The “NAHRO Together Day 3” webinar series continues for it’s final session of the year Thursday November 17 at 1:30 p.m. ET.

The session, with guest speaker Matt Avital from Ascenda Capital, will highlight how housing authorities and agencies throughout the United States can benefit from accessing certain financing structures to create and own affordable workforce housing more efficiently. The presentation will also feature Gerry Cichon, CEO of Housing Opportunity Management Enterprises in El Paso, Texas and Cody Wilson, Managing Director of Piper Sandler.

The webinar is free and open to all. Register here.

If you missed a Day 3 session and would like to view any of the sessions from previous weeks please see below:

• WATCH: The Campaign for Grade Level Reading
• WATCH: Addressing the Affordable Housing Shortfall with ARPA
• WATCH: Building Resilience and Reclaiming Creativity in a Volatile World
• WATCH: PHAs and CoCs – A True Continuum
• WATCH: All Things FSS

Read more: Final NAHRO Day 3 Session on Financing for Publicly Owned Affordable Workforce Housing

On October 12, 2022, the Department of the Treasury released the Low Income Housing Tax Credit (LIHTC) final regulations related to the income-averaging test that are now in effect. The final regulations provide guidance to using the Average Income Set-Asides, which are used to qualify as a low-income housing project and receive low-income housing credits. The final rule, which also focuses on revising limitations related to the imputed income designation of units and revising criteria/requirements of the Average Income Test, affect owners of low-income housing projects, tenants in those projects, and State/local housing credit agencies that monitor compliance.

Some revisions to LIHTC income-averaging in the final rule include:

• Unit designations: Unit designations can change based on the activity of a tenant in instances of conflicts with federal laws, guidance issued by the governing State Housing Finance Agency, and through tenant transfers.
• Meeting the Minimum Set-Aside for Income-Averaging: At least 40% of a project’s residential units must be eligible low-income units and designated collectively averaging 60% or less of area median gross income (AMGI). This fixes the “cliff effect” of the proposed rule, meaning that one-unit out of compliance does not mean that the entire project would fail the minimum set-aside.
• New definition: “Low-income unit,” specific to the Average Income Test, will now take into account if a unit is part of a group of units with a compliant average limitation.
• Reporting requirements: Temporarily requires recording and annual communication to the applicable agency of (i) units in the qualified group of units used for satisfying the average income set-aside (ii) units in the qualified group for purposes of the applicable fractions.

The final rule can be found here.

For a more in-depth look into the rule, please see our next edition of The Monitor on October 31.

On Thursday, Oct. 20 at 1:30 p.m. ET, NAHRO will continue week two of the “NAHRO Together Day 3 Series,” which offers National Conference style sessions every Thursday for the next 5 weeks. The second session, features guest speaker Adrienne Holloway of the Harris County Community Services Department in Houston, Texas, who will discuss her department’s experiences in addressing the housing shortfall with American Rescue Plan Act (ARPA) funding. This presentation will also share research findings, discuss the 10-year needs assessment for the county, and their goals to address the current and impending affordable housing crisis.

This session is open to all so register now!

For information on future NAHRO Together Day 3 sessions, please see the schedule below:

• Building Resilience and Reclaiming Creativity in a Volatile World, Oct. 27, 1:30pm-2:30pm ET
• PHAs and CoCs – A True Continuum, Nov. 3, 1:30pm-2:30pm ET
• All Things FSS, Nov. 10, 1:30-3:30 ET
• Tax-Exempt Essential Function Bonds, Providing 100% Financing For Publicly Owned Affordable Workforce Housing, Nov. 17, 1:30pm-2:30pm ET

On Thursday, Oct. 13 at 1:30 p.m. ET NAHRO will host it’s first ever event series “NAHRO Together Day 3,” which will offer National Conference style sessions every Thursday for the next 6 weeks. The first session, which features guest speakers from the Campaign for Grade-Level Reading (CGLR), will highlight the interconnection between housing and education. CGLR will highlight themes and innovations from the 2022 All-America City Award, which focused specifically on the role of public and affordable housing tied to supporting students and their families.

This session is open to all so register now!

For information on future NAHRO Together Day 3 sessions, please see the schedule below:

• Addressing the Affordable Housing Shortfall with ARPA, Oct. 20, 1:30pm-2:30pm ET
• Self-Care Post-COVID, Oct. 27, 1:30pm-2:30pm ET
• PHAs and CoCs – A True Continuum, Nov. 3, 1:30pm-2:30pm ET
• All Things FSS, Nov. 10, 1:30-3:30 ET
• Tax-Exempt Essential Function Bonds, Providing 100% Financing For Publicly Owned Affordable Workforce Housing, Nov. 17, 1:30pm-2:30pm ET

On September 30, HUD announced the Notice of Funding Opportunity (NOFO) for the Choice Neighborhoods Implementation Grants. Approximately $379 million in total will be made available to support with the implementation of neighborhood revitalization plans that are used to improve housing, economic/social factors for residents, and to create communities that attract investment for the benefit of residents.

Applications for this grant are due by Wednesday January 11, 2023. Each applicant may be eligible for up to $50 million to support implementation efforts. In addition, HUD will allocate $100 million of the total amount for Supplemental Grants to assist grantees from the fiscal years 2017 through 2020 that have already met certain requirements as per the guidelines of the grant.

For more information on this NOFO, please stay tuned for the next edition of The Monitor.

The Department of Housing and Urban Development (HUD) will be accepting FSS Action Plans up until the deadline on September 30, 2022.

New Action Plans must be submitted as required by the FSS final rule. The Plan should describe how a program will be administered, services that will be offered, and the size/characteristics of anticipated participants of the program.

New participants of an FSS program will not be able to be enrolled until the Action Plan is approved by HUD. The reviewal process takes up to 45 days and must be approved by HUD by November 14. Plans should be submitted via email to PHAFSSActionPlans@hud.gov with the subject line and attachment names titled by PHA’s name and number.

More information on the Plan and what to submit can be found in the August 31 edition of The Monitor here.

The Department of Housing and Urban Development (HUD) announced the Continuum of Care (CoC) Program Supplemental Notice of Funding Opportunity (NOFO) to Address Unsheltered and Rural Homelessness this past August. This competitive funding opportunity would make up to $322 million available to address unsheltered and rural homelessness. Applications must be submitted in e-snaps no later than October 20, 2022, at 8:00 PM EDT.

CoC’s interested in applying must demonstrate a community-wide approach in reducing homelessness. Funding is available for four different categories which include:

1. The Unsheltered Homelessness Set Aside
2. The Rural Set Aside
3. CoC Planning Unsheltered Homelessness Set Aside
4. Unified Funding Agency (UFA) Costs Unsheltered Homelessness Set Aside

Applicants must already be an existing CoC and can apply to either funding opportunity or both depending on their needs and eligibility. The NOFO can be found here.

For more information about this NOFO please see our next edition of The Monitor on September 15.

On August 16, HUD released a sample version of the FSS Action Plan, which is a required document to be completed for each Family Self-Sufficiency (FSS) program (funded or not) to be approved by HUD. The FSS Program, which has recently seen changes due to the announcement of the final rule effective June 17, 2022, implements the requirement for all grantees to submit new Action Plans. The Plan should describe how a program will be administered, services that will be offered, and the size/characteristics of anticipated participants of the program.

In the sample, HUD includes instructions for grantees/programs in creating their Action Plan, an Action Plan template, and a checklist for specific items to be addressed in the Plan. The sample also includes resources that can help in the submission process, which must be completed by September 30, 2022. The reviewal process of an Action Plan takes up to 45 days. New participants of an FSS program will not be able to be enrolled until the Action Plan is approved by HUD.

The Sample Action Plan can be found here.

More information and details on how to create your Action Plan for the FSS Program will be in the August 31 addition of the NAHRO Monitor.

On July 27, the Department of Housing and Urban Development issued Notice PIH-2022-20, which clarifies portions of the Family Self-Sufficiency (FSS) Program final rule. The final rule was published in May of this year and went into effect on June 17, 2022. The sections that are clarified in the notice cover the establishment of an escrow account for FSS participating families, the use of forfeited FSS escrow funds, and reporting requirements of financial data as related to FSS escrows.

The notice provides the following information summarized below:

Establishing an FSS Escrow Account

• PHAs or owners are required to deposit FSS escrow funds of all families participating in an FSS program into a single interest-bearing depository account.
• The escrow account may be part of the PHA or owner’s overall account or a separate account.
• Funds deposited into either account must only be used for the purposes of escrow.
• The total of the account funds must be supported by accounting records that show the balance applicable to each FSS participating family.

Forfeited FSS Escrow Funds

• The final rule requires that all forfeited escrow funds be used by a PHA/owner to benefit any FSS participants in good standing with the program regardless of the original funding source.
• The funds may only be used for activities such as transportation, child care, training, fees associated with employment or professional development, training for FSS Coordinators, and any other activities as determined by HUD.

Reporting Financial Data

• PHAs that administer the Section 8 and/or Section 9 programs must submit annual financial data to HUD.
• Data must be submitted electronically and be prepared in accordance with Generally Accepted Accounting Principles.
• The FSS program provides an accounting brief that provides clarity for this process. The brief can be found here.

For more information, see the notice here.

The deadline for the Resident Opportunity and Self-Sufficiency – Service Coordinator (ROSS-SC) Program Notice of Funding Opportunity (NOFO) is approaching as applications are set to close by July 18, 2022. The grant program will provide funds to hire a Service Coordinator with the goal of assisting residents of Public and Indian Housing through economic improvements and housing self-sufficiency. Funding flexibility will also be given for grantees to provide direct services to ROSS participants. Approximately 125 awards are set to be granted with available funds totaling to $35 million.

In addition, the Family Self Sufficiency (FSS) Program announced on July 12, 2022 that their NOFO is set to be released this summer. Potential applicants should make sure their SAM.gov registration and Unique Entity ID (UEI) is up to date in preparation for the upcoming grant application. Guidance on how to ensure up to date information for your future grants can be found here.

More information regarding the ROSS FY2022 NOFO will be found in our next addition of The Monitor.