Detailed Information on the
Multi-Family Housing Programs Assessment

Finalizing regulations that will require the property owners to maintain an appropriate reserve for capital repairs.

Implementing legislative changes that will help address dilapidated properties currently within the portfolio.

Implementing and tracking the new long-term measures, as well as developing and improving current annual goals so that they tie more directly with funding decisions.

Measure: Families assisted with renewed contracts

Explanation:

Measure: Increase percent of A and B properties by 1 percentage point annually

Explanation:As part of its efforts to preserve the loan portfolio, Rural Development recently instituted an automated program that re-categorized properties based on automated outstanding compliance issues. This re-categorization resulted in a shift in classification proportions. The target remains a 1 percent move of properties in the higher A and B categories as a result of improved oversight, aggressive action against owners, and implementation of the Multifamily Portfolio Revitalization Program.

Measure: Units selected for construction or rehabilitation

Explanation:Includes units selected for construction or rehabilitation under Sections 515, 538, 514, 516, and 533

Measure: Increase by 30 percent annually over the baseline, the amount of non-USDA dollars invested in Multifamily rental housing properties.

Explanation:RHS monitors the total transaction costs of new and rehab properties to determine the proportion of USDA-dollars dedicated to properties versus the proportion contributed by private/public partners. As the percentage of outside funds increases, the number of rural families who live in safe, decent, and sanitary housing increases. This indicator measures the results of RHS's focus on continued leveraging of limited resources annually.

Measure: Leveraging ratio: Total Non-USDA-RD dollars of MFH loans and grants divided by total USDA-RD dollars for all projects.

Explanation:Leveraging with private/public partners increases the funds available to build and rehab/repair rental housing than would otherwise be available based on annual appropriations. This indicator measures how efficient RHS leverages each dollar spent in providing affordable, safe, decent, and sanitary housing annually. For every dollar that RHS spends, public/private contributes $1.2 dollars. By increasing leveraging, RHS can provide the same amount of assistance annually to rural areas with less BA, or alternatively, the same amount of assistance with straight-lined BA through leveraging.

Measure: Decrease percent of C and D properties by 1 percentage point annually

Explanation:The quality of housing is a "quality of life" indicator. As "substandard properties" are rehabilitated, the quality of life improves for rural residents because their living standards are safe, decent, and sanitary standards and the rent is affordable.

Measure: Reduce rural homelessness by 10 percent by Fiscal Year 2010.

Explanation:The availability of housing which meets safe, decent, and sanitary standards improves access to housing by the homeless, low and very-low income persons and thereby helps to reduce homelessness. RHS builds new rental units for very low and low-income tenants. Progress toward reducing homelessness is measured by the number of units produced divided by the total number of homeless people.

Measure: Reduce substandard housing for the very low to low-income tenant population in the RHS/MFH portfolio by 5 percentage points by Fiscal Year 2010.

Explanation:The quality of housing is a "quality of life" indicator. As housing conditions improve, so does the quality of life. As RHS reduces the percentage of substandard rural rental housing, the quality of life for rural rental residents improves.

Is the program purpose clear?

Explanation: The statute and agency regulations state that the purpose of the section 515 program is to make loans to eligible entities to construct, rehabilitate and repair affordable, decent and safe rental housing for elderly and low- or moderate-income families in rural areas. The purpose of the section 521 program is to make section 515 and section 514 housing affordable to rural residents. The purpose of the section 538 program is to guarantee loans to eligible entities to provide rental housing to low- or moderate-income families in rural areas. The purpose of the section 514/516 program is to provide on-farm and off-farm housing for farm workers. Overall these programs have been designed to provide and maintain quality rental housing in rural America for very-low- to moderate-income people. The recent focus has been on maintaining and ensuring housing quality rather than providing additional units of tenant housing. This is evidenced by recent budget proposals that restrict new construction for section 515 programs and focus instead on rehabilitating and revitalizing the portfolio while continuing to fund new construction through farm labor housing and the guarantee program.

Evidence: U.S. Housing Act of 1949 Sections 514 and 515, 42 USC 1485 and Section 521, 42 U.S.C 1490a and 7 CFR Parts 3560 and 3565.

Does the program address a specific and existing problem, interest, or need?

Explanation: The program provides access to affordable rental housing to moderate-, low-and very-low-income rural households. The program's goals focus on improving the quality and availability of rural rental housing. In addition, housing quality is addressed by providing new affordable units that meet code at a reasonable cost, and by providing supplemental loans and grants to rehabilitate aging properties currently in the portfolio.

Evidence: Annual Occupancy Survey conducted by the Agency as of January 2004 shows that tenants' average adjusted household income is $9,500, less than half of the poverty line. More that 50% of tenant households are headed by elderly or handicapped members. Approximately 75% of the households are headed by women.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: There are some similarly designed programs that provide affordable housing. Multifamily Housing programs in conjunction with other federal, state, and local efforts further increase the amount of affordable housing available to low-income rural residents. Multifamily Housing is an integral part of financing with other affordable housing lenders. The program provides rural housing for the very-low-income and elderly in rural America. Multifamily Housing serves approximately 750,000 of these residents.

Evidence: U.S. Housing Act of 1949; 2000 Census U.S. Housing Act of 1949; 2000 Census; HUD Section 236 (below market interest rate); HUD Section 221(d) (4) (new construction); HUD Section 223(f) (rehabilitation); and HUD Section 8 (Rental Assistance).

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The agency is redesigning the Multifamily Housing program through its revitalization proposal and legislative package. The agency is proposing a series of program changes, including increasing reserve requirements to fund capital repairs. The major design flaw is that the reserve requirements initially set and still in place today are not sufficient to fund major capital repairs as they come due. The entire Multifamily Housing Revitalization Proposal is an effort to correct this deficiency.

Evidence: "Performance and Accountability Report; 2004 Occupancy Survey. The 2004 Comprehensive Property Assessment. "

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The program is designed with population eligibility requirements to reach the very-low-income, the elderly, the disabled, and domestic farmworkers in rural areas, which meets the program purpose.

Evidence: U.S. Housing Act of 1949; Rural Development Allocation of Funds Review

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The agency has incorporated new, ambitious long-term performance measures into its strategic plan. The agency's long-term measures are (1) reducing homelessness and (2) reducing substandard housing for the very-low to low-income tenant population. The outcome is that the quality of housing is increased for the RHS rural tenant population and homelessness is reduced in rural areas. more people are living in safe, decent and sanitary housing. RHS plans to demonstrate how it will contribute to the Rural Development goal of improving the quality of life for rural residents by increasing the number of and improving the quality of the properties in which they live. There is a direct link between an individual's quality of life and his/her living conditions. RHS plans to measure the quality of properties by using a graduated classification system that categorizes properties based on 1) financial loan quality, 2) compliance with regulatory issues and outstanding inspection review issues, and 3) physical property conditions. There are four categories of properties (A through D with A as best performing).

Evidence: Budget Documents-units table and classification summary. The USDA Rural Development Strategic Plan.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The targets for this program are ambitious. The program plans to reduce homelessness in rural America by 10 percent by 2010 and improve the quality of the housing in the RHS MFH portfolio by 5 percent by 2010. A 5 percentage point decrease in substandard housing by 2010 is ambitious because prior years' activity has shown the reverse course, where the number of substandard properties has been on the rise.

Evidence: The USDA Rural Development Strategic Plan

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: Multifamily Housing (MFH) annual performance measures are designed to indicate progress toward the long-term goal of improving the quality of rural rental housing. This improvement is accomplished by increasing the quality of the existing housing stock and increasing the amount of housing stock by maximizing USDA funding through leveraging. MFH annual performance measures are shown below: 1. Increase percent of A and B properties by 1 percentage point annually 2. Decrease percent of C and D properties by 1 percentage point annually 3. Increase by 30 percentage points annually, the amount of non-USDA dollars invested in multifamily rental housing properties 4. Leveraging: Total dollars of MFH loans and grants divided by total development costs 5. Units selected for Construction or rehabilitation 6. Families assisted with renewed contracts

Evidence: Performance and Accountability Report

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The baseline FY 2005 targets are referenced in question 2.3. These targets are ambitious because a 1% change in the number of properties from C & D classifictions to A & B in a portfolio of approximately 17,000 properties translates into a movement of 170 properties annually. Given the limited budget resources in the section 515 rehabilitation budget, the Demonstration program and the Preservation resources, moving that amount of properties annually is extremely ambitious.

Evidence: Multifamily Monthly Report; Performance and Accountability Report, and (Leveraging Report)

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: In signing the loan agreements, the borrowers commit to the agency's long-term goals of providing affordable, safe and decent housing. Partners work toward the long-term goals through regular maintenance and ongoing renovation and rehabilitation of the properties. The agency takes enforcement action against borrowers who do not work toward the long-term goals of Multifamily Housing.

Evidence: November 2004 Comprehensive Property Assessment; Agency regulations 7 C.F.R. Part 3560; Annual Notice of Funds Availability notifying the developers of the competition and the criteria that the competition will be based on.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: In 2004 a complete review of the portfolio was conducted to identify what improvements were necessary in the program. In addition, the USDA Office of Inspector General and the Government Accountability Office routinely review performance of the program. The Agency also conducts Management Control Reviews to comply with the Federal Managers Financial Integrity Act.

Evidence: November 2004 Comprehensive Property Assessment; GAO study of the Section 521 program in 2004; OIG study of the Section 521 program in 2004; Agency Management Control Review guidelines.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: "Funding for the program does not consider leveraging or the effect the level of funding will have on bringing a certain percent of the portfolio up to a particular quality standard in terms of actual budget requests/ justifications. USDA does request outputs in conjunction with the Units Table indicate the amount of resources needed to build or repair/rehabilitate properties, yet this does not reflect in a meaningful and transparent way the long-term and annual outcome performance measures. "

Evidence: FY 2005 and FY 2006 Rural Development BPI budget documents; Units Table

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The agency released a Comprehensive Property Assessment in November 2004 that has been used to develop new, long-term, and improved annual performance measures. The agency has recently published new regulation 7 CFR Part 3560 and revised 7 CFR Part 3565. Both of these regulations are designed to improve program delivery, increase participation by outside public and private lenders, and enable the loan and rental assistance programs to more effectively provide affordable housing. A new legislative package for section 515 revitalization is being proposed for 2006.

Evidence: November 2004 Comprehensive Property Assessment; 7 CFR Parts 3560 and 3565; USDA Rural Development Strategic Plan 2005 - 2010

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: "The agency tracks the obligation rate of funds appropriated, the delinquency rate for loans made, the number of real estate owned properties, the use rate of rental assistance, and the number of properties preserved. MFH produces a monthly report on all of the properties in the portfolio. This report gathers information from the management agents and field staff. Included in this report is a listing of all the properties by property classification (i.e. C&D properties and A&B properties). MFH selects properties for preservation, rehabilitation and repair from the list of properties currently classified as C&D properties. During the funding selection process, applicants indicate the amount of leverage to be used in their project. This information is used during the selection process, and greater weight is given to those projects with greater leverage. MFH compiles the leverage data on each project at the time of obligation, and this data is used in evaluating the programs. Additionally, the agency receives regularly scheduled operating performance reports from borrow- ers, which are used to monitor and manage regulatory compliance."

Evidence: Multifamily Monthly Report; 7 CFR Part 3560; Quarterly Servicing Goals Report; and Quarterly Performance Report

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: "During Fiscal Year 2004, Rural Development successfully met the requirement supervisory and managerial positions' performance plans directly linked to the mission area's strategic goals. All performance evaluations contain linkages to the strategic plan for all managers and employees. The agency conducts lender and borrower compliance reviews annually. Enforcement actions could include suspending or removing non-compliant parties from the program, or imposing civil monetary penalties. The agency conducts State Office performance reviews quarterly and provides guidance as needed to resolve non-compliance. "

Evidence: Employee Performance Appraisals; Section 238 Lender Compliance Reports; Management Control Reviews; Triennial Supervisory Visit Reports; Portfolio Management Servicing Goal Reports

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Funds under all multifamily programs are fully utilized each year and obligated prior to year-end.

Evidence: Agency year-end fund usage reports generated by the RD Finance Office.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: "As part of the annual budget process, Rural Housing prepares a Units Table to compare actual per-unit costs and number in the prior year with current and future program needs. The National Office establishes servicing goals for State Offices, which are measured quarterly. The program managers develop monthly and annual reports on program performance and use those results to make decisions to achieve efficiencies in program execution. In December 2004, the program managers began using the Rental Assistance Forecasting Tool to automatically estimate annual budgetary needs for the Rental Assistance program. The agency has also automated the Multifamily Information System to transmit tenant and payment processing data electronically. The agency has initiated an effort to centralize the multifamily payment process. Program managers currently use management tools to calculate and measure the amount of private and non-USDA funds leveraged by each program dollar. "

Evidence: Units Table; Multifamily Information System Phase IV; Rental Assistance Forecasting Tool; HB-2-3560 Asset Management Handbook; Multifamily Monthly Report

Does the program collaborate and coordinate effectively with related programs?

Explanation: "RHS meets regularly with HUD on cross-cutting housing issues. In addition, HUD has loaned employees to the agency to assist in developing a demonstration program to revitalize the Multifamily Housing portfolio. HUD has also provided guidance to the agency in developing the rental voucher program. The HUD programs were used as a partial data source for development of the Comprehensive Property Assessment. RHS and HUD have developed cooperative agreements for the administration of project based section 8 grants in RHS financed properties. The IRS and RHS have coordinated development of the Low Income Housing Tax Credit to allow credit monitoring agencies to accept RHS compliance reviews and documents. Additionally, agreements have been reached with state housing finance agencies concerning coordination of development of new subsidized units in communities where competition may be detrimental, coordination of multiple sources of development subsidy in the same property to avoid over subsidy, and acceptance of state or federal asset management inspections and compliance reviews by other funding sources. "

Evidence: "RHS meets regularly with HUD on cross-cutting housing issues. In addition, HUD has loaned employees to the agency to assist in developing a demonstration program to revitalize the Multifamily Housing portfolio. HUD has also provided guidance to the agency in developing the rental voucher program. The HUD programs were used as a partial data source for development of the Comprehensive Property Assessment. Additionally, agreements have been reached with state housing finance agencies concerning acceptance of state or federal asset management inspections and compliance reviews.RHS has had meaningful discussions with numerous State Housing Authorities on Low Income Housing Tax Credit set-asides for RHS financed properties. Memorandums of understanding have been entered into with Ginnie Mae and Fannie Mae. "

Does the program use strong financial management practices?

Explanation: "Program accounting systems and borrower-required reporting were designed with the assistance of the USDA, OIG, and outside consultants (including GAO for the subsidy model). However, the 2004 Comprehensive study concluded that ""no property has adequate reserve or suficient cash flow to do neede repairs."" USDA has promulgated proposed regulatons to correct for the reserve requirements in the program but has yet to finalize these regulations or budget for the appropriate amount of Rental Assistance Grants to account for the needed increase in the reserve requirements. It should be noted, however that Fiscal Year 2004 Federal Managers' Financial Integrity Act Report removed the material weakness as a result of the publication of 7 CFR 3560, which was published with the revised reserve requirment stripped out. "

Evidence: The cashflow model for Multifamily Housing loans; Rental Assistance Forecasting Tool; 7 CFR Part 3560.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: RHS has streamlined and published regulations that govern the Multifamily Housing programs. These new and revised regulations will improve management of the program. The Comprehensive Property Assessment, which was released in November 2004, and the 2006 Budget Revitalization proposal are examples of the steps the agency is taking to improve the management of the program. The section 538 guarantee program, through its newly created partnerships with Ginnie Mae and Fannie Mae, uses the secondary market to improve the management of the program. Additionally, as a result of recent GAO review, RHS has implemented a Rental Assistance Grant forcasting model for budgeting purposes that is overseen by 3 people rather than one and is more accurate to ensure that over budgeting does not occur.

Evidence: November 2004 Comprehensive Property Assessment; 7 CFR Part 3560 published February 2005; and 7 CFR Part 3565 published March 2005; the 2006 President's budget. Rental Assistance Budget Projection Procedures/Model.

Is the program managed on an ongoing basis to assure credit quality remains sound, collections and disbursements are timely, and reporting requirements are fulfilled?

Explanation: 'The program's financial performance is monitored on an ongoing basis at the State and National Offices to ensure that funds are being obligated and disbursed appropriately, collections are made timely and management reports are being received as required. Obligations are updated overnight and tracked weekly and collections are enhanced through preauthorized debit of borrower bank accounts using the automated MINC system (45% and growing quarterly). Re-estimates on the loan programs are performed annually, which allows RHS to project the risk of offering this type of credit in the future.

Evidence: Guidance in 7 CFR 3560 and 7 CFR 3565. The Federal Credit Supplement provides subsidy rates, obligations and commitments, and average loan size for direct loans and loan guarantees programs.

Do the program's credit models adequately provide reliable, consistent, accurate and transparent estimates of costs and the risk to the Government?

Explanation: 'The Agency monitors key cohort elements on an ongoing basis and makes adjustments annually according to established procedures. The major elements are delinquencies, losses, lending rates, subsidy, disbursements and collections. An annual subsidy rate is calculated using an audited cash flow model. This computes the risk of the loan program for the Federal government. The current ('05) subsidy rate is 47.06% for Section 515, 47.06% for Section 514, and 3.49% for Section 538. The estimated subsidy rates for FY06 are 44.59%, 44.59%, and 5.42%, respectively. Most of the difference was due to interest rate variations and the actual adjusted rates have held fairly true to estimates over the past 5 years. The major elements that contribute to the assumptions have held constant from 2002 to 2005 including delinquency and losses. The borrower interest rates for direct loan programs are subsidized with interest credit to 1%, causing a higher Budget Authority (BA) rate, while only a minimum of 20% of guaranteed 538 loans receive interest credit, with maximum subsidy to the Applicable Federal Rate (AFR). The lifetime defaults as a percentage of disbursements remain extremely low for all loan programs, and zero for 538.

Evidence: Guidance in 7 CFR 3560, 7 CFR 3565; delinquency reports, and the Federal Credit Supplement.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Long-term performance goals were recently developed and tracking mechanisms for moving properties from C & D to A & B classifications, and measuring the amount of leveraged funds used throughout MFH have been implemented. This annual tracking will be used to monitor progress toward the long term outcome of reducing substandard property in the portfolio. Given the recent 2004 Comprehensive Property Assessment, which focused on physical elements of the loan classification system, management established the goal of improving the quality of the loan portfolio. These 2003 and 2004 targets were established after the actual loan portfolio data was compiled. However, data for 2003 and 2004 show that C & D properties are increasing and A & B properties are decreasing. Based on this, it is unclear that the long-term goal for reducing substandard housing will be met. The annual leverage targets have been met in 2003 and 2004. $48 million each year produced an additional 457 units, thereby reducing homelessness. MFH is on track to meeting its long-term goal of reducing homelessness by 10 percent by 2010.

Evidence: 7 CFR Parts 3560 and 3565; November 2004 Comprehensive Property Assessment; The USDA Rural Development Strategic Plan

Does the program (including program partners) achieve its annual performance goals?

Explanation: Each year after the budget is finalized, RHS estimates the number of units it will be able to build and continue helping based on the funding level provided, and the agency routinely meets or exceeds this goal. Additionally, new annual goals were recently developed and tracking mechanisms for moving properties from C & D to A & B classifications, and measuring the amount of leveraged funds used throughout MFH have been implemented. The annual leverage targets have been met in 2003 and 2004. By increasing the leverage amounts by $48 million annually, MFH has made significant progress toward meeting its long-term goal. Given the recent 2004 Comprehensive Property Assessment, which focused on physical elements of the loan classification system, management established the goal of improving the quality of the loan portfolio. These 2003 and 2004 targets were established after the actual loan portfolio data was compiled. FY2003 Target - 0.70, Actual - 0.78 FY2004 Target - 1.2, Actual - 1.2 However, the goals for increasing A and B properties and decreasing C and D properties were not met. In fact A and B properties are decreasing and C and D properties are increasing.

Evidence: Annual Performance Plan; Performance and Accountability Report

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: "RHS requires that all projects be evaluated for costs using the Marshall and Swift industry standards software. RHS also does cost certification audits on all of the projects completed during the year. Multifamily Housing leverages its resources with private/public partners to increase the number of new construction properties and rehab/repaired properties. MFH has been concentrating on increasing the leverage percentage in each project and has established improved leverage as a continuing measure of efficiency. In FY 2004, Multifamily Housing leveraged $1.19 for every program dollar allocated, which was an increase of 78 cents from FY 2003 and 66 cents from FY 2002. "

Evidence: Agency year-end and monthly accounting system funding, and loan status reports.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: "Housing trade groups such as The Housing Assistance Council and The Council for Affordable and Rural Housing frequently issue reports and analysis where USDA multifamily housing programs fare well in many aspects of performance and comparability. Universally, these and other groups have said our delivery structure and responsiveness is superior to HUD. Additionally, there have been some favorable comparisons for USDA in various GAO reports. "

Evidence: "In its 2005 study, Preserving Rural Rental Housing Programs, that was funded by the McArthur Foundation funded, a group of nationally recognized affordable housing professionals compared Section 515 programs favorably to other programs in rural America. They stated in the report that ""The section 515 rural rental housing program is the principal source of affordable housing for low income rural renters - is a national asset"". This is strong praise from a group spearheaded by advocates and the National Law Project, who are frequently critical of HUD. GAO Report 05-174 released March 16,2005 compared assistance to the elderly and found the 515 program superior to HUD's programs in the subset of Congregate Care and similar in other areas. GAO Report 02-76 showed a PDV analysis of development costs per unit of subsidy, and found 515 costing substantially less than comparable 811 and 202 HUD programs. It was the least costly effective alternative for housing low and very low income customers in each of the tests done, as compared to other similar programs. Partly, this is due to rural costs versus urban costs, but the bottom line in nearly every chart in the GAO report had the 515 at 30-50% less per unit in PDV. "

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The program is routinely reviewed by the USDA OIG and by GAO. Both have concluded that the program is effective and provides decent, safe, sanitary housing to low-income, elderly, and disabled rural residents. However, OIG reports problems with subsidy paymetn accuracy. A march 2005 OIG report notes that RHS failed to meet any of the 12 OIG reforms suggested in a 1999 report. Additionally, the Comprehensive Property Assessment study concluded, "Market analysis results show that the portfolio continues to serve a needed purpose and is worthy of revitalization." The CPA market assessment report noted: "Typically, properties in the sample have current RHS-approved rents that are far too low to support the long-term costs of operation while continuing to make mortgage payments on their Section 515 loans." While the program does provide decent, safe, affordable housing, the report's conculsions show that it will not continue to do so in the near future without changes.

Evidence: "GAO-02-76 Comparing the Characteristics and Costs of Housing Programs. GAO-02-392 Multifamily Rural Housing: Prepayment Potential and Long-Term Rehabilitation Needs for Section 515 Properties. OIG doesn't issue one report, but conducts a series of audits of MFH programs. November 2004 Comprehensive Property Assessment "