cityhousing hamilton march 4, 2010 page 1 operational review report...

CityHousing Hamilton March 4, 2010 Operational Review Report For

CityHousing Hamilton Date of Review:

Completed by: SHS Consulting in association with Refact Consulting, for

Ron Wilson, Housing Officer

City of Hamilton, Housing Division 71 Main Street West Hamilton, Ontario, L8P 4Y5 Phone: (905) 540-6285 In Attendance: At the administration office (55 Hess St. / 191 Main St.):

For SHS consulting:

November 5, 2009, Ed Starr, Cassandra Vink, and Johanna Hashim, Alex Siniakov

November 6, 2009, Cassandra Vink and Johanna Hashim

November 9, 2009, Cassandra Vink, Johanna Hashim and Adene Kuchera

November 10, 2009, Johanna Hashim and Adene Kuchera

November 17, 2009, Johanna Hashim and Adene Kuchera At the buildings reviewed:

For SHS consulting: Ed Starr and Johanna Hashim

November 9, 2009: 155 Park – The Martinique: Dave Chambers (Property Manager) and Kevin Johnson (Custodian), 20 Congress – Pine Grove Place: Chris Saunders (custodian), 2 Oriole Crescent #104: Neil Johnson (Property Manager)

November 10, 2009: 500 McNab North: Donna Kirchnoph (Property Manager), 10 Brock Street #3 and #7 Donna Kirchnoph (Property Manager)

November 11, 2009: 95 Hess: Andy (Custodian), 120 Strathcona – Strathcona Gardens: Jacqueline Rosettani (Property Manager), 66 Greendale #25: Dave Pangborn (Property Manager)

CHH Board Meeting March 10, 2010 Report #10011, Appendix C

CityHousing Hamilton March 4, 2010 Municipal Freedom of Information and Protection of Privacy Act: Please note that this report may include information which is protected under the Freedom of Information and Protection of Privacy Act. No private information contained in this report should be released without the written consent of the individual to whom the information relates. Disclaimer: The purpose of this operational review is to assist CityHousing Hamilton in meeting the requirements of a Local Housing Corporation and their responsibilities under the Social Housing Reform Act, 2000 (SHRA). This report does not provide a complete statement of issues and concerns arising from the operation of the housing portfolio which is the subject of this report. This report is not intended to be relied upon by any third party. The City of Hamilton, its employees, consultants and agents are not liable for any injury or damage (including death), property loss, damage, costs or expenses sustained by or claims or actions against CityHousing Hamilton, its directors, officers, employees, independent contractors, residents, members or any other third party, which may arise directly or indirectly from oral or written statements made by the City of Hamilton, its employees, consultants or agents as a result of the operational review conducted by the City of Hamilton. CityHousing Hamilton is advised to take all steps which may be needed to satisfy itself as to its compliance with the City of Hamilton’s requirements under the program and at law.


CityHousing Hamilton March 4, 2010 1.0 GENERAL INFORMATION

1.1 PROJECT DESCRIPTION

The total portfolio consists of:

Project Name Address Municipality # of Units Program

Municipal Non-Profit Housing

Broadway 101 Broadway Ave Hamilton 45 Federal-Provincial

Gageview Place 1285 Upper Gage Ave Hamilton 13 Federal-Provincial

King St. E 1781 King St E Hamilton 18 Federal-Provincial

Limeridge E Rd 1150 Limeridge Rd E Hamilton 66 Federal-Provincial

Limeridge E Rd 580 Limeridge Rd E Hamilton 65 Federal-Provincial

Oakwood Mews 25 Towercrest Dr Hamilton 64 Federal-Provincial

Stone Chuch Rd. 470 Stone Church Rd E Hamilton 70 Federal-Provincial

The Crofts of McClure 1884, 1900 Main St W Hamilton 158 Federal-Provincial

PH 1 - Wentworth St N 75 Wentworth St N (40 Apts), 96-110 Ashley St (8 Th), 89, 93 Century St (2 Th)

Hamilton 47 Federal-Provincial

PH 2 - Wentworth St. N 75 Wentworth St N (40 Apts), 96-110 Ashley St (8 Th), 89, 93 Century St (2 Th)

Hamilton 3 Federal-Provincial

Brock St. 10 Brock St Hamilton 10 Provincial

Cumberland Gage 430 Cumberland Ave Hamilton 152 Provincial

Lillian Heights 67 Ossington Dr Hamilton 20 Provincial

Rymal Court 1081 Rymal Rd E Hamilton 23 Provincial

Wave 1 - The Trenholm 1100 Limeridge Rd E Hamilton 57 Provincial

Upper Paradise Rd 772 Upper Paradise Rd Hamilton 47 Municipal Non-Profit

Total Municipal Non-Profit 858

Hamilton Portuguese Non-Profit Housing / Hamilton Portuguese Community Homes

Villa Corvo - Gurnett Drive

7, 11, 15, 19, 23 Gurnett Dr Hamilton 5 Federal-Provincial

Villa Santa Maria 680 Stone Church Rd W Hamilton 65 Federal-Provincial

Villa Sao Miguel 170 East Ave S Hamilton 46 Federal-Provincial

Hamilton Portuguese Community Homes

690-700 Stonechurch Rd W Hamilton 45 Sec. 95 Private Non-Profit

(Federal)

Issue: The Building Selection Form for Access to Housing does not accurately reflect all of the units in CityHousing Hamilton’s portfolio.


CityHousing Hamilton March 4, 2010


Total Hamilton Portuguese Non-Profit Housing 161

Dundas Valley Non-Profit Housing

Motherwell Mills 122-132 Hatt St Dundas 34 Federal-Provincial

Sherwood Place 25 Lynden Ave Dundas 40 Municipal Non-Profit

Total Dundas Valley Non-Profit Housing 74

City of Hamilton Properties

Roxorough Park 1,3,6,22,23,26 / Bernard St./ Eaton Pl/ Airdrie Ave/ Bingham Rd

Hamilton C 173 Federal-Provincial

Roxorough Park 100-106 (Even) Lang St. Hamilton C 91 Federal-Provincial

Bernard / Britania 35,37(Odd),59 Bernard St./685,689-695 (Odd),699 Britannia Ave


Saint Andrews Dr 10 St. Andrews Drive Hamilton C 96 Public Housing

Kenora Ave 245 Kenora Avenue Hamilton C 168 Public Housing

Congress Crescent 20 Congress Crescent Hamilton C 110 Public Housing

Congress Crescent 30 Congress Crescent Hamilton C 110 Public Housing

Mt. Albion / Congress Crescent

50 Congress Crescent Hamilton C 53 Public Housing

Queenston Road 555 Queenston Road Hamilton C 200 Public Housing

Scattered Units 11 Holton Ave N, Balsam St S, Brucedale Ave E, Walmer Rd,

Hamilton C 18 Private

Hamilton OH 9 (scattered units)

29-41 Bingham Rd/ 34,36,44 Martha St S./Roxborough

Hamilton C 69 Public Housing

Oriole Crescent 1 & 2 Oriole Crescent Hamilton C 159 Public Housing

Stoney Creek OH 1 5 Maple Ave. Stoney Creek 43 Public Housing

Stoney Creek OH 6 10,12 Jotland Ct./ Markham Cres/ Arbut Cres.

Stoney Creek 17 Public Housing

Stoney Creek OH 3 12 Mellenby St./ Odessa St./ Rand St./William Johnson St

Stoney Creek 23 Public Housing

Catherine St. North 385,387,405,523 Catherine Street North


Osler Drive 104 Osler Drive Dundas 29 Public Housing

Sanford / Aikman Sts 30 Sanford Ave. South Hamilton C 350 Public Housing

Main & Hess 191 Main St. W, 200 Jackson St W Hamilton C 462 Public Housing

James Street North 4-10 (Even) Picton St. West/ James St. North






2-36 (Ev) Strachan St W/Macnab St N/ Ferrie W/James St N


Martinique 155 Park Street South Hamilton C 375 Public Housing

Rebecca St. 226 Rebecca St Hamilton C 199 Public Housing

Kenneth Soble Towers 500 Macnab St. North Hamilton C 146 Public Housing

Jackson / Hess 95 Hess St, 181 Jackson St W Hamilton C 555 Public Housing

Governors Road 249 Governors Rd. Dundas 25 Public Housing

Florence 120 Strathcona Ave N Hamilton C 259 Public Housing

Mohawk Gardens 17,18,19,20 Seeley Ave./East 23rd St./ East 24rd St./East 25st St./East 21st St./East 22st

Hamilton C 84

Federal-Provincial

Fiddlers Green Road 109 Fiddlers Green Rd Ancaster 45 Public Housing

Purnell Drive 77 Purnell Dr Hamilton C 131 Public Housing

Quindale Gardens (scattered units)

11, 28 Rainham St/ Queen Victoria Dr/ Quinlan Ct/ Queenslea Dr/ Raleigh Ct


Upper Ottawa St. 980 Upper Ottawa St Hamilton C 57 Public Housing

Cranbrook / Greendale 149-175 (Odd) Cranbrook Dr / Greendale Dr


Locheed / Limeridge Rd. 1111, 1115-1129 (Odd) Limeridge Rd E/ Locheed Dr



11, 66, 83 Locheed Dr/ Birchview Dr/ Limeridge Rd/ Carson Dr/


Limeridge Rd / Elgar Ave

350-362 (Even) Limeridge Rd / Elgar Ave



1, 3, 5, 19, 20 Banff Dr/ Austin Dr. Hamilton C 86 Public Housing

Bobolink Rd /Millwood Place

101-145 (Odd) Bobolink Rd/ 4, 6-48 (Even) Millwood Pl


Montcalm Drive 45 Montcalm Dr Hamilton C 76 Public Housing

Macassa Park 60, 92 Macassa Ave Hamilton C 40 Public Housing

Upper Gage Ave 801 Upper Gage Ave Hamilton C 244 Public Housing

Glamis Court 25 Glamis Ct Hamilton C 1 Public Housing

Rexford Drive 209, 211, 230, 232 Rexford Dr Hamilton C 6 Public Housing

Lawfield Manor 12 Lisa Ct / 15, 22, 35, 54 Folkstone Ave/ 39, 62 Lawnhurst Dr





Gourley & Lawfield W 104,140 Lawnhurst Dr / Lester St/ Ling St/ Garrow Dr/ Gondola St


Mohawk Gardens 395 Mohawk Rd E Hamilton C 28 Public Housing

Hamilton Home Project 25 Brewster St/ 51, 91, 64 Berrisfield Cres


Mohawk Gardens 395 Mohawk St E Hamilton C 169 Public Housing

Total City of Hamilton Properties 5,130

First Place Hamilton

Housing HOPE 405 York Blvd Hamilton 60 Provincial

Central & Pilgrim Place 185, 206-210 Jackson St E Hamilton 79 Federal-Provincial

First Place 350 King Street East Hamilton 463 Sec. 27 Non-Profit

(Federal)

Total First Place Hamilton 602

Section 27 Non-Profit

Ada Pritchard Apartments

68 Macassa Avenue Hamilton 45 Sec. 27 Non-Profit

(Federal)

Coronation Park 41 Reid Ave South Hamilton 16 Sec. 27 Non-Profit

(Federal)

Total 61

Total CityHousing Hamilton Portfolio 6,886

The Building Selection Form for Access to Housing lists the projects an applicant can apply for. This list is available on the City’s website. The number of units for the following projects is listed incorrectly:

• 122 Hatt Street: listed as 31, should be 34

• 68-90 Macassa / Upper Sherman: listed as 61, should be 45

• 801 Upper Gage Avenue: listed as 242, should be 244

• 555 Queenston Road: listed as 199, should be 200

• 226 Rebecca Street: listed as 189, should be 199

• 95 Hess Street South: listed as 556, should be 555

• 200 Jackson Street West: listed as 465, should be 462

• 96-110 Ashley, 89-93 Century: listed as 10, should be 8

• 350 King Street East: listed as 85, should be 463

• 425 York Blvd.: listed as 54, should be 60

The following projects were listed on the Building Selection Form but were not in the list of CityHousing Hamilton projects:

• 280 Fiddlers Green Road

• 5 Kendale Court



2.0 CORPORATE REQUIREMENTS

2.1 MEMBERS, OFFICERS and DIRECTORS Section 3 of O. Reg. 339/01 requires that every housing provider be incorporated under one of the prescribed Acts under which non-profit or co-operative corporations are normally incorporated.

The Corporations Information Act requires that a "notice of change" be filed when there is a change of directors/officers and/or a change of their home address. The corporate status should be active, the member/director list should be current and all corporate reporting should be up-to-date.

A list of directors/members was provided by the group and reviewed. The list differs from the list contained in Corporate Search conducted on November 26, 2009, and no “Notice of Change” has been filed since the election of the current directors on April 30, 2007. The last “Notice of Change” was filed on June 7, 2006.

2.2 MINUTES AND MEETINGS

The Corporations Act and The Co-operative Corporations Act require that a minute book be kept and that minutes are properly approved and certified. A minute book is kept for 2006 and electronic versions of the minutes are kept beginning in 2007. The minutes appear to be properly approved and certified.

Issue: Vacancy and unit allocation reports, maintenance reports, and resident relations reports are not reviewed regularly by the Board.

Directive

To meet the requirements of the Corporations Information Act, the Board is directed to file a "notice of change" with the Ministry of Consumer Services.

Issue: The corporate status information filed with the Ministry is not up to date.

Directive

To meet its requirements under the Social Housing Reform Act, CityHousing Hamilton is directed to request that the Building Selection Form posted on the City’s website be updated to correct the discrepancies discussed above, and that CityHousing Hamilton staff regularly review the Building Selection Form to ensure that it matches with CityHousing Hamilton’s portfolio listing.



Minutes were reviewed onsite for the period January 2006 to December 2006. Six Board meetings, including the annual general meeting, were held during that period of time. Five Board meetings, including the annual general meeting, were held during the period January 2007 to December 2007. Seven Board meetings, including the annual general meeting, were held in the period January to December 2008. Seven Board meetings, including the annual general meeting, are scheduled for the period January to December 2009. There is evidence in the minutes that the Board reviews their operations through Board review and approval of:

Y the annual operating budget Y the audited financial statements Y monthly/quarterly financial reports Y the rental arrears report N the vacancy and unit allocation report N the maintenance report

N the resident relations report Y the personnel/staff report

In addition to the reports above, the Board reviews the following reports at most Board meetings:

• List of Unfinished Business

• Financial / Administration Reports, such as Mortgage Renewal Reports

• Real Estate / Capital Works / Property Management Reports, such as Capital Works Summary Reports, Updates on Developments, Proposed Rental Rates Reports

The Social Housing Reform Act, 2000 prohibits the Non-Profit from lending or giving away any project funds (rent received or payments from the City of Hamilton or interest on such payments) or underwrite the repayment of any obligation of a third party. There is no evidence in the minutes that money is loaned or being given away.

Recommendation

It is recommended that the Board review the following reports: the vacancy and unit allocation report at each meeting and the maintenance report, and the resident relations report quarterly.



2.3 ANNUAL GENERAL MEETING An annual general meeting must be held every year as required under the Corporations Act for the purposes of:

• The appointment of an auditor

• Election of directors and appointment of officers

The last Annual General Meeting was held on July 16th, 2009. The appointment of an auditor was confirmed at the last annual general meeting. Election of directors and appointment of officers was not completed at the last annual general meeting. Directors were elected and officers were appointed on April 30, 2007 (which was not the annual general meeting) for a term to expire on November 30, 2010. A new Chief Executive Officer/Secretary was appointed on February 11, 2009.

2.4 QUORUM

According to Bylaw #1, the quorum size is the majority of the elected directors. A quorum was present at all of the meetings reviewed.

No Issues: a quorum was present at all meetings.

Directive

To ensure its responsibilities under the Corporations Act are met, The Board is directed to obtain legal advice to confirm that electing the directors and appointing officers at a meeting other than the annual general meeting is legally binding.

Issue: the directors are elected and officers are appointed at a meeting other than the annual general meeting which may not meet the requirements of the Corporations Act.



2.5 SOCIAL HOUSING REFORM ACT, 2000

REGULATIONS/MANUALS/DIRECTIVES

The review revealed that: N The City of Hamilton Service Agreement has been fully executed and is on

file. Y The City of Hamilton’s Communiqués are available for reference and

filed/stored in a convenient location (They are available for reference on the City of Hamilton’s website)

Y A copy of the Social Housing Reform Act, 2000 and related Regulations are available for reference. (They are available online and in hard copy)

Y The Service Manager’s Guides: Special Needs Housing and Central Waiting List & RGI Assistance are available for reference. There is no Guide to the Operating Framework.

Y Access to Housing policy and procedure information is available for the public’s reference, including the internal review process. (The access to Housing Application Guidelines are available on the City of Hamilton’s website. Information on the internal review process is provided when a decision is made that is eligible for internal review)

And that the following information concerning their housing project is available to the public:

Y The information provided under section 60 of Ontario Regulation 298/01 to the housing provider by the service manager.

The following information is available to the public on the City of Hamilton’s

website: 1. The housing projects within the service manager’s service area and the

housing providers that operate them

2. How to apply for rent-geared-to-income assistance

3. The eligibility criteria for rent-geared-to-income assistance

4. The requirements to be included in the special priority household category

Issues: There is no Service Agreement or Shareholders Agreement with the City of Hamilton. There are no written policies and procedures for internal transfers and internal reviews.



4.1 The requirements to be included in the categories established by the service manager under local priority rules and ranking rules for these categories.

6. The requirements relating to waiting lists.

7. The geographic areas into which the service manager has divided its service area for the purposes of its centralized waiting list

12. The mandates, established under section 99 of the Act, of each housing provider that operates a housing project within the service manager’s service area

The following information was confirmed to be available elsewhere:

5. The provincial and local occupancy standards in force within the service manager’s service area. (In the lease)

8. The rules and procedures in respect of the transfer of households to a unit in a housing project operated by a different housing provider. (In the lease and the Community Relations Worker provides this information to interested tenants)

9. The type of decisions of the service manager that are subject to internal review. (In the letter provided when a decision has been made that is subject to internal review)

9.1 The rules and procedures of the service manager in respect of the internal review of decisions. (In the letter provided when a decision has been made that is subject to internal review)

9.2 The rules and procedures of the service manager in respect of the opportunity for members of the household to comment on information that may form a significant basis for a decision that is adverse to the household. (In the letter provided when a decision has been made that is subject to internal review)

Some information was not reviewed as it relates most directly to Access to Housing, and the City of Hamilton determined that they are beyond the scope of this review.

Y Information concerning the types and sizes of units in its housing project. (On the City of Hamilton’s website) N The housing provider’s policies and procedures for internal transfers

(Information on internal transfers is provided to interested tenants by the Community Relations Worker. No written policies and procedures are currently in use. A draft internal transfer policy was developed in April 2005.)

Partial The housing provider’s procedures for internal reviews under section 20, O.Reg.339/01,s.9(1). (Internal review procedures are explained verbally



originally and then explained in the letter provided when a decision is subject to an internal review. No written procedures are currently in use.)

Y Members of the public are allowed to make copies of the information at their own expense. O.Reg.339/01,s.9(2). (Staff indicated they would make copies of the information for anyone who is interested.)

3.0 CONFLICT OF INTEREST

3.1 CONFLICT OF INTEREST BYLAW

Section 4 (2) of O. Reg. 339/01 states that:

Conflict of interest is defined by the regulation as a situation in which: 1. The personal or business interests of a director, officer, agent or employee of a housing

provider are in conflict with the interests of the housing provider. 2. A personal gain, benefit, advantage or privilege is directly or indirectly given to or received by

a director, officer, agent or employee of a housing provider, or a person related to one of them, as a result of a decision by the housing provider.

The Act requires that housing providers implement a conflict of interest policy/bylaw that is consistent with this directive. Policies in this directive may be reflected in a Conflict of Interest by-law, or a Code of Conduct By-Law, or a Spending/Financial By-Law.

The Conflict of Interest provisions of the bylaw approved by the Board, as well as the City of Hamilton’s Conflict of Interest Policy for staff, were reviewed. The bylaw(s) meets all requirements of the Social Housing Reform Act, 2000. In addition, a conflict of interest declaration is a standing item on each agenda.

No Issues: The Board has a Conflict of Interest provision in its by-laws and staff have a Conflict of Interest Policy.

Recommendation

It is recommended that the Board execute a Service Agreement and Shareholders Agreement with the City of Hamilton. It is recommended that the Board ensure that written policies and procedures are developed and followed for internal transfers and internal reviews.



3.2 IDENTIFIED CONFLICT(S) OF INTEREST

There was one known conflict of interest identified in the Board minutes reviewed; and was appropriately disclosed and resolved.

4.0 PROPERTY MANAGEMENT

The Social Housing Reform Act, 2000 Part VI and Section 8 of O. Reg. 339/01 requires that the housing provider follow an open and competitive selection process in hiring employees or engaging a property management company to manage its housing projects.

Sections 4.1 and 4.2 apply to groups using a Property Management Firm. They have been deleted as they are not applicable to CityHousing Hamilton.

4.3 EMPLOYEE CONTRACTS

Copies of the current job descriptions and collective agreements were reviewed. CityHousing Hamilton, through the City of Hamilton, has established Human Resources policies regarding hiring, discipline, benefits, record keeping, termination, regular performance reviews, etc. The City’s solicitor has previously reviewed the contracts to ensure compliance with all applicable laws. Recent contracts have been based on the original version that was reviewed by the solicitor.

Job descriptions have been developed for the following positions:

• Administrative Assistant

• Capital Works Administrative Coordinator

Issues: Although almost all positions have undergone job evaluations in the last few years, most job descriptions have not been updated recently

Job descriptions are not signed by the Chief Executive Officer or designate

The vast majority of performance appraisals are not being conducted annually according to City policy. Succession plans have not been prepared for managerial positions.

No Issues: Any conflict of interests identified have been appropriately disclosed and resolved.



• Community Development Coordinator – Housing

• Community Relations Worker – Housing

• Custodian

• Family Support Worker

• Grounds person – Housing

• Housing Energy Projects Coordinator

• Housing Operations Administrative Assistant

• Housing Programs Officer

• Maintenance Repair Person – Housing

• Manager, Housing Technical Services

• Manager, Operations – Housing

• Manager, Tenant Support Services – Housing

• On-Site Support Worker (ROOFS Program)

• Paralegal – Housing

• Program Manager, Housing Development and Partnerships

• Promotional Marketing Officer

• Property Manager – Housing

• Property Management Assistant

• Public Health Nurse

• Receptionist / Clerk – Housing

• Recreation Assistant – Housing

• Security Tenant

• Senior Policy Analyst – Housing Development and Partnerships

• Senior Policy Analyst – Policy and Program Development

• Specifications Writer / Contract Administrator – Housing

• Tenant Placement Representative – Housing

• Yardi Application Specialist

• Housing Loans Officer

• Home Management Worker



The Property Management Support Officer position does not have a job description. The person filling this position is still listed as a Property Manager and doing property management duties. The duties and position of the Property Management Support Officer is still in the development process.

Each job description is part of a job posting to fill that position and has the date of posting but is not signed by the Chief Executive Officer or delegate. Some job descriptions were posted in 2002 and have not been updated recently. More recent changes in legislation may have an impact on the duties performed by specific staff. Almost all positions have undergone job evaluations in the last few years. A City of Hamilton Performance Management and Appraisal Policy has been implemented and this policy applies to all City employees. The purpose of this process is to align employee performance with the strategic plan and developmental goals and objectives of the City. The appraisal is to be conducted at least once every twelve months and is mandatory for annual progressive salary increases.

A Performance Appraisal spreadsheet was developed and this listed all full-time and part-time employees. This spreadsheet listed 110 staff in the Housing Division. As of July 16, 2009, only four appraisals have been listed as complete. The main reason given for not completing a performance appraisal was workload pressures. A number of training opportunities have been scheduled to support management training and staff have been directed to consider the “Specialized Performance Appraisal Basics for Managers” as a mandatory training course for Property Managers and staff. Succession plans have not been prepared for managerial positions.

Recommendation

It is recommended that the Board ensure that policies are in place and followed to ensure:

• That all job descriptions are updated to reflect changes in legislation and any changes arising from this Operational Review.

• That all job descriptions are signed by the Chief Executive Officer or designate within a reasonable time of the document being prepared.

• That performance appraisals are conducted annually, in keeping with the City’s policy, together with the preparation of a learning plan for all staff. The achievement of performance appraisals and learning plans should be an item each manager is graded on in their performance appraisal.

Recommendation

It is recommended that succession plans are prepared for each managerial position and a succession policy is prepared for all positions.



4.4 COMPETITIVE PROCESS

Hiring is to be documented, open, and competitive.

Human Resources staff confirmed that all staff hired in the past year (excluding for First Place) were selected after a documented, fair, open, competitive process. Documentation relevant to the hiring was not available for review.

5.0 FINANCIAL REVIEW

5.1 AUDITOR’S MANAGEMENT LETTER RECOMMENDATIONS

Auditor’s Management Letter Issues and Recommendations

Year Issues and Recommendations

2008 • Journal entries: currently the Business Administrator has the ability to create and approve journal entries. It was recommended that the two functions be separated and have a restricted access in the Yardi system. The functions have been separated, journal entries are only created by the FA1's/ Finance Officer and approved by the Business Administrator. The Business Administrator does not create any journals. The Yardi system has not been changed to reflect this restriction.

• Software updates: there was an issue of financial reports being inconsistent (non balancing accounts). Resolving such issue proved to be difficult since technical staff have problems working with outdated software. It was recommended that management weigh the cost and benefit of updating YARDI software. Staff are currently developing specifications for new software.

• Tenant collections: the audit turned up a problem of collecting rents from certain tenants. Account balances indicated slow rent collection and lack of any consequences for failure to pay rent. It was recommended that the management reviews rent collection policies including any consequences for failure to pay rent. An Enhanced Rent Collection policy and Persistent Late Policy was approved by the Board July 16, 2009.

Issue: Existing software is not meeting the needs of the corporation.

No Issues: With the exception of First Place, staff have been hired in a documented, open, and competitive process.



2007 • Only a Draft Management Representation Letter could be located. No other documents outlining deficiencies and/or recommendations could be located. The draft letter indicated that during the course of performing the audit, they did not identify any reportable weaknesses in internal control.

2006 • Unreconciled bank account: the auditor identified a weakness in internal control related to operating bank account which was unreconciled for most of 2006, the amount was roughly $20,000. The auditor notes that timely reconciliations are necessary to detect errors and omissions as early as possible. Management responded by investigating the issue of unreconciled bank account and has stated that it will continue its practice of monthly bank account reconciliation and review and will monitor such practice more closely.

• Rent revenue adjustments: there was an inconsistent practice of rent revenue adjustments by the outsourced property manager compared to the directly managed properties. The time it takes to process the applications and make the necessary adjustments differed between the two types of properties, subsequently affecting the timing of adjusting subsidy. It was recommended that management look into the cost and benefit of implementing controls which will consistently apply the same policy to all of its properties. All properties are now directly managed.

5.2 SUBSIDY ESTIMATES

The operating agreements which established the funding obligations of the funder are terminated at the point of transfer for all non-profit and cooperative projects previously funded by the Ministry of Municipal Affairs and Housing and now being transferred to service managers. Consequently, the

No Issues: Budget estimates were provided for the Local Housing Corporation portion of the portfolio ninety days prior to the beginning of their fiscal year. On receipt of the approved subsidy from the City of Hamilton, the Board reviews and revises their annual operating budget plan for internal use.

Recommendation

It is recommended that specifications continue to be developed for new software and the Board move forward with the software update.


CityHousing Hamilton March 4, 2010 detail of the calculation of subsidy is set out in the SHRA, 2000 (Sections 102 to 111) and O. Reg. 339/01(Sections 27 to 34).

CityHousing Hamilton provides estimates for the previous Local Housing Corporation portion of the portfolio as set out in the SHRA, 2000 (Section 105(1)). The budgets for the remainder of the portfolio are benchmarked, and thus budget submissions to the Service Manager are not required. For the years reviewed the group submitted its budget estimates ninety days prior to the beginning of their fiscal year which complies with the New Funding Model. On receipt of the approved subsidy from the City of Hamilton, the Board reviews and revises their annual operating budget plan for internal use.

Summary of Budget Submission Date, and Budget and Subsidy Amount Approved

Year Date Estimates

Submitted Subsidy Amount

Approved Board Approved

Budget

2010 September of 2009 Not Available Not Available

2009 Not Available $27,101,735 $57,295,455

2008 October of 2007 $25,736,561 $55,862,698

5.3 ANNUAL INFORMATION RETURN (A.I.R.) MANAGEMENT REPRESENTATION REPORT

Section 113 of the SHRA, 2000 requires that a housing provider submit an audited statement and an annual report to the service manager. If a housing provider fails to give the service manager its annual report in accordance with this section, section 113(9) of the Act allows the service manager to reduce the amount of subsidy payments.

The group submitted the 2008A.I.R. to the City of Hamilton October 1, 2009, ten months after their fiscal year end. It was not submitted within five months of their fiscal year end as required by the Social Housing Reform Act, 2000, Part VI, Section 113.

The Management Representation Report for the 2008 A.I.R. indicated: the corporation did not receive a management letter from its auditors reporting deficiencies in internal controls or operations. This appears to be in contradiction to our review of the financial statements which included an auditor’s management letter.

Issue: The 2008 A.I.R. was not submitted within five months of the corporation’s fiscal year end.



5.4 FINANCIAL REPORTS

Financial reports are provided to the Board at every Board meeting on a bi-monthly basis.

Overview of Financial Variance Reports, 2007 to 2009

Date Year-to-date

Spending Forecasted Year-

end Spending Variance from

Approved Budget

February 19, 2007 $52,629,065 $52,496,107 -$132,958

April 23, 2007 $8,960,930 $53,765,578 $51,732

June 25, 2007 $17,932,791 $53,798,374 $18,936

September 17, 2007 $26,967,618 $53,935,233 -$117,923

November 5, 2007 $36,043,791 $54,065,688 -$248,378

December 10, 2007 No report, Board meeting cancelled

February 28, 2008 Report not found

April 17, 2008 Report not found

June 19, 2008 $18,489,068 $55,557,225 $305,472

September 18, 2008 $27,015,871 $55,425,553 $437,144

November 27, 2008 Report not found

February 11, 2009 $27,050,360 $55,595,006 $267,691

July 16, 2009 $22,659,859 $57,393,095 -$97,640

September 16, 2009 $34,472,111 $57,504,715 -$209,263

The variances found in the bi-monthly financial reports between the spending and the

approved annual budgets reviewed are moderate. While the by-monthly reports show modest variances to the budget, the financial position at the end of the year shows a materially larger deficit (discussed further in Section 5.12, below). As mentioned, the Appendix spreadsheet to the bi-monthly financial report for November 5, 2007 shows a $248,378 variance from the

Issue: There have been some occasions where financial reports appear not to have been prepared for the Board meeting.

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that policies and procedures are in place so that audited statements and the annual report are submitted to the service manager within five months of the corporation’s fiscal year end.



approved annual budget, and no report was found for December 10, 2007 and the Board meeting was cancelled. In the absence of a variance report for December, the year end deficit increased to $402,557. For 2008 the bi-monthly financial report from September 18, 2008 shows a $437,144 variance from the approved annual budget and no bi-monthly financial report was found for the meeting on November 27, 2008. The year-end deficit for 2008 was $1,231,760.

Computer Records Computer records are protected with regular computer backup. Incremental backups are completed daily, and full system backups are conducted weekly. Back up files are stored offsite in a secure location.

5.5 REVENUES

Current Tenant Accounts Receivables As of October 31, 2009, arrears of current tenants were $501,131, equivalent to 22.2% of all tenant charges in October 2009. A breakdown of arrears of current tenants by type of charge is shown in the following table:

Arrears of Current Tenants as of October 31, 2009 by Type of Charge

Amount Percentage of All Tenant

Charges in Oct. ‘09

Rent $286,437 12.7%

Misrepresentation $172,983 7.7%

Maintenance $25,675 1.1%

Miscellaneous $16,037 0.7%

Total Arrears of Current Tenants $501,131 22.2%

Arrears of current tenants by age of receivable is shown below. Almost half of the arrears are more than 90 days old.

Issue: There have been some occasions where financial reports appear not to have been prepared for the Board meeting.

Recommendation

It is recommended that the Board ensure that financial variance reports be prepared and reviewed by the Board at each meeting.



Arrears of Current Tenants as of October 31, 2009 by Age of Receivable

Total 31-60 days 60 to 90 days More than 90

days old

Amount $501,131 (678 households)

$196, 368 $83,194 $231,466

Percentage 100% 39% 17% 46%

Rent arrears of 12.7% in October 2009 are substantially lower than the 20.5% in October 2008, but higher than the 9.2% in October 2007. Rent arrears from January 2009 to the end of September 2009 have slight variances from the figures for the same period in 2008, but in general are relatively similar. Arrears in both 2008 and 2009 have trended higher than in 2007.

Accounts Receivables by Project Manager Rent arrears by Project Manager have been reviewed for the ten-month period starting January

2009. Arrears vary significantly both by mandate of the buildings and by Property Manager. The variance among Property Managers managing seniors housing portfolios and those managing the family segment are shown below. Average arrears are much lower in the seniors segment of the portfolio. The largest decreases and increases in rent arrears between January and October for Property Managers managing seniors and family portfolios is also shown.

Accounts Receivables by Property Manager

Property Manager Average Arrears

Largest Change January to October 2009

Lowest Highest Decline Incline

Seniors 0.1% 10.9%. 8.3% to 3.5% 0.7% to 3.0%

Family 9.4% 34.0% 32.4% to 17.0% 1.7% to 22.7%

There are likely a number of reasons for differences in arrears by property manager, though timely reporting to property managers of their level of arrears, use of arrears as a performance indicator for property managers, and annual performance appraisals are important to ensure staff diligence on controlling and securing arrears.

Accounts Receivables and Write-offs From Former Tenants As of October 31, 2009, the outstanding balance on receivables from former tenants is $468,599.

Over the past several years the write-offs have been increasing in dollar amounts but as a percentage of revenue from operations they have decreased somewhat. As mentioned in the 2008 Debt Write-off report, a collections co-ordinator has been hired by CityHousing Hamilton and has proven to be more successful than the previously used collections agency.



For the period July 1, 2008 to December 31, 2008, debt-write off was $231,992 or 1.28% of revenue from operations. This is somewhat higher than their target of 1.0%.

An overview of the write-off amounts for the portion that was direct managed and portion outsourced for 2006 to 2008 is shown below.

Write-offs From Former Tenants

Write-Off Amount Year

Direct Managed Outsourced Total

2008 N/A N/A $685,794

(18 months)

2007 $386,940 $45,860 $432,800

2006 $309,610 $45,525 $355,135

As of November 18, 2009 there were $3,434,210 listed to a collection agency. Recoveries by the collection agency have been just over 16%, further details are provided below.

Accounts From Formers Tenant in Collections

Year Amount

Listed Amount $3,434,210

Returned Amount $6,767

Bankrupt $60,639 Closed

Deceased $8,188

Recoveries $549,034

Percentage Recoveries 16.30%

Accounts Receivable Policies and Procedures According to the draft report to the Board (Enhanced Rent Collection Procedures - dated July 16, 2009), the current eviction policy has been in place since July 1, 2006 and it is believed it has contributed to arrears. Board approval on a more strict and updated policy July 16, 2009, with detailed changes outlined in that report. A policy is in place for rent arrears, former tenant arrears and collection for damages to units.



Internal Controls for Revenues Internal controls for revenues include:

Y pre-number receipts are issued for cash received (Receipts are pre-numbered for cash

and debit transactions, but not for cheques) N cash payments are not formally discouraged whenever possible. Y cash is stored securely and/or deposited frequently (Cash is stored in a safe, and

deposited on close to a daily basis) Y cheques are not cashed from current cash receipts (As confirmed by Ron Wilson) Y cheques are immediately endorsed “for deposit only” (As confirmed by Ron Wilson

and Finance staff) N/A two persons count revenue from coin laundry machines and coins are emptied and

deposited regularly (laundry machines are rented, cards are used in lieu of coins, and vendor is responsible for dealing with revenues)

Y GST filings are completed at least annually (Quarterly) N/A Units are classified correctly on the Annual Information Return (Not verified as City

of Hamilton indicated that they verify that units are classified correctly).

Recommendation

It is recommended that the Board ensure that timely reporting of accounts receivables is provided to Property Managers, and performance appraisals are conducted annually, with arrears being one of the key performance indicators in the evaluation of Project Mangers. It is recommended that the Board establish a policy to discourage cash payments whenever possible.



5.6 VACANCY LOSS

Vacancy losses for the past five years are summarized in the following table.

Vacancy Losses, 2005 to 2009

Year

Units With At Least

One Vacant

Day

Average Number of

Vacant Days

Days Lost Vacant

Revenue Lost

Percent of Potential Revenues

2009 (Nine Months) 341 86 29,317 $382,131 N/A

2008 462 75 34,794 $475,275 1.60%

2007 456 59 27,081 $369,347 1.30%

2006 470 57 26,732 $402,949 1.40%

2005 439 72 31,769 $454,759 N/A

Vacancy figures tend to fluctuate, initially decreasing between 2005 and 2007, and then significantly increasing in 2008 and almost going back to original levels. The average length of vacancy has been increasing since 2006. Reasons for the high vacancy losses in 2009 include staff illness and units on hold and not available for rent. Units have been on hold as a result of bedbug infestations at two locations, elevator maintenance at one location (81 units), and delamination/asbestos removal renovations at one location (35 units). There is no reporting on vacancy loss and limited accountability for managing vacancy losses as no performance standards exist among Property Managers and Tenant Placement staff for managing losses. Another concern raised by informants is the curb appeal of some of the properties.

Recommendation

It is recommended that the Board direct staff to conduct an analysis of turnover time to determine the reasons for the length of the vacancies and strategies for reducing the turnover time.

Issue: The turnover times following a vacancy have been increasing.



5.7 INSURANCE

The group is currently insured with a group insurance company as required by SHRA, 2000. Insurance is provided by Aon Reed Stenhouse Inc. under the Social Housing Services Corporation Insurance Program, and expires on November 1, 2010. Terms listed in the Certificate of Insurance outline a comprehensive coverage of property damage, loss of business revenue, breakdown of machinery, commercial general liability, crime, personal injury, etc.

Diana Belaisis, Manager, Employment Services, Human Resources Division confirmed they are using a system to report accidents to WSIB. We were unable to verify the system for reporting other incidents (for example, accidents, emergencies, vandalism).

5.8 BANK STATEMENT REVIEW

Bank statements for the period January to September 2009 were reviewed for the following.

Y bank balance is reconciled monthly. Y reconciliations are reviewed by an alternate person (Reconciliations for the two most

recent months have been reviewed by an alternate person (Business Administrator), though previously several months were not reviewed by an alternate person. However, there has been a number of turnovers in both the Business Administrator and person responsible for preparing the reconciliations over the period. The procedure appears to be being kept by current staff.)

Y mortgage payments were made on time (Preauthorized) Y municipal taxes are current (Taxes are recorded by the city and funds are transferred

from the group to the City at the end of the month) Y utilities are paid within discount periods (There are no discount periods, but penalties

for late payment. Utilities are paid prior to the penalty period)

No Issues: The group has insurance coverage as required by the SHRA and is using a system to report accidents to WSIB.

No Issues: The group has insurance coverage as required by the SHRA and is using a system to report accidents to WSIB.



5.9 DISBURSEMENTS

Internal controls for disbursements include:

Y written purchasing policies exist and are consistently followed (Written purchasing policy document exists outlining various policies and procedures such as maintaining and updating vendor list, pre-qualifying acceptable bidders, delegation of authority on purchases of material amount, etc.)

Y three written quotations are obtained for goods/services costing from $5,000 to $49,999 and the lowest bids are accepted

Y a public or pre-qualified tender or invitational (minimum three invitations) is held for goods/services costing over $50,000

Y there are board approved signing authorities and spending limits in place (Depending on the purchasing amount, various levels of approval are necessary. For purchases greater than $250,000, Council approval is required. For purchases greater than $100,000, City Manager approval is required, etc.)

Y cheques and supporting invoices/documentation are reviewed by a board member and signed by two authorized signing authorities (Signing of cheques has been delegated to signing officers for the Corporation)

Y cheques are not signed in advance Y all cheques are pre-numbered Y voided cheques are maintained on file N/A appropriate payroll remittances are being made to Revenue Canada (Payroll

remittances are made through the City of Hamilton, and the process was not verified)

CityHousing Hamilton Staff regularly conduct petty cash reconciliations. There is currently one CityHousing Hamilton staff person with a corporate credit card. The credit card payments are reconciled monthly. No payments are made to directors, except in the case of reimbursement of expenses related to attendance of the Ontario Non Profit Housing Association Conference.

Upon reviewing Accounts Payable Aging Summary for 2008, it is evident that majority of all bills are paid off quickly. Approximately 67% are paid within 30 days, and another 27% in the 30 days to follow, leaving only 6% still payable after 60 days. This is an improvement over the previous year where 64% were paid within 30 days, another 24% in the 30 days to follow, and 12% still payable after 60 days.

No Issues: The group has internal controls in place for disbursements.



5.10 NON-SHELTER AGREEMENTS

The non-shelter space in this portfolio is as follows: Non-shelter space agreements have been reviewed for the following spaces:

Leasee Space Size Rent Expiry

Evi's Super Store Deli

Main Hess Mall, 191 Main

St

690.85 square feet

6,300/year, utilities paid separately

month to month

Nino’s Restaurant (1782956 Ontario Inc. (Marta Buffa)

Unit 102, 162 King William

St

$11 +GST per square foot

June 2011, certificate of

insurance on file is current

Safin Grill Ltd. 95 King St. E 262 square feet $525

month to month lease with 3

months written notice

Alliance Computers

211 King St. E 2,100 square feet $27,300 and $.25 per square foot

increase per year Feb. 28 2014

Non-shelter space agreements were not available for the following spaces:

Leasee Space

Shoppers Drug Mart Main Hess Mall, 191 Main St

Hair Dresser Unit 102, 162 King William St

Career Development Centre

3rd Floor, 191 Main St.)

Youth Transitional Housing

4th and 5th Floor and office on 6th Floor, 191 Main St. (apparently have agreement for 4th and 5th floor, but not 6th)

Social Planning Research Council

162 King William St

Good Shepherd 500 MacNab

Brain Injury Services 30 Stanford

Issues: Formal agreements are not in place for all non-shelter space in the portfolio, and the expiry of the agreements and supporting documentation such as insurance certificates is not monitored, and documents are not kept in a central location.



The non-shelter space at the following locations are vacant:

• 95 King St. � The space has mold issues and cannot be rented and would require renovations

to make it rentable. CityHousing Hamilton is planning to develop this building as Live/work for Artists and the planning is underway and the building won't be finished (rentable) until early 2011.

• 89 King St, (1,775 square feet)

� The space was listed "to lease" on MLS network by a local Real Estate company. The real estate company were given the phone numbers of people who had called to potentially rent this space but there have been no serious written offer to rent. There has been interest from Fast food restaurant however the Board of Directors have been hesitant to rent the space for fast food operation due to noise and smell issues and to some extent they would prefer another retail use. Hamilton tourism were also contacted but they were not interested as they may be locating elsewhere. Currently there is possible interest to rent to a Cultural/Artist entity. The space was listed a triple net lease for about $15.00 per square foot depending upon the extent of the leasehold improvements negotiated. Current vacancies at 89 King St. could result in a deficit of $26,625 for the group.

There is not a signed non-shelter agreement with the City of Hamilton for use of a portion of the 23rd Floor at 55 Hess St. and 3rd floor of 191 Main which sets out the terms of the cost sharing arrangements with the City of Hamilton.

Recommendation

It is recommended that the Board enter into formal agreements for all non-shelter space in the portfolio, including a formal agreement with the City of Hamilton for use of a portion of the 23rd Floor at 55 Hess St, and monitor the expiry of the agreements and supporting documentation such as insurance certificates, and keep the documents in a central location.



5.11 CAPITAL RESERVE FUND

Section 93 (2) (f) of the SHRA, 2000 states that the duties of a housing provider include: The housing provider’s participation in a system for the pooling capital reserves for investment purposes. Section 26 (2) of O. Reg.339/01: The housing provider shall participate in a system for pooling capital reserves for investment purposes and shall follow such investment policies referred to in that clause as may be established by the Social Housing Services Corporation. The Social Housing Services Corporation Financial has set December 31, 2003 as the deadline for housing providers to invest all their funds in their capital reserves.

CityHousing Hamilton’s Municipal Non-Profit housing units are required to participate in the system of pooling capital reserves for investment purposes. The capital reserve fund account related to these units has been correctly established and used. The former Local Housing Corporation Units are not required to establish a capital reserve fund. The Capital Repair Program for the CityHousing Hamilton portfolio is being funded annually through the operating budget as approved by the Board of Directors in 2002. For the year 2009, the Capital Budget was approved by the Board in the amount $9,750,000. The balance of the Capital Reserve fund prior to any expenditures was $16,685,509 which includes a budgeted contribution of $7,133,840. After expenditures it is anticipated that the Capital Reserve fund will have funds of $6,935,509. CityHousing Hamilton is only required by the Province to contribute approximately $6.2 million to the Capital Reserve. A Capital Works Expenditure summary has been reviewed and given the year-to-date total expenditures (as of October 26, 2009), the revised capital budget is slightly under the initially budgeted amount of $9,750,000. All recorded expenditures appear to be appropriately categorized as capital expenditures.

Issues: A capital reserve account has not been set up with Phillips, Hager & North for the Portuguese Non-Profit portion of the portfolio, (though accounts have been set up with for Municipal Non-Profit (Hamilton) and Dundas Valley Non-Profit).

The following items are not up to date and being utilized for capital planning: Building Condition Audits, Energy Audits, a long term Capital Plan, and a Capital Reserve fund study.



However, it should be noted that to address the projected operating deficit in 2009, the Board decided to fund some maintenance requirements of a capital nature from the 2009 capital budget. Also, as a further response to address the operating budget deficit for 2009, a Board report from November 25, 2009 indicates one of the options being considered is to fund an additional $500,000 in maintenance requirements of a capital nature from the 2009 capital budget, including complete unit retrofits, full building bed bug treatments, flooring and boilers. Some of these expenditures, such as full building bed bug treatments, do not appear to be eligible capital expenditures under the current definition. Another option being considered to address the operating budget deficit for 2009 is to reduce the 2009 annual capital reserve allocation by $500,000 from $7,133,840 to $6,633,840.

The full amount of the reserve fund is invested with Phillips, Hager & North (PH&N) for only a one year timeframe upon renewal and placed in instruments in accordance with the SHRA, 2000.

The Capital Reserve Balance as of September 30, 2009 for each portion of the municipal non-profit units is provided below.

Capital Reserve Fund Balance as of Sept. 30,

2009

Balance

Municipal Non-Profit (Hamilton) $3,725,473

Dundas Valley Non-Profit $417,240

Portuguese Non-Profit $37,945*

*As of Dec. 31, 2009

Accounts have been set up with Phillips, Hager & North for Municipal Non-Profit (Hamilton) and Dundas Valley Non-Profit but not yet for Portuguese Non-Profit. The allocation of funds to specific investment products is as follows:

Capital Reserve Fund Asset Allocation, as of Sept. 30,

2009

Asset Class

Municipal Non-Profit (Hamilton)

Dundas Valley Non-

Profit

Cash & Short Term 20% 20%

Fixed Income 53% 53%

Canadian Income 18% 18%

International Equity 4% 4%

U.S. Equity 5% 5%



The Corporation does not have up to date Building Condition Audits which are important inputs into capital planning. Further, the Corporation does not have a multi-year Capital Plan that they are following for capital purchases, replacements, etc.

5.12 FINANCIAL POSITION

As of December 31st, 2008 the corporation has an accumulated surplus of $671,936 after experiencing a deficit for the year. The initial balance at the beginning of 2008 was $2,532,490 (see the following table for further details). The balance at the beginning of 2007 was $2,988,070 and in 2006 was $2,590,653.

Issues: The corporation had a deficit in 2007 and 2008 and was projecting a deficit for 2009 as of September 30, 2009, through activities have been proposed to mitigate the deficit and a number of them have been implemented

Concerns have been raised about the past process of establishing Operating Budgets such as timing, and appropriate input from all relevant parties.

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that a capital reserve account has been set up with Phillips, Hager & North for the Portuguese Non-Profit portion of the portfolio.

Recommendation It is strongly recommended that the Corporation conduct Building Condition Audits, Energy Audits, and prepare a Capital Plan in conjunction with a reserve fund study. Moving forward, it is strongly recommended that the Board ensure that there are sufficient capital funds, (by conducting Building Condition Audits, a long term capital plan and updating the replacement reserve study), prior to reducing Capital Reserve fund contributions.



Operating Fund Balance

2006 2007 2008

Total Revenue $52,761,697 $53,920,977 $55,437,890

Allocation to Capital Reserve (-$6,860,764) (-$6,892,214) (-$7,136,720)

Net Revenue $45,900,933 $47,028,763 $48,301,170

Total Expenses (-$45,897,895) (-$47,431,320) (-$49,532,930)

Excess of Revenue over Expenses $3,038 (-$402,557) (-$1,231,760)

Adjustment for amortization of deferred contribution

$68,171 $68,171 $68,171

Reconciliation adjustment $326,208 $187,264 (-$1,987)

SM directed transfer to Capital Reserve $0 (-$308,458) (-$231,832)

Board directed transfer to the City $0 $0 (-$463,146)

Beginning Balance $2,590,653 $2,988,070 $2,532,490

Ending Balance $2,988,070 $2,532,490 $671,936

At the November 25, 2009 Board Meeting the Board received report #09050, which included information on the Operating Budget Variance as at September 30, 2009. At the July 16, 2009 Board meeting, staff were projecting a full year deficit for CHH of $1,498,672. The Board was made aware that staff would pursue a number of specific activities to mitigate the deficit and a number have been implemented as of November 25, 2009, including a more intensive and proactive rent-up strategy to fill vacant units more quickly and reduced expenditures on non health and safety property maintenance. As of September 30, 2009 the forecasted full year deficit is $957,432. The report indicates that financial adjustments to mitigate deficits are typically implemented at fiscal year-end. As mentioned in the Capital Reserve Fund section above, two options have been identified to mitigate the deficit. The first is to reduce the annual capital reserve allocation by $500,000 from $7,133,840 to $6,633,840. CHH is only required by the Province to contribute approximately $6.2 million to the capital reserve. The second option is to fund some maintenance requirements of a capital nature from the 2009 capital budget. An additional $500,000 could be added to the approved 2009 capital budget for operating pressures including complete unit retrofits, full building bed bug treatments, flooring and boilers. Implementation of these two options at year-end 2009 would completely mitigate the forecasted operating deficit and a small surplus would be achieved. There are a number of key reasons behind the currently projected deficit. These include: Revenue

Based on the current trend, operational revenue will be $1,528,603 lower than the budget. This is mainly due to vacancies. Several factors are/(have) contributing/(ed) to vacancy losses including staff illness and units on hold and not available for rent. Units have been on hold as



a result of bedbug infestations at two locations, elevator maintenance at one location (81 units), and delamination/asbestos removal renovations at one location (35 units). Maintenance Costs

Maintenance costs are forecast to be $1,443,178 higher than the budgeted amount. This is with all non health and safety operating expenditures on hold for the remainder of 2009. The components driving the cost of maintenance include general building repairs, plumbing costs, security and grounds maintenance, bed bugs, waste disposal. and delayed capital expenditures. Accounts Receivables/ Arrears

As of September 30, 2009, there were 691 tenants with outstanding rental arrears totaling 413,738 or 13.9% of current month rent revenues. This is well above the target set by staff of 5.0%. Items anticipated to be under budget include: Subsidy

Rent subsidy is anticipated to by $221,373 higher than anticipated due to additional Rent Supplement subsidies. Administration Costs

Administration costs are expected to be below budget by $170,647. Six vacant staff positions with salary and benefit costs of approximately $373,000 are contributing to the lower administration cost, though bad debt (over budget by $152,151), legal costs (over budget by $50,000, which is related to the transition of First Place) and insurance for flooding (non-insured incidents and the $25,000 insurance deductible for the claim for the July 26th flood generated an operating pressure of $87,493) have been higher than anticipated. Utilities

Utility costs are anticipated to be well below budget ($1,559,466 lower than budgeted). The budgeted amount for utilities has been overstated over the past few years (and will be adjusted downwards in 2010). Municipal Taxes

Municipal taxes are $220,529 lower than budgeted. Phase Two of the Operational Review will be recommending steps that we believe would help reverse the growing annual deficit. Concerns have been raised about the past process of establishing Operating Budgets such as timing, and appropriate input from all relevant parties. Changes have been made to the 2010 Operating Budget process to improve the process, including, preparation at the same time as the City’s budget process, and direct involvement of Property Managers in preparing building-



by-building 2010 operating budgets based on actual expenditures and trends over the past 5 years. This should improve accountability and awareness of expenditures in 2010. The proposed 2010 Operating Budget results in an additional Service Manager subsidy requirement of $168,354. The budget for expenditures represents a decrease of 1.05% or $588,769 in operational spending, while the budget for operating revenues is 2.51% or $757,123 lower than 2009. Changes to the operating budget include:

• Rent revenues in line with the current situation. Vacant units due to bed bugs, renovations, etc. have been taken into account.

• An additional $172,000 has been budgeted for administration costs as a result of salary increases due to CUPE 5167 and non-union job evaluations

• An increase of $170,000 in administration costs has been budgeted for bad debts, which is representative of the current level of arrears

• Maintenance budget is the same as the 2009 adjusted budget

• Municipal taxes budget is $34,974 lower than the 2009 budget, but including a 2% increase over the 2009 actual amount

• The utility budget is based on guidelines issued from the Social Housing Services Corporation (SHSC), which results in a reduction of the budget by $286,395.

• Mortgage costs are reduced by $669,899 from the 2009 adjusted budget due to mortgage renewals and debenture expiry.

The changes to the budget process for 2010 are positive steps towards addressing concerns raised about the past process of establishing Operating Budgets such as timing, and appropriate input from all relevant parties. In addition to the changes made for 2010, it is anticipated that recommendations on additional changes to the budget process may be made as part of Phase Two of the Operational Review.

5.13 CORPORATE RECORDS – ACCESS, CONFIDENTIALITY, RETENTION

The Board should have made some provision for gaining access to corporate records in the event staff are sick, during periods when staff are on vacation, in the event staff /property management firm are terminated, and so on. Review what arrangements, if any, have been made for this, and note what the arrangement is.

Corporate records are kept at the head office at 55 Hess St. Corporate records are available to Board members.

Issue: A draft policy on records management has been created, but it is shared with the Housing Branch, and has not been finalized.



A Business Continuity Plan has been developed for CityHousing Hailton to follow in the event access to the head office is disturbed. The plan outlines the various steps to be followed to ensure the Corporation can continue operating at a second location, at one of the owned buildings.

Retention & Confidentiality The Board should have clear policies on the storage and disposal of all files e.g. financial, legal, project data, tenant files

A draft policy on Records Management was created for CityHousing Hamilton in November 2006 as well as the Housing Branch. The draft policy outlines the records that are created by staff, legislation by which the Housing Branch is authorized to collect information, privacy legislation relating to the record, and the retention period, disposal method and authority by which records are maintained and destroyed. The draft policy provides specific instructions on active file storage and security, inactive file storage, and records retrieval. For corporate accountability, CityHousing Hamilton should have its own policy on records management, which has regard for City policies, but fits with its own unique legislated business environment.

5.14 MARKET RENT

No Issues: In most cases, the market rents being charged for 2009 are above the Benchmark rents and where the actual market rents are below the Benchmarks an analysis has been conducted to determine the rent levels that could be charged to be consistent with comparable properties.

Recommendation It is recommended that the Board ensure that a policy on records management is prepared and followed.



The following is a comparison of the benchmarked rent to the actual market rents charged:

Comparison of 2008 Benchmark Market Rents with 2008 Actual Market Rents

Project Unit Type # of Units Benchmark Rent Actual Rent

Rent Incentive1 / (Shortfall)


122 Hatt 2 B TH 20 $733 $764 $31

122 Hatt 3 B TH 14 $861 $951 $90

Total Units 34

Municipal Non-Profit Housing

1285 Upper Gage 2 B TH 5 $805 $851 $46

1285 Upper Gage 3 B TH 8 $904 $958 $54

1150 Limeridge Rd. 2 B TH 26 $805 $838 $33

1150 Limeridge Rd. 3 B TH 40 $904 $937 $33

580 Limeridge Rd. 2 B TH 35 $805 $877 $72

580 Limeridge Rd. 3 B TH 30 $904 $893 (-$11)

25 Towercrest 2 B TH 19 $805 $850 $45

25 Towercrest 3 B TH 39 $904 $919 $15

25 Towercrest 4 B TH 6 $985 $1,028 $43

470 Stone Church 2 B TH 40 $805 $828 $23

470 Stone Church 3 B TH 30 $904 $878 (-$26)

67 Ossington 3 B TH 20 $904 $897 (-$7)

1081 Rymal Rd. E. 3 B TH 23 $904 $897 (-$7)

1100 Limeridge Rd. 1 B Apt 50 $636 $674 $38

1100 Limeridge Rd. 2 B Apt 7 $686 $749 $63

1900 Main W. 1 B Apt 73 $551 $712 $161

1884, 1900 Main W. 2 B Apt 59 $628 $784 $156

1900 Main W. 3 B Apt 26 $667 $962 $295

101 Broadway 1 B Apt 43 $587 $692 $105

101 Broadway 2 B Apt 2 $725 $784 $59

1781 King St. E. 1 B Apt 12 $551 $633 $82

1781 King St. E. 2 B Apt 6 $628 $739 $111

430 Cumberland 1 B Apt 74 $587 $593 $6

430 Cumberland 2 B Apt 47 $675 $700 $25

430 Cumberland 3 B Apt 31 $725 $819 $94

75 Wentworth N. 2 B Apt 24 $664 $651 (-$13)

75 Wentworth N. 3 B Apt 16 $709 $716 $7

Century, Ashley 3 B TH 8 $779 $789 $10

1 Rent incentive refers to the difference between the actual market rent charged and the benchmark rent when actual market rent is greater than the benchmark rent.



Century, Ashley 4 B TH 2 $886 $804 (-$82)

10 Brock 3 B TH 7 $779 $805 $26

10 Brock 4 B TH 3 $886 $878 (-$8)

Total Units 811

Portuguese Non-Profit Housing

170 East Ave. 1 B Apt 16 $550 $574 $24

170 East Ave. 2 B Apt 30 $627 $692 $65

680 Stonechurch 1 B Apt 4 $493 $625 $132




Gurnett Drive 3 B TH 5 $903 $935 $32

Total Units 116

In most cases, the actual market rents for 2009 are above the Benchmark rents resulting in a rent incentive. There are currently seven instances where the actual market rents are below the Benchmarks resulting in revenue shortfall. These all occur in the Municipal Non-Profit Housing units. An analysis conducted in 2008 by CityHousing Hamilton staff of rent levels revealed three market rent levels in the portfolio. In some cases, market rents are consistent with other average rent levels in comparable properties and as such, staff recommendation was to implement a 1.8% increase as per Provincial guidelines for 2009. In other cases, CityHousing Hamilton’s rents are higher than in comparable properties, resulting in difficulties in renting these units. Staff recommended keeping the current rents for these properties and not implementing any increase. In some properties in the portfolio, rents are lower than the average for comparable properties so staff recommended a 4.0% increase in rental levels implemented over a three-year period. Six of the seven properties with actual market rents below the Benchmarks had market rents consistent with other average rent levels in comparable properties, (10 Brock Street being the exception), the other had rents higher than in comparable properties. Rent levels should continue to be monitored on an annual basis.



6.0 RESIDENT/TENANT RELATIONS

6.1 LEASES/OCCUPANCY SUBSIDY AGREEMENT FOR TENANTS RECEIVING

RENT-GEARED-TO-INCOME (RGI)

O. Reg. 339/01 requires that the housing provider enter into a written lease or occupancy agreement with each household occupying an RGI housing unit.

The lease/occupancy subsidy agreement for tenants who receive RGI contains the following required clauses:

Y does not exceed one year Y reflects the market rent/housing charge for the unit Y reflects the geared-to-income rent payable by the household for one month

NA the initial fee for membership NA sector support levies Y additional charges allowable under the RTA (utility charges, utility

allowances, parking charge) Y adjustment for misrepresentation of, or failure to report income Y prohibition on subletting/assignment of units Y occupancy restricted to names on lease Y reporting changes in occupants Y services and utilities included in the rent Y additional charges allowable under O. Reg. 339/01, Section 22(3). N/A all members of the household 16 years of age and older sign the lease (All

members of the household 18 years of age and older sign the lease. At the Service Manager’s discretion, members of the household who are 16 and 17 years of age could be required to sign the lease, but the Service Manager does not require this.)

No Issues: In most cases, the market rents being charged for 2009 are above the Benchmark rents and where the actual market rents are below the Benchmarks an analysis has been conducted to determine the rent levels that could be charged to be consistent with comparable properties.



6.2 TARGETING

Approved Targets and Actual Activity for Municipal Non-Profit Units Approved Targets Actual Activity

Municipal Non Profit

Municipal Non Profit

Number % Number %

RGI 430 50.1% RGI 469 54.7%

Market 428 49.9% Market 389 45.3%

Total 858 Total 858

Dundas Valley Dundas Valley

Number % Number %

RGI 52 70.3% RGI 48 64.9%

Market 22 29.7% Market 26 35.1%

Total 74 Total 74

Portuguese Portuguese

Number % Number %

RGI 68 46.6% RGI 77 52.7%

Market 78 53.4% Market 69 47.3%

Total 146 Total 146

For the municipal non-profit units, being under target on market units is not non-compliance with the funding program. However, by not meeting the targets for market rent, the revenue targets supported by market rents are not being met.

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to direct staff to comply with the target plan established under section 98(1) of the Act.

Issue: The group is under target on market units which means the revenue targets supported by market rents are not being met.



6.3 WAITING LIST

Ron Wilson confirmed that the group is participating in the Access to Housing centralized waiting list.

6.4 TENANT FILE REVIEW

A total of forty (40) tenant files were reviewed including twenty-eight (28) Rent-Geared-to-Income (RGI) tenant files which were reviewed comprehensively and 12 files which were reviewed for specific documentation. The files reviewed comprehensively were selected by CityHousing Hamilton staff and represented a range of type and size of households, as well a spectrum of sources of income including stable and fluctuating employment income, government and private pension income, Ontario Works (OW), Ontario Disability Support Program (ODSP), and spousal or child support income. Two files were reviewed for each of the thirteen portfolios (13 Property Managers and Property Management Assistants) and an additional fourteen files were selected throughout the portfolio.

Issues: There were some concerns identified in the review of the tenant files. The main concerns include: When household occupants reach 18 years of age or individuals 18 years of age or older move into or out of the unit, a new lease is not always prepared and signed by all current members of the household aged 18 years of age or more. The market rent amount for the unit was not included in the Form N1 or notice of change in rent form issued to tenants. There were some cases where the RGI calculations and errors in applying the social assistance scale have resulted in the wrong rent being charged. When a rent calculation is completed without all required income documentation received, the notice of rent change does not note that the new rent is subject to change upon receipt of required documentation, and that the outstanding documentation is still due. There were some cases where households in an over or under-housed situation were not provided with correspondence noting the situation and providing the next steps to be taken for a transfer to a unit of a more appropriate size.

No Issues: The group is participating in the Access to Housing centralized waiting list.



The sampling of files reviewed comprehensively included current RGI tenant files from the following properties:

Property Number of

Files Reviewed

Banff Drive (Richard Court) 1

Bobolink Road 1

20 Congress Crescent 2

50 Congress Crescent 1

430 Cumberland Avenue 1

East 21st Street 1

Ferrie Street 1

Greendale Drive 1

95 Hess Street South 1

181 Jackson Street 1

200 Jackson Street West 1

1150 Limeridge Road East 1

25 Lynden Avenue 1

322 MacNab Street 1

191 Main Street West 1

1884 Main Street West 1

395 Mohawk Road East 1

45 Montcalm Drive 1

155 Park Street South 2

77 Purnell Drive 1

680 Stone Church Road 1

120 Strathcona Avenue North 2

25 Towercrest Drive 1

801 Upper Gage Avenue 1

980 Upper Ottawa Street 1

Total 28

The tenants files reviewed comprehensively also represented the various different housing program portfolios, as follows:



Program/Corporation Number of Files Reviewed

Municipal Non-Profit (Hamilton) Housing Corporation

4

Hamilton Portuguese Community Homes Inc.

1


1

City of Hamilton 22

First Place Hamilton 0

Section 27 Non-Profit 0

Total 28

Below is a detailed summary of the findings from the comprehensive review of the 28 RGI tenant files.

Area Reviewed Comments

1 Original application for housing on file

Issue: The original application for housing was not on file in some of the files Three of the 28 files, (11%), reviewed did not include the tenants’ original application for housing.

2 Application for housing requests information necessary for verifying occupancy and eligibility standards

No Issues: The current application for housing requests the necessary information and documentation for verifying occupancy and eligibility standards.

3 Occupancy standards are being met

Issue: In files reviewed where tenants are in an over-housed situation there were no forms or other correspondence or out of date correspondence with the tenant on file addressing the over-housed situation. Two of the 28 files, (7%), reviewed indicated that occupancy standards were not being met. In both cases, 3-bedroom units were being occupied by one adult and one child only. In one case, the household has been over-housed since July of 2007 and there are no forms or other correspondence with the tenant on file addressing the over-housed situation. In the second case, there are also no forms or other correspondence with the tenant on file addressing the over-housed situation. For a third file, it was unclear as to whether occupancy standards are currently being met as the doctor’s note indicating the need for an extra bedroom is from April 2007 rather than



from the past year. No files reviewed showed households that were under-housed.

4 Eligibility standards are being met

Issue: It was not possible to confirm eligibility standards are being met for some of the files. For the majority of the files reviewed, it appeared that eligibility standards are being met. For the 3 files where the original application for housing was missing, it was not possible to determine if eligibility standards were being met as there was no documentation on file indicating status in Canada. Two (2) of the files reviewed did not show any evidence of a landlord check being completed. No files reviewed indicated any arrears with a social housing provider within Ontario.

5 Lease agreement is on file and shows all current occupants, is signed by all primary tenants and a representative of the housing provider, is witnessed by a third party, and includes dates where appropriate

Issue: In some cases the lease agreement on file was not signed by all primary tenants. All 28 files reviewed, (100%), included lease agreements. However, while the lease states that: “Occupants who

reach the age of 18 will be required to become tenants and

your household will be required to sign a new lease for

your Unit to reflect this,” 4, (14.2%), of the leases reviewed did not include the signatures of individuals in the unit who were over the age of 18 years. In 2 cases, the individuals over the age of 18 who had not signed the lease had been under 18 years of age at the time of initial occupancy. In 2 other instances, individuals who were more than 18 years of age at the time of move-in to the unit had not signed the lease. Finally, in 1 case the lease on file included a tenant who was no longer residing in the unit.

6 Lease agreement shows correct market rent level, utilities and appliances for the unit.

Issue: Most of the files reviewed did not show the correct market rent level. Twenty-five of the 28 lease agreements received, (89%), did not show the correct market rent level for the unit. For the majority of these files, the market rent of the unit at the time of occupancy is noted, although for 3 files only the tenants’ rent-geared-to-income amount is noted. Leases did indicate the utilities and appliances for the unit, as well as utility changes and allowances that are applied to the rent.



7 MFIPPA is addressed in the lease agreement and permission is given to report arrears to the Service Manager

No Issues: The Municipal Freedom of Information and

Protection Act is addressed in the lease agreement and permission is given to report arrears to any municipal department or agency administering social housing waiting lists in accordance with the Social Housing Reform Act.

8 Copy of lease agreement acknowledged by tenant as being received

No Issues: In almost all cases files did have a documented acknowledgement that the lease agreement was received by the tenant Of the 28 files reviewed, 1 file, (4%), did not have documented acknowledgement that the lease agreement was received by the tenant.

9 Request for verification of household composition and income is made at least annually

No Issues: In almost all cases files a request for verification of household composition and income is made at least annually. With the exception of 1 file, (96%), household composition and income verification is requested at least annually, or every 2 years for seniors on fixed incomes. One file of a non-senior household had no evidence of there being a request for verification of household composition and income during the past year.

10 Income reductions and increases that would result in rent changes of $10 or more are reported and the rent is adjusted accordingly

Issue: The income reductions and increases for some files are not being reported as required. Four of the files reviewed (14%) indicated that income reductions and increases are not being reported as required. For the first file, the tenant has been requested to provide income information on a quarterly basis but was not currently doing so. In the second file, income changes were not being reported but they were captured in the annual review when the tenant provided their Notice of Assessment and retroactive rent adjustments were completed. In the third file, annual review forms completed in October 2009 indicated an income decrease in March 2009, but no retroactive rent adjustment was made. In the fourth file, documentation provided in September 2009 showed support payments were no longer being made effective February 2009, but no retroactive rent adjustment was made.



11 Review of household income and composition is made, dated and supported with appropriate income and asset verification documentation

Issue: In some cases completed income and asset verification documentation is not received during the review of household income and composition. With the exception of the 1 file noted above (section #9) where household composition and income verification had not be requested annually, upon receipt of the income and asset verification documentation, annual reviews were subsequently completed by staff, (96%). In some cases, completed income and asset verification documentation was not received including: 6 files, (21%), did not have banking documentation provided; 1 file did not have other interest income documentation; 2 files did not have Notice of Assessment documentation; and 1 file did not have current documentation indicating children 16 years of age or older were attending school full time. Annual reviews were completed for these households based on the assumption that there was no additional income. In addition to the above noted files where insufficient documentation was received, 1 file, (4%), indicated no income documentation was provided for the most recent annual review, and 3 files, (11%), did not provide complete employment or social assistance income documentation. Annual reviews were not completed for the file where no income documentation was provided, and for 1 of the files which had incomplete income documentation was provided.

12 Appropriate follow-up has been made where household changes have not been reported within the required timeframe

Issue: In some files appropriate follow-up was not made where household changes have not been reported within the required timeframe. In the majority of cases where household changes have not been reported within the required timeframe, documentation was found on file indicating that appropriate follow-up was made. This included reminder letters specifically noting the information and documentation still outstanding, as well as notices to the tenants that their subsidy would be revoked. However, in approximately 6 files, (21%), there was no evidence of follow-up on some of the documentation not provided in the annual request for household composition and income verification. Annual reviews were completed for these households based on the assumption that there was no



additional income.

13 Eligible sources of income have been requested to be sought

No Issues: Eligible sources of income have been requested to be sought where applicable. For most of the files reviewed, the request for eligible sources of income was not applicable. For the 3 files where it was applicable, documentation on file indicated that it was requested to be sought.

14 Income declaration form includes all income sources as outlined in the SHRA

No Issues: The income declaration form includes all categories of income sources as are outlined in the Social

Housing Report Act.

15 Tenant is given the opportunity to comment before a decision was made on third party information, and that they are advised of the internal review process and timelines for adverse decisions

No Issues: Tenants have been given the opportunity to comment before a decision was made on third party information, and are advised of the internal review process and timelines for adverse decisions. For most of the files reviewed, the opportunity to comment before a decision was made on third party information was not applicable. For the 1 file where it was noted to be applicable, the tenant was provided with only a 10-day opportunity to comment. In all files, tenants were advised of the internal review process and timelines for adverse decisions.

16 RGI calculations result in the correct rent being charged

Issue: In some cases RGI calculations and errors in applying the social assistance scale have resulted in the wrong rent being charged. Two of 28 files reviewed, (7.1%), had incorrect RGI calculation. In the first file, the error was very minor and resulted in only a $1 error to the rent amount. The error was due to the rounding to the nearest dollar of bi-weekly gross income amounts prior to adding them up and multiplying/diving to a monthly amount, subtracting the employment deduction and multiplying by 30%. In the second file, a couple of errors were made resulting in a $49 rent error. These errors included using an incorrect amount for one weekly paystub, and also applying 4 weeks of work to a one month period. With a second rent calculation in the same file, there was again a misread of a paystub. This resulted in a $2 rent error. Errors in applying the social assistance scale and in applying utility charges/allowances were also noted in a total of 6 files, (21.4%) (including one of the files noted above as having



an incorrect RGI), and these are described below (sections #17 and #18).

17 Deductions for employment are made correctly

No issues: Deductions for employment are made correctly Deductions for employment were made correctly in the 8 files where this deduction was required, (100%). For the remaining 20 files reviewed, an employment deduction was not required or applicable.

18 Utility charges/allowances are made correctly

Issue: In a small number of cases the utility charges/ allowances were not made correctly. In 2 of the 28 files reviewed, (7.1%), utility charges/allowances do not appear to have been made correctly. In the first file, a charge of $24 was added to the rent up until 2001 at which time it was increased to $30. The $30 charge corresponds with the CityHousing Hamilton utility scale for the building. In the second file, the CityHousing Hamilton utility scale indicates that for the size of unit (2-bedroom) in the building, an allowance of $72 should be applied. This was applied up to and including the rent in 2005, after which an allowance of $79 is applied. This amount corresponds with the utility allowance for a 3-bedroom unit in the building. There is no evidence or documentation in either file indicating that there has been a change in terms of the utilities or appliances included/not included in the rent.

19 Social assistance scale is applied correctly

Issue: In some cases errors in applying the social assistance scale have resulted in the wrong rent being charged. In 4 of the 28 files reviewed (14%), it appears that the social assistance scale is not being applied correctly. In 2 of the files, tenants were receiving ODSP but had non-benefit income that exceeded the allowable threshold for their size of benefit unit. In this case, the 30% RGI ratio should have been used to calculate the RGI rent, but instead the ODSP scale amount was used. In the other 2 files, the OW rent scale being used is for a size of benefit unit that does not correspond to the current documentation on file. In one instance, the rent scale used is for a 3-person benefit unit size whereas current documentation on file (ie. basic needs amount on OW stub) indicates that the benefit unit size is 1 person. There is no current OW drug or dental card on file. In the other file, the OW rent scale



being used is for a 2-person benefit unit size whereas current documentation on file (ie. basic needs amount on OW stub, and a drug card for a separate benefit unit) indicates otherwise.

20 Rent register corresponds with most recent rent calculation

No Issues: The rent registers provided corresponded with the most recent rent calculations in all the files reviewed, (100%).

21 Notice of change in rent is provided, Form N1 used for notice given after January 1, 2007, signed by staff and dated

Issue: The Form N1 was not used in all cases for notice given of changes in rent after January 1, 2007. In 4 of the 28 files reviewed, (14%), a Form N1 was not used for a change in rent after January 1, 2007. In all cases, the tenants were notified of a new rent which was different from the rent specified in their lease, but this was in the form of a letter rather than the N1 notice of rent change. For 27 of the 28 files reviewed, (96%), the N1 notice of rent change did not include the current market rent for the unit. In 25 files, (89%), there was no evidence of any documentation to the tenant indicating the current market rent amount for the unit. The exceptions were 2 files where the lease agreement was very recent and thus included the current market rent, and the 1 file where the tenant’s rent had increased to the market rent amount and the N1 form correspondingly noted the current market rent amount for the unit. With regard to the N1 forms reviewed, all were signed by staff and dated.

22 Rent reductions are effective the first day of the first month after the notice is given, rent increases are effective the first day of the second month after the notice is given

No Issues: For all the files reviewed, (100%), the notices of rent changes indicated rent increases and decreases to be effective at the appropriate time relevant to the issuing of the notice.

A review of additional tenant files was conducted to determine if proper procedures were being followed.

Area Reviewed Comments

23 Appropriate follow-up where household changes have not been reported

No Issues: Appropriate follow-up is made where household changes have not been reported, aside from the follow-up on missing income documentation discussed above.

Appropriate follow-up is undertaken in cases where household changes have not been reported. Letters requesting



information are sent to the tenant and these state the next steps in the process, which may result in the removal of the rental subsidy. A Community Relations Worker is also assigned to the case and the tenant is sent a letter requesting that the tenant work with the Community Relations Worker to remedy the problem or provide the required information. As noted in the review of the 28 RGI tenant files, however, in some cases there was no evidence on file of follow-up on missing income documentation. (See Section #12 above)

24 Appropriate form for notices of rent arrears is used, with proper notice periods provided

No Issues: The appropriate form for notices of rent arrears, the N4: Notice to End a Tenancy Early for Non-payment of Rent, is used with proper notice periods provided

The appropriate form for notices of rent arrears, the N4: Notice to End a Tenancy Early for Non-payment of Rent, is used with proper notice periods provided. The process in place is to send a letter to the tenant informing the tenants of rent arrears, the date when these have to be paid and the next step in the collection process. The files reviewed show that the letter may be signed by the Property Manager or the Community Relations Worker but the N4 is always signed by the Property Manager.

25 Appropriate form for Notice to Vacate is used, with proper notice periods provided

No Issues: The appropriate form for Notice to Vacate is used.

The appropriate form for Notice to Vacate is issued. The files reviewed show that a letter is sent to the tenant regarding rent arrears and includes a date by which these have to be paid and the next steps in the collection process. This is followed by the issuance of the N4 form, which is then followed by the issuance of the L1 Form: Application to Evict a Tenant for Non-payment of Rent and to collect rent the tenant owes. The files reviewed also contain the Landlord Tenant Board Certificate of Service for the N4 and L1 forms.

26 Appropriate form for Overhoused households is used, with proper notice periods provided

Issue: In some cases a letter was not provided to overhoused households.

A letter is provided to the tenant stating the overhoused situation and providing the next steps to be taken to re-house the tenant in more appropriate accommodation, except in the two cases noted in Section #3, above. If the tenant refuses three offers of accommodation, a letter from the Property Management Support Officer is sent to the tenant regarding the removal of rental subsidy, the tenant’s right to appeal and



the period by which the request for review must be received. As noted above (Section #3), at least 2 of the 28 RGI files reviewed, (7%), indicated that occupancy standards were not being met and there were no forms or other correspondence with the tenant on file addressing the over-housed situation.

27 Appropriate form for charges for damages is used, with proper notice periods provided

Issue: An invoice is made detailing charges for damages but if the tenant does not also have arrears no letter or deadline is given for which payment has to be made.

A Tenant Invoice detailing the charges for damages and signed by the Project Manager is sent to the tenant. In the case where the tenant also has rent arrears, the Tenant Invoice is accompanied by a letter with details on the outstanding rent and the charges for damages and a date by which the charges have to be paid. Where there is a Tenant Invoice for charges for damages only it is not accompanied by a letter. It is recommended that all Tenant Invoices be accompanied by a cover letter signed by the Property Manager or Assistant Property Manager with a deadline for which payment for damages have to be made.

28 Households in arrears have a repayment plan in place and up to date

No Issues: Households in arrears have a repayment plan in place, normally as part of the agreement mediated by the Landlord Tenant Board. In the case where the tenant is not keeping to the terms of the repayment plan, a notice to end a tenancy early for non-payment of rent (N4) is issued.



Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that policies are in place and followed so that when household occupants reach 18 years of age or individuals 18 years of age or older move into or out of the unit, a new lease is prepared and signed by all current members of the household aged 18 years of age or more, and all other occupants of the unit are verified and noted on the lease, and it is also signed by a representative of CityHousing Hamilton. The Board is directed to ensure that the market rent amount for the unit be included in the Form N1 or any notice of change in rent form issued to tenants. The Board is directed to ensure that in cases where occupancy standards are not being met, policies and procedures are in place and are followed so that correspondence is issued to the tenant noting the over or under-housed situation and providing the next steps to be taken for a transfer to a unit of a more appropriate size. Recommendation

It is recommended that the Board ensure that policies and procedures are in place and followed so that all RGI calculations are reviewed by a Property Manager prior to the notification of the rent being issued to the tenant household. It is recommended that the Board ensure that when a rent calculation is completed without all required income documentation received, that it be noted in the notice of rent change that the new rent is subject to change upon receipt of required documentation, and that the outstanding documentation is still due. It is recommended that tools be used to better manage information and data flow related to tenant files.



7.0 MAINTENANCE ADMINISTRATION

A sample of buildings for site visits were selected by CityHousing Hamilton staff and these buildings were:

• 155 Park – Seniors high-rise apartments

• 20 Congress – Family high-rise apartments

• 2 Oriole Crescent – Family townhouses

• 500 MacNab – Singles high-rise apartments

• 10 Brock Street – Family townhouses

• 66 Greendale – Family townhouses

• 95 Hess – Singles high-rise apartments

• 120 Strathcona – Seniors high-rise apartments The purpose of the site visits was to examine the materials that are kept on site, including the fire safety plan, fire inspection log book, roof anchor inspection log book, elevator license, and WHMIS material safety data sheets. While the findings of the site visits outlined below relate to the buildings visited, it is reasonable to expect that the findings are generally representative of other buildings in the portfolio.

7.1 ELEVATOR SAFETY

The elevator inspection log books for three of the five high-rise apartments visited were on site and available for review. These were updated with the inspection date and the initials of the person performing the inspection. The last inspection dates were October 2009 and November 2009 and the inspections were performed by the contractor retained by CityHousing Hamilton. Elevator inspection log books for two of the high-rise apartments visited were not available for review as Property Managers for both these buildings said they were not allowed inside the elevator room where the log book was kept. An updated elevator license was posted in the elevators of three high-rise apartment buildings visited. One of the buildings had an expired license posted although an updated license was in the office. Another building did not have an elevator license posted in the elevator or elsewhere.

Issue: The log books for some of the elevator inspections were not available for review as the Property Managers indicated that they were not allowed inside the elevator room where the log book was kept.



CityHousing Hamilton has an elevator maintenance contract in place with a qualified firm.

7.2 FIRE SAFETY

CityHousing Hamilton uses a contractor certified under the Ontario Fire Code (OFC) for all necessary life safety inspections. Annual, semi-annual, and monthly inspections are conducted by the contractor as required. The log books for inspections and tests are kept on site and updated for 2009. Inspections of life safety equipment, such as the fire extinguisher, and performed by CityHousing Hamilton staff, are conducted weekly and daily. Most of the staff members in attendance during the building inspections confirmed that these inspections were done daily and weekly as required but a staff member at one of the buildings visited noted that these inspections were not done on a daily basis in that building. A copy of the updated Fire Safety Plan with a letter from the Fire Department was available on site for all high-rise apartments visited but the plan was not posted in the Fire Alarm Control Panel for any of the buildings. Building layout maps or instructions on what to do during a fire are posted in front of elevators. Staff confirm that all tenants receive a copy of the “Smoke Alarm Maintenance Information for Tenants and Occupants in Rental Units” and that tenants of high-rise buildings receive the “Instructions to Occupants on Fire Procedures” when they sign the lease. The review of tenant files showed that only 9 out of 20 files, (45%), reviewed for these documents had a copy of the “Smoke Alarm Maintenance Information for Tenants and Occupants in Rental Units” signed and dated by tenants.

Issues: The Fire Safety Plan was not posted in the Fire Alarm Control Panel of some of the buildings visited.

Many of the tenant files reviewed did not include a copy of “Smoke Alarm Maintenance Information for Tenants and Occupants in Rental Units” signed and dated by the tenant. No inventory of units that have the strobe lights is kept to allow for placement of tenants with hearing difficulties.

Recommendation

It is recommended that clear guidelines regarding access to the elevator room be created.



Staff at one of the buildings visited confirmed that some of the units have strobe lights to alert the tenant, if they have significant hearing difficulties, when the fire alarm sounds but tenant placement staff does not keep track of which units have the strobe lights to allow for placement of tenants with hearing difficulties. The contractor performs annual smoke detector and automatic door closer inspections. A copy of the updated Fire Safety Code was not available for inspection at any of the buildings visited.

7.3 ROOF ANCHORS

Roof anchors are present at the five high-rise apartment buildings visited and the roof anchor inspection log book was available on site. The log books show that annual inspections by the contractor for three of the five buildings visited are updated and the roof anchor layout was posted on the door leading to the roof. The log books for two of the buildings visited showed that the last inspection was conducted in August 2007 and these buildings did not have the roof anchor layout posted as required.

Issue: In some building visited, annual roof anchor inspections were not conducted and a roof anchor layout was not posted on every exit door.

Directive

To meet the requirements of the Fire Safety Code, the Board is directed to ensure that the Fire Safety Plan is posted in the Fire Alarm Control Panel of all the buildings in the portfolio and that all buildings be provided an updated copy of the Fire Safety Code.

Recommendation

It is recommended that the Board ensure that policies are in place and followed so that a copy signed and dated by the tenant acknowledging receipt of information on fire prevention, emergency response, and smoke alarm maintenance is kept in the tenant files. It is recommended that the Board direct staff to develop and keep an inventory of units with strobe lights and that tenant placement staff ensure that tenants who require this modification to their housing unit are placed in appropriate units.



7.4 WHMIS - WORKPLACE HAZARDOUS MATERIAL INFORMATION SYSTEM

Onsite staff confirms that they receive WHMIS information and training and Material Safety Data Sheets were posted in the property management office for four of the five high-rise buildings visited.

7.5 MAINTENANCE RECORDS

Ongoing maintenance records for each unit are kept in YARDI. The maintenance records include:

Y results of move-in/move-out inspections Y tracking of work using a work order system

Issues: Maintenance reports are not produced regularly and provided to the Board.

There is no follow up to determine whether the maintenance/repair is done properly and in a timely fashion.

Directive

To meet the requirements of the Hazardous Products Act and the Hazardous Materials

Information Review Act, the Board is directed to ensure that policies are in place and are followed so that Material Safety Data Sheets are posted in a prominent location for information of the employees.

Issue: Material Safety Data Sheets were not posted in a prominent location in one of the buildings visited.

Recommendation

It is recommended that the Board ensure that policies are in place and are followed to ensure that annual roof anchor inspections are conducted by the contractor and that a roof anchor layout is posted on every exit door that leads to the roof.



Staff indicated that it is more time consuming to isolate a unit of interest in the capital maintenance records. Maintenance reports are not produced regularly and provided to the Board. Staff have indicated that there is no follow up to determine whether the maintenance/repair was done properly and in a timely fashion. Follow up should be done and included in the YARDI reports or such other systems CityHousing Hamilton may utilize. A number of concerns have been expressed with the maintenance process, including:

� Heavy reliance on Property Managers and Property Management Assistants for maintenance advice, despite variable capabilities of Property Managers and Property Management Assistants regarding technical aspects of maintenance

� Slow to respond to maintenance requests � Lack of education for tenants on basic maintenance � After hours maintenance requests not handled well � Inconsistent procurement of contractors � No inspections/quality assurance of maintenance work conducted by contractors to

ensure work is completed properly � No planned annual inspections � Limited preventative maintenance � No maintenance “standards”

We anticipate making recommendations for improvement to the maintenance process as part of Phase Two of the Operational Review.

Recommendation

It is recommended that the Board regularly review the maintenance records to identify trends for budgeting purposes. It is recommended that the Board ensure that follow up is done to ensure maintenance is done properly and in a timely fashion.



7.6 PREVENTIVE MAINTENANCE

Deborah Filice confirmed that CityHousing Hamilton does not have a documented preventive maintenance plan, although inspections of elements such as roof anchors, generators, elevators, fire alarms, and furnaces in the townhouse units are performed by contractors selected through a bid process. Annual unit inspections are not performed although move-in and/or move-out inspections are performed. In addition, a CityHousing Hamilton staff member normally accompanies contractors performing annual smoke detector and automatic door closer inspections and performs a casual inspection of the units to note any obvious deficiencies. N annual unit inspections are done Y boiler and pressure vessel inspections are done Y elevator inspections are done Y smoke detector inspections are done Y furnace & air make-up unit maintenance is done

7.7 CAPITAL RESERVE STUDY

Issues: As mentioned previously, the following items are not up to date and being utilized for capital planning: Building Condition Audits, a long term Capital Plan, and a Capital Reserve fund study.

Recommendation

It is recommended that the Board develop a documented preventative maintenance plan that includes information for inspections performed by a contractor and inspections performed by CityHousing Hamilton staff. It is recommended that the Board ensure that annual inspections of housing units are performed to assist with capital planning and budgeting.

Issues: The group does not have a documented preventive maintenance plan

Annual inspections of housing units are not being performed.



The capital planning process is currently being done for a one year time horizon. It is initiated by Property Managers identifying the capital planning needs followed by prioritization by Capital Planning staff. A long term capital plan has not been created and Building Condition Audits (BCAs) are out of date and not being utilized. Also, an up to date documented capital reserve study has not been completed for use as a planning tool. The most recent Capital Reserve Plan was prepared for the Hamilton Municipal Non-Profit Housing Corporation in January 31, 2004. The Capital Reserve Plan prepared for the Hamilton Municipal Non-Profit Housing Corporation outlined the following anticipated cash expenditures and contributions:

Hamilton Municipal Non-Profit Expected Cash Expenditures and

Contributions in Accordance with the Capital Reserve Plan from January 31, 2004

Year Cash

Expenditures Contributions

Cash Expenditures Less

Contributions

Year 1 $600,000 $437,770 $162,230

Sum of years 2 to 5 $2,400,000 $1,886,410 $513,590

Sum of years 6 to 10 $3,000,000 $2,694,632 $305,638

The 2005 balance of the capital reserve related to the Hamilton Municipal Non-Profit Housing Corporation was $3,520,468. The Plan anticipated a capital reserve balance of $2,539,010 at the end of 2015. More recently, for the full portfolio, CityHousing Hamilton’s capital reserve fund balance as of December 2008 was $9,728,966 as per the financial statements. The balance has decreased from 2006 ($10,891,088) but is higher than 2007 ($9,410,573). An overview of the capital contributions and expenditures for 2006 to 2008 is shown below.

Capital Reserve Fund Balance

2006 2007 2008

Allocation from Operating Budget $6,860,764 $6,892,214 $7,136,720

Other Contributions $478,404 $430,733 $0

Total Allocation $7,339,168 $7,322,947 $7,136,720

Sale of Units $1,358,045 $0 $0

Building Rehabilitation (-$7,929,207) (-$7,818,665) (-$6,896,382)

Other expenses $0 $0 (-$153,777)

Net transfer in/out of Capital Reserve Fund $0 (-$984,797)* $231,832

Beginning Balance $10,123,082 $10,891,088 $9,410,573



Ending Balance $10,891,088 $9,410,573 $9,728,966

*This is largely a result of transfers from the capital reserve fund to the sold unit reserve

A review of the overall capital planning process found that it is subject to several concerns, including:

� Lack of coordinated decision making � Not clear how priorities are set � Reliance on Property Manager for capital planning, who may have limited technical

knowledge � The most recent Building Condition Audits (BCAs) are out of date and not being

utilized � The computer-based capital planning system is not being utilized � No formal long term capital plan in place (i.e. more than 1 year ahead) � No plan to follow therefore unwise spending decisions � Limited linkage between capital planning and maintenance � Process starts too late in the year for meaningful input

The capital planning process needs to be made more timely, comprehensive, and inclusive, and link to the annual business planning in a meaningful way. Phase Two of the Operational Review will recommend changes to the capital planning process.

7.8 EMERGENCY MAINTENANCE PLAN

An emergency maintenance plan is in place, with 24-hour on-call access to property managers. Emergency numbers to contact police and the fire department are posted in each building. A list of pre-approved contractors is provided to all the Property Managers and is posted on site. Y 24 hour on-call system (with access to property manager) Y emergency numbers (police, fire, etc.) Y procedures for specific situations (e.g. water or heat disruption, power failure,

elevator breakdown, etc.)

No Issues: An emergency maintenance plan is in place.

Recommendation

It is recommended that the Board prepare Building Condition Audits (BCAs), a long term capital plan, and update their capital work assessment through a replacement reserve study and that results be used as a planning tool for current budgeting and future jobs.



Y list of pre-approved contractors to make emergency repairs Y evacuation centres

A Business Continuity Plan has been prepared documenting how to address a potential disaster situation of evacuation.

7.9 WORK ORDERS

When a municipal work order or fire safety inspection report is issued, a copy is provided to the Property Manager to issue internal work orders accordingly. At the time of review there were outstanding internal work orders in the life safety category, but we were unable to confirm whether any outstanding municipal work orders were in place or items related to fire safety inspections were outstanding.

Housing Officer Date Program Manager Date Social Housing Administration

No Issues: We were unable to confirm whether any outstanding municipal work orders were in place or items related to fire safety inspections were outstanding.



APPENDIX ONE: SUMMARY OF DIRECTIVES / RECOMMENDATIONS

Section Directives / Recommendations

1.1 PROJECT DESCRIPTION

Directive

To meet its requirements under the Social Housing Reform Act, CityHousing Hamilton is directed to request that the Building Selection Form posted on the City’s website be updated to correct the discrepancies discussed above, and that CityHousing Hamilton staff regularly review the Building Selection Form to ensure that it matches with CityHousing Hamilton’s portfolio listing.

2.1 MEMBERS, OFFICERS and DIRECTORS

Directive

To meet its requirements under the Corporations Information Act, the Board is directed to file a "notice of change" with the Ministry of Consumer Services.

2.2 MINUTES AND MEETINGS

Recommendation

It is recommended that the Board review the following reports: the vacancy and unit allocation report at each meeting and the maintenance report, and the resident relations report quarterly.

2.3 ANNUAL GENERAL MEETING

Directive

To ensure its responsibilities under the Corporations Act are met, The Board is directed to obtain legal advice to confirm that electing the directors and appointing officers at a meeting other than the annual general meeting is legally binding.

2.5 SOCIAL HOUSING

REFORM ACT, 2000

REGULATIONS/MANUALS/ DIRECTIVES

Recommendation

It is recommended that the Board execute a Service Agreement and Shareholders Agreement with the City of Hamilton. It is recommended that the Board ensure that written policies and procedures are developed and followed for internal transfers and internal reviews.

4.3 EMPLOYEE CONTRACTS

Recommendation

It is recommended that the Board ensure that policies are in place and followed to ensure:

• That all job descriptions are updated to reflect changes in legislation and any changes arising from this Operational Review.

• That all job descriptions are signed by the Chief Executive



Officer or designate within a reasonable time of the document being prepared.

• That performance appraisals are conducted annually, in keeping with the City’s policy, together with the preparation of a learning plan for all staff. The achievement of performance appraisals and learning plans should be an item each manager is graded on in their performance appraisal.

Recommendation

It is recommended that succession plans are prepared for each managerial position and a succession policy is prepared for all positions.

5.1 AUDITOR’S MANAGEMENT LETTER RECOMMENDATIONS

Recommendation

It is recommended that specifications continue to be developed for new software and the Board move forward with the software update.

5.3 ANNUAL INFORMATION RETURN (A.I.R.) MANAGEMENT REPRESENTATION REPORT

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that policies and procedures are in place so that audited statements and the annual report are submitted to the service manager within five months of the corporation’s fiscal year end.

5.4 FINANCIAL REPORTS

Recommendation

It is recommended that the Board ensure that financial variance reports be prepared and reviewed by the Board at each meeting.

5.5 REVENUES

Recommendation

It is recommended that the Board ensure that timely reporting of accounts receivables is provided to Property Managers, and performance appraisals are conducted annually, with arrears being one of the key performance indicators in the evaluation of Project Mangers. It is recommended that the Board establish a policy to discourage cash payments whenever possible.

5.6 VACANCY LOSS

Recommendation

It is recommended that the Board direct staff to conduct an analysis of turnover time to determine the reasons for the length of the vacancies and strategies for reducing the turnover time.



5.10 NON-SHELTER AGREEMENTS

Recommendation It is recommended that the Board enter into formal agreements for all non-shelter space in the portfolio, including a formal agreement with the City of Hamilton for use of a portion of the 23rd Floor at 55 Hess St, and monitor the expiry of the agreements and supporting documentation such as insurance certificates, and keep the documents in a central location.

5.11 CAPITAL RESERVE FUND

Recommendation

It is strongly recommended that the Corporation conduct Building Condition Audits, Energy Audits, and prepare a Capital Plan in conjunction with a reserve fund study. Moving forward, it is strongly recommended that the Board ensure that there are sufficient capital funds, (by conducting Building Condition Audits, a long term capital plan and updating the replacement reserve study), prior to reducing Capital Reserve fund contributions.

5.13 CORPORATE RECORDS – ACCESS, CONFIDENTIALITY, RETENTION

Recommendation It is recommended that the Board ensure that a policy on records management is prepared and followed.

6.2 TARGETING

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to direct staff to comply with the target plan established under section 98(1) of the Act.

6.4 TENANT FILE REVIEW

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that policies are in place and followed so that when household occupants reach 18 years of age or individuals 18 years of age or older move into or out of the unit, a new lease is prepared and signed by all current members of the household aged 18 years of age or more, and all other occupants of the unit are verified and noted on the lease, and it is also signed by a representative of CityHousing Hamilton. The Board is directed to ensure that the market rent amount for the unit be included in the Form N1 or any notice of change in rent form issued to tenants.



The Board is directed to ensure that in cases where occupancy standards are not being met, policies and procedures are in place and are followed so that correspondence is issued to the tenant noting the over or under-housed situation and providing the next steps to be taken for a transfer to a unit of a more appropriate size.

Recommendation

It is recommended that the Board ensure that policies and procedures are in place and followed so that all RGI calculations are reviewed by a Property Manager prior to the notification of the rent being issued to the tenant household. It is recommended that the Board ensure that when a rent calculation is completed without all required income documentation received, that it be noted in the notice of rent change that the new rent is subject to change upon receipt of required documentation, and that the outstanding documentation is still due. It is recommended that tools be used to better manage information and data flow related to tenant files.

7.1 ELEVATOR SAFETY Recommendation

It is recommended that clear guidelines regarding access to the elevator room be created.

7.2 FIRE SAFETY

Directive

To meet the requirements of the Fire Safety Code, the Board is directed to ensure that the Fire Safety Plan is posted in the Fire Alarm Control Panel of all the buildings in the portfolio and that all buildings be provided an updated copy of the Fire Safety Code.

Recommendation

It is recommended that the Board ensure that policies are in place and followed so that a copy signed and dated by the tenant acknowledging receipt of information on fire prevention, emergency response, and smoke alarm maintenance is kept in the tenant files. It is recommended that the Board direct staff to develop and keep an inventory of units with strobe lights and that tenant placement staff ensure that tenants who require this modification to their housing unit are placed in appropriate units.



7.3 ROOF ANCHORS

Recommendation

It is recommended that the Board ensure that policies are in place and are followed to ensure that annual roof anchor inspections are conducted by the contractor and that a roof anchor layout is posted on every exit door that leads to the roof.

7.4 WHMIS - WORKPLACE HAZARDOUS MATERIAL INFORMATION SYSTEM

Directive

To meet the requirements of the Hazardous Products Act and the Hazardous Materials Information Review Act, the Board is directed to ensure that policies are in place and are followed so that Material Safety Data Sheets are posted in a prominent location for information of the employees.

7.5 MAINTENANCE RECORDS

Recommendation

It is recommended that the Board regularly review the maintenance records to identify trends for budgeting purposes. It is recommended that the Board ensure that follow up is done to ensure maintenance is done properly and in a timely fashion.

7.6 PREVENTIVE MAINTENANCE

Recommendation

It is recommended that the Board develop a documented preventative maintenance plan that includes information for inspections performed by a contractor and inspections performed by CityHousing Hamilton staff. It is recommended that the Board ensure that annual inspections of housing units are performed to assist with capital planning and budgeting.

7.8 CAPITAL RESERVE STUDY

Directive

To meet its responsibilities under the Social Housing Reform Act, the Board is directed to ensure that a capital reserve account has been set up with Phillips, Hager & North for the Portuguese Non-Profit portion of the portfolio.

Recommendation

It is recommended that the Board prepare Building Condition Audits (BCAs), a long term capital plan, and update their capital work assessment through a replacement reserve study and that results be used as a planning tool for current budgeting and future jobs.


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