4-1 SUBMISSION ANNUAL ADMIN PLAN_EXHIBIT 3

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If the case involves a hardship for a particular family, statement of the circumstances and discussion of possible alternatives; If the case involves a public official or member of the governing body, explanation of his/her duties under state or local law, including reference to any responsibilities involving the HCV program; If the case involves employment of a family member by the PHA or assistance under the HCV program for an eligible PHA employee, explanation of the responsibilities and duties of the position, including any related to the HCV program; If the case involves an investment on the part of a member, officer, or employee of the PHA, description of the nature of the investment, including disclosure/divestiture plans. Where the PHA has requested a conflict of interest waiver, the PHA may not execute the HAP contract until HUD has made a decision on the waiver request. SAHA Policy In considering whether to request a conflict of interest waiver from HUD, SAHA will consider factors the reasons for waiving the requirement; consistency with state and local laws; the existence of alternative housing available to families; the individual circumstances of a particular family; the specific duties of individuals whose positions present a possible conflict of interest; the nature of any financial investment in the property and plans for disclosure/divestiture; and the possible appearance of impropriety. Owner Actions That May Result in Disapproval of a Tenancy Request \[24 CFR 982.306(c)\] HUD regulations permit the PHA to disapprove a request for tenancy for various actions and inactions of the owner. If the PHA disapproves a request for tenancy because an owner is not qualified, it may not terminate the HA properties unless the owner has violated the HAP contract for those units \[HCV GB p. 11-4\]. SAHA Policy SAHA will refuse to approve a request for tenancy if SAHA becomes aware that any of the following are true: The owner has violated obligations under a HAP contract under Section 8 of the 1937 Act (42 U.S.C. 1437f); The owner has committed fraud, bribery or any other corrupt or criminal act in connection with any federal housing program; The owner has engaged in any drug-related criminal activity or any violent criminal activity; The owner has a history or practice of non-compliance with HQS for units leased under the tenant-based programs, or with applicable housing standards for units leased with project-based Section 8 assistance or leased under any other federal housing program; The owner has a history or practice of failing to terminate tenancy of tenants of units assisted under Section 8 or any other federally assisted housing program for activity Page 13-6 04/01/14