On August 27, HUD’s Office of Community Planning and Development (CPD) published notice CPD-18-10, titled “Suspension of 24-Month Commitment Requirement for Deadlines Occurring in 2016, 2017, 2018, 2019, and 2020.” The FY18 omnibus contained a hard-fought provision, first included in the FY 2017 omnibus, which suspended the HOME program’s statutory 24-month commitment requirement for HOME funds that are set to expire in 2016, 2017, 2018, 2019, and 2020. The commitment requirement was widely viewed as a difficult and unnecessary deadline for participating jurisdictions (PJs) to meet.
Due to the suspension of the 24-month commitment requirement for HOME funds, HUD is suspending deadlines occurring in 2016, 2017, 2018, 2019, and 2020 for the following HOME requirements:
- HOME Investment Trust Fund Treasury account commitment requirement
- HOME Investment Trust Fund local account commitment requirement
- Includes all program income, repayments, and recaptured funds.
- PJs must still commit funds in its local HOME account at the beginning of its program year before committing funds in its HOME Treasury account.
Although the Appropriations Acts suspended the 24-Month commitment deadline, it did not suspend the following deadlines, which remain in place and will be continue to be enforced by HUD:
- CHDO reservation requirement
- HOME expenditure deadline requirement
- Expiration of the HOME grant
- State recipients and subrecipients commitment requirement
HUD has revised HOME Deadline Compliance Status reports to reflect the removal of these deadlines.
Although NAHRO is pleased with the suspension of the 24-month commitment requirement for HOME funds for the years 2016-2020, NAHRO has recommended that Congress make this provision permanent to provide consistency and support the effective planning and administration of HOME. As the FY18 Omnibus only suspended the commitment requirement for funds expiring through 2020, PJs remain unclear as to whether future HOME allocations will be subject to the 24-month deadline. The 24-month requirement is an unnecessary and burdensome step towards the completion of projects by the 4-year completion deadline.