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SEB Housing Affordable Housing Consultant Memo to BPDA, Conclusion

We think the current way the program is being run has the potential to have a disparate impact on applicants to BPDA units, and we think the lack of guidelines or consistent policy is making this program more difficult to implement and administer than it needs to be. In order to protect ourselves, we feel we have no choice but to send files to the BPDA (for new move-ins) that are less complete than they would be if the guidelines were clearer. For recertifying households, when there are questions about deposits, we can ask the BPDA to review the details to provide guidance while still preparing the applicant and property for a denial at audit.

To end where I started, I sincerely hope you do not read this email as an overly harsh criticism of the BPDA or this program. It is absolutely NOT intended in that way. Rather, I write to you because I have genuine concerns about how certain BPDA policies are being implemented, how a lack of guidelines in certain instances is creating unnecessary confusion and unintended consequences, and how the BPDA can establish remedies for non-compliance that are incentivizing and proportional. Stated differently, I am writing to you in an effort to improve this process for all involved, and to further our shared goals of ensuring affordable units in the City of Boston are available to those who need them.