HUD Shifts Authority for Certain CDE Plans to Hub Directors

HUD has delegated the authority to approve certain Compliance, Disposition and Enforcement (CDE) plans to regional Hub directors. Effective with the issuance of Notice H 2010-12 on July 9, 2010, Hub directors now have the authority to approve all CDE plans except those that recommend accelerating and/or foreclosing on an insured and/or assisted loan or those that recommend relocating residents and abating a Section 8 contract.

The Department recently conducted an assessment of the CDE plan submission and review process, which revealed the multiple layers of review and concurrence CDE plans were required to undergo before the final approval at headquarters. CDE plans are required when sites receive a physical inspection score outside established thresholds.

From this assessment, HUD concluded that delegating the authority to approve CDE plans that do not recommend abatement and relocation, and/or acceleration and foreclosure of a mortgage, to the Hub director will greatly reduce the amount of time it takes to approve the vast majority of CDE plans. This will reduce the number of days it takes to implement the compliance, disposition, or enforcement actions approved, and reduce potential risk to the Department by implementing corrective action and enforcement activities with less delay.

The realignment has produced new procedures, as follows: The Hub director or a designee such as the operations officer, the director of project management, or the Multifamily Program Center director must approve a CDE plan within 30 days of the date of the release of a second, consecutive physical inspection score below 60. The Hub director continues to follow the guidance contained in the April 7, 2003, memorandum captioned, “Under 60 Compliance—Disposition and Enforcement.”

Due dates, approval actions, and information regarding the Hub or Program Center's progress toward implementing the actions approved in a CDE plan will now be entered into a SharePoint Log found on the Business Relationships and Special Initiatives Division SharePoint site at: http://hudsharepoint.hud.gov/sites/DASMFH/OMAM/brsi/default.aspx.

The Hub director should designate one lead person and a backup at the Hub level to enter this information onto the SharePoint log. Only the lead person, the backup, and the Hub director will be given edit rights to the SharePoint site. All other staff will have viewing rights.

The director, Business Relationships and Special Initiatives Division, Office of Asset Management, will monitor the Hub's progress toward approving CDE plans and implementing the actions recommended within a reasonable amount of time. The CDE plan SharePoint Log will be monitored by HUD, which also plans to hold teleconference calls with each Hub to ensure that the CDE plans are being approved in a timely manner and that all actions approved are being carried out on schedule.

Questions regarding the new procedures should be directed to the Office of Asset Management, Business Relationships and Special Initiatives Division, at (202) 402-2629.