are contained in the application package.
5. All applicants must receive at least eight (8) hours of homebuyer education from a HUD
certified counselor.
Page 5 of 15
IDE
6. The average purchase price for the sum of all properties acquired shall be discounted at
least fifteen (15) percent from the current market appraised value. The minimum
discount is five (5) percent from the current market appraised value.
7. The current market appraisal will be made in conformity with the requirements of the
URA at 49 CFR 24.103 and completed within sixty (60) days prior to an offer to purchase
or closing transaction.
8. All residential properties acquired must have been foreclosed, vacant for at least ninety
(90) days and on the lender's list of current inventory.
9. All residential properties are eligible for direct assistance. Examples include, but are not
limited to, single-family residential dwelling units, multi-family residential dwelling units
and residential condominium units.
10. The interest rate on Direct Assistance Deferred Payment Loans (DPL) will be zero (0)
percent.
11. The DPL must be repaid when the assisted property is sold, refinanced, is no longer the
homesteaded residence or is operated for an activity deemed ineligible for assistance
under NSP guidelines.
12. The Direct Assistance DPL shall be secured through use of a Promissory Note and
Mortgage.
13. The assisted property is subject to the minimum affordability period of the federal HOME
Investment Partnership Program.
14. All acquired property transaction must be in conformity with the Uniform Relocation Act.
15. All direct assistance activities will be made in conformity with Community Development
Block Grant (CDBG) down payment assistance policies.
16. All properties receiving NSP Direct Assistance must be, and remain, the homesteaded
property of the owner.
C. Direct Assistance Reguiations
. Direct Assistance - 24 CFR 570.201(n)
. Uniform Relocation Act - 49 CFR 24.103
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.500(a)
. Environmental Reviews - 24 CFR part S8
. Affordability Period - 24 CFR 92.252(a), (c), (e) and (f), and 92.254
. Residency - HUD Handbook 4350.3
. Income Guidelines - Section 2301(f)(3)(A) of HERA
V. DEMOLITION OBIECTIVES AND POLICIES
A. Obiectivds)
Eliminate blighted and unsafe residential structures through clearance, demolition and removal of
foreclosed buildings and improvements.
B. Demolition Policies
1. Structures on foreclosed properties that are not economically feasible to rehabilitate,
pose a health or safety threat, or are contributing to community blight may be
demolished. Note that only blighted structures are eligible for demolition.
2. Demolished properties may be placed in a land bank, according to HERA guidelines, may
be redeveloped, or may be transferred to a local non-profit provider of affordable
housing.
Page 6 of 15
IDE
3. Demolition will be considered if the cost to rehabilitate the acquired property is fiscally
not feasible. Note that only blighted structures are eligible for demolition.
4. All residential structures acquired must have been foreclosed upon, vacant for at least
ninety (90) days and on the lender's list of current inventory.
5. All proposed demolition must be approved by the Director of Housing and Human
Services, or his/her designee, prior to commencing work.
6. Housing and Human Services does not intend demolition to be a major NSP activity.
Rather, the Department reserves the right to demolish structures on acquired property
should it be deemed more fiscally responsible and said structures are blighted.
7. Demolished property is subject to the minimum affordability period of the federal HOME
Investment Partnership Program.
C. Demolition Regulations
. Demolition - 24 CFR 570.201(d)
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.s00(a)
. Environmental Reviews - 24 CFR part 58
. Affordabllity Period - 24 CFR 92.2S2(a), (c), (e) and (f), and 92.254
. Land Banking - 24 CFR 570.201(a) and (b)
. Resale of Property - Section 2301(d)(3) of HERA
. Uniform Relocation Act - 49 CFR 24.103
VI. LAND BANK OBIECTIVES AND POLICIES
A. Obiectivefs)
Establish a land bank for acquired foreclosed homes for the purpose of stabilizing neighborhoods and
encouraging re-use or redevelopment of urban property.
B. Land Bank Policies
1. All properties acquired for the local land bank must have been foreclosed upon, vacant
for at least ninety (90) days and on the lender's list of current inventory.
2. The average purchase price for all properties acquired shall be discounted at least fifteen
(15) percent from the current market appraised value.
3. The current market appraisal will be made in conformity with the requirements of the
URA at 49 CFR 24.103 and completed within sixty (60) days prior to an offer to purchase
or closing transaction.
4. An NSP-assisted property may not be held in a land bank for more than ten (10) years
without obligating the property for a specific, eligible redevelopment in accordance with
HERA requirements.
5. Acquired property is subject to the minimum affordability period of the federal HOME
Investment Partnership Program.
6. Property must be granted and maintain a homestead exemption.
C. Lank Bank Regulations
. Land Bank - 24 CFR 570.201(a) and (b)
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.500(a)
. Environmental Reviews - 24 CFR part 58
. Affordability Period - 24 CFR 92.252(a), (c), (e) and (f), and 92.254
Page 7 of 15
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. Uniform Relocation Act - 49 CFR 24.103
VII. TRANSFER PROPERTY OBIECTIVES AND POLICIES
A. Obiective(s)
Provide permanent residential structures that will be occupied by a household whose income is at or
below 120 percent of area median income.
B. Transfer Proverty Policies
1. Residential properties acquired under the Collier County NSP program must be sold,
rented or benefit households whose income is at or below 120 percent of area median
income.
2. Twenty-five (25) percent of the Collier County NSP allocation must assist households
whose income is at or below 50 percent area median income.
3. When an abandoned or foreclosed-upon home or residential property is purchased,
redeveloped or otherwise sold to an individual as a primary residence, then such sale shall
be in an amount equal to or less than the cost to acquire and redevelop or rehabilitate
such home or property up to a decent, safe, and habitable condition. Sales and closing
costs are eligible NSP redevelopment or rehabilitation costs. Note that the maximum
sales price for a property is determined by aggregating all costs of acquisition,
rehabilitation, and redevelopment (including related activity delivery costs, which
generally may include, among other items, costs related to the sale of the property). HUD
will not consider the costs of boarding up, lawn mowing, or simply maintaining the
property in a static condition to be redevelopment or rehabilitation costs.
4. When an acquired home or residential property is rented, the maximum affordable rent
shall not exceed the Fair Market Rents (FMR) as published annually by HUD for the Naples
- Marco Island MSA.
5. Acquired property is subject to the minimum affordability period of the federal HOME
Investment Partnership Program.
C. Transfer Property Regulations
. Acquisition - 24 CFR 570.201(a)
. Property Location - Section 2301(c)(2) of HERA
. Program Income - 24 CFR 570.500(a)
. Affordability Period - 24 CFR 92.252(a), (c), (e) and (f), and 92.254
. Uniform Relocation Act - 49 CFR 24.103
. Resale of Property - Section 2301(d)(3) of HERA
. Residency - HUD Handbook 4350.3
. Income Guidelines - Section 2301(f)(3)(A) of HERA
VIII. ACTIVITY PROCEDURES
A. General
I. The Collier County Board of County Commissioners approves the HUD One Year Action
Plan and delegates administration of the NSP grant to the Director of Housing and Human
Services.
il. The Director of Housing and Human Services has grant administration responsibility.
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iii. Current job descriptions for all actively involved employees will be maintained by the
Department of Human Resources.
iv. Financial duties and responsibilities must be separated so that no one employee has sole
control over cash receipts, disbursements, payroll, reconciliation, etc.
v. All activities must be in compliance with HERA, NSP and HUD CDBG regulations.
B. Acquisition of Real Property
i. The Director of Housing and Human Services, or his/her designee, will work with Real
Property Management to identify abandoned and foreclosed properties for sale. Housing
and Human Services may partner with Information Technology to produce GIS mapping of
foreclosed properties. Additionally, Housing and Human Services may partner with Code
Enforcement to develop a list of bank contacts for the acquisition of foreclosed
properties.
ii. As potential properties are identified, Housing and Human Services personnel, with the
assistance of Real Property Management representatives, will conduct and initial
evaluation of each property to determine suitability for acquisition and rehabilitation.
iii. Real Property Management will conduct or procure an appraisal of each property deemed
suitable within sixty (60) days prior to making an offer to purchase. Letter of federal
funding use issued to bank.
iv. Appraisals will note that the property has been vacant for at least ninety (90) days in
order to conform and comply with the requirements of the Uniform Relocation Act (URA).
v. Following initial evaluation and appraisal, proposed offers to purchase will be prepared by
Housing and Human Services and Real Property Management personnel. All offers to
purchase must be approved by the Director of Housing and Human Services.
vi. Real Property Management will negotiate with foreclosing lenders to obtain acceptance
of approved offers to purchase, and will prepare Agreements for Sale and Purchase.
Letters of federal funding use will be issued to lenders as appropriate.
vii. Agreements for Sale and Purchase will contain appropriate contingencies regarding
marketable title, environmental review and other due diligence items, and must be
approved by the County Attorney's Office for form and legal sufficiency.
viii. Upon approval of Agreements for Sale and Purchase, Real Property Management will
obtain proper execution of the Agreements.
ix. Real Property Management will conduct all due diligence review, including obtaining
evidence of clear title from an approved vendor, and will coordinate with Housing and
Human Services, Risk Management, Code Enforcement, and other departments, agencies
and organizations as appropriate.
x. Housing and Human Services will perform Environmental Review as part of the due
diligence process.
xi. Real Property Management will prepare and/or review all documentation required for the
closing of acquisitions, and will coordinate with the County Attorney's Office to obtain
approval of all documents for form and legal sufficiency. Real Property Management will
obtain proper execution of all documents.
xii. Real Property Management will coordinate with Finance to obtain funds necessary for
closing.
xiii. Real Property Management will perform final examinations of title and conduct the
closing of all acquisitions following all appropriate closing procedures, and will supervise
the recording of acquisition conveyances and all documents necessary for title clearance
in the Public Records of Collier County, Florida.
xiv. Housing and Human Services to "drawdown" funds from HUD only after eligible funds
have been expended.
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xv. Housing and Human Services to update quarterly insurance spreadsheet with newly
acquired property information.
xvi. All County departments assisting Housing and Human Services will use the inter-
department billing system to receive payment for service(s) rendered.
xvii. Acquisition purchase prices shall not exceed One Hundred Fiftv and 00/100 Dollars
($lS0,OOO.00l per residential unit. Any single acquisition purchase price in excess of the
aforementioned limit must be specifically approved by the Collier County Board of County
Commissioners.
xviii. The Chairman of the Board of County Commissioners is authorized to execute
Agreements for Sale and Purchase for the acquisition of residential properties at purchase
prices in accordance with the Collier County NSP Administrative Plan, based upon
appraised values, and as approved by the County Attorney's Office, through February 13,
2013.
C. Rehabilitation
i. Rehabilitation Specialist to perform site inspection and prepare Bid Specification Form.
ii. Rehabilitation Specialist to ensure contractor access to property.
iii. Housing and Human Services to work with Purchasing Department to procure bids for
rehabilitation projects.
vi. Director of Housing and Human Services and Purchasing Department to approve winning
bid for projects.
vii. Rehabilitation Specialist to notify Collier County Sherriff's Office of newly acquired
residential properties.
viii. Grant Support Specialist to transfer utilities to Collier County.
ix. Grant Support Specialist to notify property maintenance vendor of newly acquired
residential properties and add properties to Community Watch Program.
x. Rehabilitation costs shall not exceed Fiftv Thousand and 00/100 Dollars ($50,000.00) per
residential unit. The Department of Housing and Human Services shall have authority to
enter into contracts for rehabilitation not to exceed fifty-thousand dollars ($50,000.00).
The Purchasing Department shall have authority to enter into contracts for rehabilitation
not to exceed two hundred thousand dollars ($200,000.00). Any rehabilitation
expenditures in excess of the aforementioned limits per unit must be specifically
approved by the Collier County Board of County Commissioners.
xi. Payment for eligible activities will be governed by Section X - Purchasing Policy.
D. Direct Assistance
i. Housing Outreach Coordinator to qualify clients interested in Direct Assistance.
ii. Housing and Human Services to use department approved checklist to ensure NSP
property requirements are satisfied: letter of federal funding provided to seller, appraisal
within sixty (60) days of offer to purchase or closing transaction, property foreclosed
upon and vacant for ninety (90) days.
iii. Housing Manager to approve all requests as eligible.
iv. SHIP Loan Processor to prepare request for direct payment. Check to be issued jointly to
closing agent and client(s).
v. All households assisted not to exceed 120 percent Area Median Income (AMI).
vi. All assisted households to complete at least eight (8) hours of home buyer education.
vii. Direct Assistance shall not exceed Fiftv Thousand and 00/100 Dollars ($SO,OOO.OOl. The
Department of Housing and Human Services shall have authority to enter into contracts,
agreements and security instruments for direct assistance not to exceed fifty-thousand
dollars ($50,000.00). Any direct assistance amounts in excess of the aforementioned
Page 10 of 15
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limits per unit must be specifically approved by the Collier County Board of County
Commissioners.
viii. Direct Assistance may not exceed fifty (50) percent of the required down payment.
E. Demolition
i. Director of Housing and Human Services to approve all demolition activities.
ii. Demolition will be considered if the cost to rehabilitate the acquired property is fiscally
not feasible. Note that only blighted structures are eligible for demolition.
iii. Estimated cost to rehabilitate will be determined by a Bid Specification Form completed
by a Rehabilitation Specialist.
iv. Following demolition, property may be either placed in a Collier County Land Bank for up
to ten (10) years or ownership may be transferred to a local non-profit provider of
affordable housing.
v. Demolition shall not exceed Twentv Five Thousand and 00/100 Dollars ($25,000.00) per
residential structure. The Department of Housing and Human Services shall have
authority to enter into contracts for demolition not to exceed twenty-five thousand
dollars ($25,000.00). Any demolition expenditure in excess of the aforementioned limits
per structure must be specifically approved by the Collier County Board of County
Commissioners.
vi. Payment for eligible activities will be governed by Section X - Purchasing Policy.
F. Land Banking
i. Director of Housing and Human Services to approve all transfers of property to the Collier
County Land Bank.
ii. Housing and Human Services to partner with Real Property Management to track, report
and monitor land bank properties.
iii. Housing and Human Services to contract with vendor to maintain property (i.e. lawn
maintenance, etc.).
iv. Property may be held in land bank no longer than ten (10) years from date of acquisition
by Collier County.
G. Transfer of Prooerty
i. Purchasers of NSP assisted residential dwelling units must obtain a first mortgage from a
lender on the Housing and Human Services' approved lender list.
ii. Proceeds from the sale of properties is considered program income as described in
Section XIII- Program Income of this Administrative Plan.
iii. Purchasers of N5P assisted residential dwelling units must have a household income of
120 percent of AMI or less.
iv. If property is transferred to a non-profit provider of affordable housing and subsequently
rented, the maximum affordable rent shall not exceed the Fair Market Rents (FMR) as
published annually by HUD for the Naples-Marco Island MSA. Any revenue in excess of
allowable costs must be returned to Collier County as program income.
v. Purchasers are responsible for all closing costs associated with the transfer of property.
vi. The maximum sales price for a property is determined by aggregating all costs of
acquisition, rehabilitation, and redevelopment (including related activity delivery costs,
which generally may include, among other items, costs related to the sale of the
property).
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IX. PROGRAM PROCEDURES
A. General
i. Director of Housing and Human Services has responsibility for management and
coordination of all aspects of the Collier County NSP Program.
ii. Financial duties and responsibilities must be separated so that no one employee has sole
control over cash receipts, disbursements, payroll, reconciliation, etc.
iii. HUD has granted permission for grantees to incur pre-award costs effective September
30, 2008.
iv. The NSP Program allows ten (10) percent of the gross grant amount plus ten (10) percent
of program income to be used for general administration and planning costs as defined at
24 CFR 570.205 and 206.
i. Rehabilitation Specialist will perform inspection of all properties considered for
acquisition by Housing and Human Services.
ii. Inspection will be performed using the HUD Housing Quality Standard (HQS) Inspection
Form.
iii. Housing and Human Services may contract with vendor to evaluate mold mitigation needs
on acquired properties.
iv. Rehabilitation Specialist may perform periodic inspections throughout the rehabilitation
period.
v. Inspection and approval of completed work must be completed by Housing and Human
Services prior to issuance of partial or final payment.
vi. Inspection will ensure compliance with lead-based paint procedures.
vii. Housing and Human Services will ensure all code enforcement violations are remedied
prior to transferring ownership.
viii. At a minimum, the Department of Housing and Human Services intends to administer all
NSP related activities during the initial eighteen (18) months under County control and
operation.
B. Environmental Review
i. All properties proposed for acquisition must compiy with the environmental review
requirements pursuant to 24 CFR part 58.
C. Change Orders
i. All changes to contracts subject to the provisions of the Collier County Purchasing Policy
shall be processed in accordance with that policy and the County's Procurement
Administrative Procedures.
ii. The Purchasing Department may approve administratively a contract extension up to six
(6) months from date of original contract or agreement execution.
iii. Extensions greater than six (6) months time must be approved by the Collier County
Board of County Commissioners.
D. Pavment
i. Housing and Human Services shall present the Clerk's Finance Department with Request
for Payment packages and/or process requests for payment against established Purchase
Orders.
ii. Progress payments, as approved by Housing and Human Services, may be made directly
to a vendor or organization for any NSP eligible activity.
iii. Payment for eligible work tasks and/or activities may be made directly to the provider of
the service(s), as approved by Housing and Human Services.
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iv. Eligible activities are those outlined in the US Department of Housing and Urban
Development Docket No. FR-5255-N-01.
v. Any performance milestones are in effect for program monitoring requirements only, and
as such, are used by Housing and Human Services, HUD and other grantor agencies as
general target goals rather than strict performance requirements.
E. Final Insvection
i. Upon completion of all rehabilitation work, Rehabilitation Specialist will issue a Certificate
of Final Inspection.
ii. Contractors will provide all requested and required release of liens, certificate of
occupancy and any other construction related close-out documents.
F. Monitoring County Owned Prooerties
i. Once title is transferred to Collier County, properties will be placed on the Community
Watch Program list.
ii. Housing and Human Services will work with Purchasing to properly procure home
maintenance services for all County owned properties. Services may include, but not be
limited to, lawn care maintenance, routine site inspections, lock changing and post-
construction cleanup.
Iii. Collier County Sheriff's office will be notified of all properties currently owned by Collier
County.
iv. Housing and Human Services' Rehabilitation Specialist will make regular site visits to
monitor property conditions and ensure contracted work is on schedule and being
completed as planned.
G. Transfer of Property
i. Housing and Human Services will maintain a list of completed homes available for
sale/rental and a list of homes currently under construction with an estimated availability
date.
ii. Persons wishing to purchase an NSP assisted home will be served on a first-come-first
served basis once eligibility and readiness to purchase has been secured.
iii. Purchasers shall be responsible for all closing costs involved in property transfer.
iv. To facilitate the sale of an NSP assisted property, Collier County and purchaser will enter
into a standard Agreement for Sale and Purchase through Real Property Management.
v. Purchasers must provide at least a One Thousand and 00/100 Dollar ($1.000.00l deposit
which will be applied to the closing costs.
vi. All interested purchasers to be pre-qualified by Housing and Human Services.
X. PURCHASING POLICY
Collier County's Department of Housing and Human Services will employ the following Purchasing Policy for
management of the NSP Program:
i. Acquisition of Real Property
a. Real Property Management shall have authority to negotiate the
purchase of real property eligible for the Collier County NSP Program.
b. Real Property Management shall negotiate with foreclosing lenders to
obtain acceptance of approved offers to purchase, and will prepare
Agreements for Sale and Purchase.
c. Agreements for Sale and Purchase will contain appropriate contingencies
regarding marketable title, environmental review, and other due
Page 13 of 15
IDE
diligence items, and must be approved by the County Attorney's Office
for form and legal sufficiency.
d. Acquisition purchase prices shall not exceed One Hundred Fiftv Thousand
and 00/100 Dollars ($lS0,000.00) per residential unit. Any single
acquisition purchase price in excess of the aforementioned limit must be
specifically approved by the Collier County Board of County
Commissioners.
e. The Chairman of the Board of County Commissioner is authorized to
execute Agreements for Sale and Purchase for the acquisition of
residential properties at purchase prices in accordable with the Collier
County NSP Administrative Plan, based upon appraised values, and as
approved by the County Attorney's Office, through February 13, 2013.
ii. Other Purchases (excluding Real Property)
a. All purchases, excluding real property, under the NSP Program shall be
procured in accordable with the County's Purchase Policy and the
County's Procurement Administration Procedures.
b. All purchases, excluding real property, of Two Hundred Thousand and
00/100 Dollars ($200.000.00) or less under section X(ii)(a) may be
awarded by the Purchasing/General Services Director.
c. All purchases, excluding real property, exceeding Two Hundred Thousand
and 00/100 Dollars ($200,000.00) included under section X(ii)(a) shall be
awarded by the Board of County Commissioners.
Xl. MARKETING PROGRAM
Collier County's Department of Housing and Human Services will actively market the Neighborhood Stabilization
Program (NSP). The purpose of the marketing program is to raise community awareness of the program's
availability, locate qualified and interested residents in the program, inform local non-profit providers of
affordable housing about potential program opportunities and involve our local contractors and tradesmen.
The Collier County NSP program will seek to increase the availability of affordable housing while also stimulating
local businesses. All vendors interested in participating in the program will be encouraged to register with the
Collier County Purchasing Department thereby allowing the dissemination of requests for services.
The Department of Housing and Human Service may market the program through newspaper advertisements,
Collier TV, local fairs and scheduled events. Housing and Human Services will work with the Public Service Public
Information Officer, as well as the Communication and Customer Relations Department.
The Director of Housing and Human Services, or designee, will work with the Public Services Public Information
Officer to approve all marketing activities and expenses in advance.
XII. REPORTING
The U.S. Department of Housing and Urban Development (HUD) requires regular reporting on each NSP grant
through the Disaster Recovery Grant Reporting (DRGR) system. For NSP only, HUD is waiving the annual reporting
requirements of the consolidated plan to allow for collection of more regular information on various aspects of
the uses of funds and of the activities funded with NSP dollars.
To collect these data elements and to meet reporting requirements, HUD is requiring Collier County to report on
its NSP funds using the online DRGR system, a streamlined, Internet-based format. The NSP program requires
quarterly reports. Such reports are due not later than thirty (30) days following the end of each calendar quarter
Page 14 of 15
IDE
with the first such report due not later than July 31,2009, for the quarter ending June 30, 2009. Each quarterly
report must be posted on Collier County's website so that the public may have ready access to the information.
In addition to this quarterly performance reporting, Collier County will report monthly on its NSP obligations and
expenditures beginning thirty (30) days after the end of the 15th month following receipt of funds, and continuing
until reported total obligations are equal to or great than Collier County's total NSP award.
For more information please refer to the October G, 2008 Federal Register Notice (73 FR 58341, Section 0,
Reporting).
Xlll. PROGRAM INCOME
Revenue received by Collier County (as defined at 24 CFR 570.500(c)) that is directly generated from the use of
CDBG funds (which term includes NSP grant funds) constitutes program income. Additionally, HUD requires anv
revenue from the sale, rental, redevelopment, rehabilitation or any other eligible use of NSP funds to be provided
to and used by Collier County. This includes revenue received by a private individual or other entity that is not a
subrecipient.
Program income received before July 30, 2013 may be retained by Collier County and treated as additional CDBG
funds and used in accordance with NSP regulations. Program income received on or after July 30, 2013 must be
returned to the u.s. Treasury. Substantially all program income must be disbursed for eligible NSP activities
before additional cash withdrawals are made from the u.S. Treasury.
HUD permits Collier County's Department of Housing and Human Services to use ten (10) percent of the NSP grant
and ten (10) percent of program income earned for general administration and planning activities as those are
defined at 24 CFR 570.205 and 20G. The ten (10) percent limitation applies to the grant as a whole.
The Collier County Neighborhood Stabilization Program Administrative Plan is adopted this 24th day of March,
2009.
ATTEST:
DWIGHTE. BFlOCK,c'q:cRK
BOARD OF COUNTY COMMISSIONERS
COLLIER COUNTY, FLORIDA
If}
,I' d-
BY: ~. ;/"1->-'""'''' , A -4t24/2009
DONNA FIALA, CHAIRMAN
AtttIt _.~ C'ltI'
.t..... OII~,
APPROVED AS TO FORM
AND LEGAL SUFFICIENCY
~~
BY: .
COLLEEN GR ENE
ASSISTANT COUNTY ATTORNEY
Page 15 of 15