From Les Sparks:

First, let me ask if this PHA has a COCC? If so, it may be possible to do something, but outright compensation might be a little tricky.

Frankly, I am a little more concerned about the cell tower. Going back to look at the criteria. Since most of that came from multifamily, I need to see if we adopted the same ideas – that cell towers on projects are project revenue.

Let me know what it is.

7 . 2 TREATMENT O F F E E INCOME UNDER OMB CIRCULAR
A-87 AND 24 CFR PART 8 5
OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments (also at 2 CFR Part 225), as well as 24 CFR part 85, Administrative Requirements for Grants and Cooperative Agreements to State, Local, and Federally Recognized Indian Tribal Governments, establish the basic requirements on the use of federal program funds. For PHAs that convert to asset management (required of PHAs with 250 or more units), any internal fee-for-service charges to AMPs or programs (property management fees, asset management fees, etc.) are used to reimburse the PHAs for its claim of the overhead costs related to these programs (these overhead costs are previously claimed through the cost allocation process under OMB Circular A-87). The fee-for-service amounts are considered non-program income for purposes of A-87 and 24 CFR part 85; however, other state and local restrictions may still apply. Consequently, any reasonable fees earned by the PHA/COCC will be treated as local revenue subject only to the controls and limitations imposed by the PHA’s management, Board or other authorized governing body.

Only the fee-for-service amounts are considered non-program income and not other program funds. For example, assume that a project receives revenue from leasing its rooftop to a cellular phone company. That rooftop revenue would be considered program income in that the income was generated by a program asset. On the other hand, the management fee (or fee-for-service) charged to the project, and received by the COCC, would not be considered program income. The PHA has “earned” the management fee Changes in Financial Management and Reporting Requirements for Public Housing Agencies Under the New Operating Fund Rule (24 CFR Part 990) 34 and the PHA may use such funds in accordance with its mission, subject only to any
local, but not federal, restrictions.