Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code HOU

16. Specific lobbying issues

Budget of the United States Government, Fiscal Year 2014; all provisions relating to the U.S. Department of Housing and Urban Development (HUD), U.S. Department of Agriculture (USDA) -Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service (IRS) proposals related to the Low Income Housing Tax Credit (LIHTC) and bond-financed multifamily housing programs. (Continued).
PL 112-25: Budget Control Act of 2011. A bill to control the budget; All provisions in Title I TEN-YEAR DISCRETIONARY CAPS WITH SEQUESTER, Sections 101,102,105,106 & Title III Section 302 Enforcement of budget goal related to discretionary spending levels as part of deficit reduction requirements (which could reduce funding for important U.S. HUD and USDA affordable multifamily housing programs).

H.CON.RES.25:Establishing the budget for the United States Government for fiscal year 2014 and setting forth appropriate budgetary levels for fiscal years 2015 through 2023. All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; urged replacement of sequestration [not included].

S. CON. RES. 8: Concurrent Resolution on the Budget for Fiscal Year 2014. The concurrent resolution on the budget for fiscal year 2014 and this resolution sets forth the appropriate budgetary levels for fiscal years 2013 and 2015 through 2023.
All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; and all provisions regarding sequestration in TITLE III Sec. 301. Deficit-neutral reserve fund to replace sequestration & TITLE IV Subtitle A, Sec. 403. Adjustments for sequestration or sequestration replacement.

HR 2410: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs.

S. 1244: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs.

Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. [Not formally introduced in reporting period, became HR 2610 on 7/2/13.]

S.1243: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs.

House Appropriations Committee "FY 2014 Report on the Suballocation of the Budget Allocations." All provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittee.
Senate Appropriations Committee, "FY14 Subcommittee Allocations." All provisions concerning the 302(b) allocation for the
Transportation-Housing and Urban Development and Related Agencies Subcommittee.

S. 766: A bill to amend section 520 of the Housing Act of 1949 to revise the census data and population requirements for areas to be considered as rural areas for purposes of such Act; all provisions [definition of rural area determines eligiblity for USDA-RHS housing programs].

S.954: Agriculture Reform, Food, and Jobs Act of 2013;TITLE VI--RURAL DEVELOPMENT, all provisions of Sec. 6202 Definition of rural area for purposes of the Housing Act of 1949 [definition of rural area determines eligiblity for USDA-RHS housing programs].

PL113-3: No Budget, No Pay Act of 2013; all provisions of Sec. 3. Holding Salaries of Members of Congress in Escrow Upon Failure to Agree to Budget Resolution.
Advocated for retaining the Low Income Housing Tax Credit (LIHTC) program as part of comprehenisive tax reform efforts by the House Ways and Means and Senate Finance Committees.

Adovacted for Section 8 and Rental Assistance Reform consistent with the April 13, 2012 House Financial Services Committee Discussion Draft Legislation, Affordable Housing and Self-Sufficiency Improvement Act of 2012: A bill to reform affordable housing programs and the provision of supportive services under the United States Housing Act of 1937; all provisions [not introduced during reporting period].

Draft bill from Rep. Nydia Velazquez: Expanding Meaningful Access to HUD Programs Act of 2013. To expanded access to programs of the Department of Housing and Urban Development for persons with limited English language proficiency; All provisions. [Not introduced during reporting period.]

All policies, funding, and administrative issues related to management, production and preservation of affordable multifamily housing subject to HUD, USDA-RHS, and Treasury-IRS regulations.

HUD Press Release HUD No. 13-054 "HUD Announces Major Restructuring of Field Offices," April 24, 2013; all provisions.
HUD [Docket No. FR5698N01] "Notice of Intent To Close 16 Field Offices" Friday, April 26, 2013; all provisions.

Offered preliminary feedback to HUD on potential demonstration program to test methodologies for achieving long-run cost savings in HUDs insured and assisted housing portfolios for high performing owner/sponsors to take advantage of less prescriptive oversight & a potential share of cost savings when they agree to fold groups of affordable housing properties into single portfolios that will be managed as one unit. (Demo program not formally proposed during reporting period.)

Offered preliminary policy recommendations that would achieve cost savings in the management & operation of federally assisted multifamily housing by: Eliminating Costs Unique to Affordable Housing; Performing Income Certifications Once for All Programs; Using Federal Tax Returns for Rent Calculations; Track, Enforce and Prevent Repeat Payment Agreements; Reduce the frequency of Management Occupancy Reviews (MORs); and examine the feasiblity of reducing or eliminating interim income recertifications.

The White House Domestic Policy Council Rental Policy Working Groups "Federal Rental Alignment-Administrative Proposals, December 31, 2011; all provisions (to better align the operation of federal rental programs and policies across the Administration).

Government Accountability Office "Decision in the Matter of Assisted Housing Services Corporation; North Tampa Housing Development Corporation; The Jefferson County Assisted Housing Corporation; National Housing Compliance; Southwest Housing Compliance Corporation; CMS Contract Management Services and the Housing Authority of the City of Bremerton; Massachusetts Housing Finance Agency," File: B-406738; B-406738.2; B-406738.3; B-406738.4; B-406738.5; B-406738.6; B-406738.7; B-406738.8. August 15, 2012; all provisions.

HUD [Docket No. FR-5600-N-33-C1] "HUDs Fiscal Year (FY) 2011 NOFA for the Performance-Based Contract Administrator (PBCA) Program Technical Correction," March 15, 2012; all provisions.

HUD [Docket No. FR-5600-N-33] "HUDs Fiscal Year (FY) 2012 Notice of Funding Availability (NOFA) for the Performance-Based Contract Administrator (PBCA) Program for the Administration of Project-Based Section 8 Housing Assistance Payments Contracts," March 9, 2012; all provisions.

HUD "Performance-Based Annual Contributions Contract, Project-Based Section 8 Contract Administration," February 24, 2012; all provisions.





HUD "Annual Contributions Contract Project-Based Section 8 Contract Administration, Second Amendment of Term, Incentive- Based Performance Standards Tasks, and Fees " October 17, 2012; all provisions. Urged amending to include Management & Occupancy Reviews (MORs) in PBCA tasks [not included].

HUD "Revising Handbook 4350.1, Phase I, Units and Topics," April 8, 2013; all provisions.
HUD Notice H 2011-30 "Use of Reserve for Replacement Accounts in Restructured Mark-to-Market (M2M) Properties," October 19, 2011; all provisions.
HUD Handbook 4350.1 REV-2, Multifamily Asset Management and Project Servicing; all provisions, especially Chapter 4 "Reserve Fund for Replacements."

HUD Proposed Rule [Docket No. FR5586P01, RIN 2501AD60] "Pet Ownership for the Elderly or Persons With Disabilities in Multifamily Rental Housing; Accumulation of Deposits for Costs Attributable to Pets," May 24, 2013; all provisions.

HUD Office of Housing Multifamily Housing Programs Memorandum "Suspension of the Requirements Contained in Sections 9-23, 9-24, and 9-25 of the Section 8 Renewal Policy Guide," September 7, 2012; all provisions (regarding new appraisal procedures for benchmarking rents in rent comparability studies).

HUD [Docket No. FR5413N02] "Section 8 Housing Choice Voucher ProgramDemonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas, Discussion of Comments, and Request for Participation," April 20, 2011; all provisions.

HUD [Docket No. FR5667N01] "Supportive Housing for the Elderly; Advance Notice of Senior Preservation Rental Assistance Contracts Award Process," January 8, 2013; all provisions.

HUD Mortgagee Letter 2012-25, Revised Requirements for Project Capital Needs Assessments, Estimated Reserves for Replacements and Remedies for Accessibility Deficiencies November 21, 2012; all provisions.
HUD Notice H 2012-27 Revised Requirements for Project Capital Needs Assessments, Estimated Reserves for Replacements and Remedies for Accessibility Deficiencies November 21, 2012; all provisions.

HUD "Guidance on Housing Notice H 2013-17, Updated Requirements for Prepayment and Refinance of Section 202 Direct Loans," June 26, 2013; all provisions.
HUD Notice H 2013-17, "Updated Requirements for Prepayment and Refinance of Section 202 Direct Loans," May 30, 2013; all provisions.

HUD Final Notice [Docket No. FR5526N02] Public Housing Assessment System (PHAS): Physical Condition Scoring Notice and Revised Dictionary of Deficiency Definitions, August 9, 2012; all provisions.

HUD Preparing for REAC Inspections (Guidance for MultiFamily and Public Housing Properties);" all provisions.

HUD Notice H 2012-5, "Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily Housing," April 23, 2012; all provisions.

All policies related to HUD's: Real Estate Assesment Center scoring and procedures for HUD-assisted and/or FHA insured properties; 2530 previous participation certification policies and submission procedures; and Management and Occupancy Review for owners and management agents, "Workload Sharing" pilot programs, & "Sustaining our Investments" Initiative.

IRS Notice 2013-22, "Public Comment Invited on Recommendations for 2013-2014 Guidance Priority List," March 22, 2013; all provisions. [Urged action on the Utility Allowances Submetering Proposed Rule and Casualty Loss Policies.]



IRS [RIN 1545-B191] Proposed Rule "Utility Allowances Submetering," August 7, 2012; all provisions.

IRS Notice 2012-18 Physical Inspections Pilot Program February 9, 2012; all provisions [LIHTC compliance requirements].

Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties.

USDA-RHS [RIN 0575AC93] Proposed Rule, "Civil Monetary Penalties," January 4, 2013; all provisions.

Offered prelimiary input to USDA-RHS regarding the RHS' plans to develop a pest management policy and best practices ; our input focused on application to multifamily properties.

USDA-Rural Development (RD) Procedure Notice 458, September 24, 2012; RD Handbook Changes INSERT RD HB-2-3560 Chapter 3 (Revision to Attachment 3-F to reflect no change to the Fiscal Year 2013 Management Fee).

Advocated for policies to address ongoing occupancy issues, including prolonged vacancies, in properties that participate in USDA-RHS's Multifamily Housing programs.

Advocated for policies to address improper payments in USDA-RHS's Section 521 Rural Rental Assistance program, including access to HUD's Enterprise Income Verification system.

All policies related to USDA Rural Development's Improper Payments Information Act (IPIA) audit for the Rental Assistance Program, Multi-Family Integrated System and its findings reviews, and rural housing preservation.

Comptroller of the Currency, Board of Governors of the Federal Reserve System & Federal Deposit Insurance Corporation[Docket ID OCC-2013-0003, Federal Register Number:2013-06075] Notice "Community Reinvestment Act; Interagency Questions and Answers Regarding Community Reinvestment" Mar 18, 2013; all provisions related to community development.

17. House(s) of Congress and Federal agencies Check if None

Housing & Urban Development - Dept of (HUD), Agriculture - Dept of (USDA), Treasury - Dept of, Internal Revenue Service (IRS), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP), White House Office, Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Deposit Insurance Commission (FDIC),

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code GOV

16. Specific lobbying issues

HR 313: Government Spending Accountability (GSA) Act. A bill to amend title 5, United States Code, to institute spending limits and transparency requirements for Federal conference and travel expenditures, and for other purposes; all provisions.

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

22. New General description of client’s business or activities

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address: www.sahma.org, www.ahma-psw.org, www.nahma.org (registrant)

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization