PHAs Make Coronavirus Requests of Congress

In partnership with our sister groups CLPHA, PHADA and the Moving to Work (MTW) Collaborative, NAHRO has drafted and sent a letter to the House and the Senate thanking them for the nearly $3 billion in affordable housing assistance in the CARES Act, and asking for substantial resources and flexibilities, including:

  • An additional infusion of $8.5 billion for the Operating Fund and the Section 8 voucher program;
  • An increased supply of Tenant Protection Vouchers;
  • Additional rental assistance for families in need; and
  • A $70 billion investment in public housing infrastructure.

Almost 800 PHAs and organizations joined NAHRO, PHADA, CLPHA, and the MTW Collaborative in signing the letter. You and your partners can also send the letter to your members of Congress through NAHRO’s Advocacy Action Center.

NAHRO continues to provide the latest information on the NAHRO Coronavirus page.

Missed Our Virtual Convening? Recordings Now Available!

Despite the challenges posed by COVID-19, NAHRO remains committed to connecting members and others with industry leaders and important perspectives. In lieu of our cancelled Washington Conference, we put together a complimentary virtual convening on March 30-31, and are now pleased to provide links to both events. 

Dr. Raphael Bostic, President of the Federal Reserve Bank of Atlantadiscussed the bank’s reaction to the COVID-19 crisis, presented on Inclusive Economic Development: Lessons and Challenges, and took questions from attendees. View this webinar here.  

Dr. Mark Calabria, Director of the Federal Housing Finance Agencydiscussed FHFA’s reaction to the COVID-19 crisis, its mission, its role in the housing sector, and his thoughts on critical milestones ahead. View this webinar here. 

Thank you to Yardi for sponsoring both events!   

Watch out for more virtual events as NAHRO continues to provide its members with the news, analysis, and guidance they need. 

Social Security Recipients Do Not Need to File a Tax Return to Receive COVID-19 Relief Payments

NAHRO has reviewed a press release from the U.S. Department of Treasury and the Internal Revenue Service (IRS) that announces Social Security beneficiaries will automatically receive their Economic Impact Payments. This announcement will allow many seniors and low-income individuals, that have not filed a tax return, to receive their Economic Impact Payment without requesting it. There was a previous concern that Social Security recipients, that did not file a tax return in 2018 or 2019, would have to file a special simple tax return to receive their Economic Impact Payment.

NAHRO is maintaining a coronavirus resource page at www.nahro.org/coronavirus. The Treasury Department and IRS press release is reprinted below and is available at home.treasury.gov/news/press-releases/sm967.

Social Security Recipients Will Automatically Receive Economic Impact Payments

April 1, 2020

WASHINGTON – The U.S. Department of the Treasury and the Internal Revenue Service today announced that Social Security beneficiaries who are not typically required to file tax returns will not need to file an abbreviated tax return to receive an Economic Impact Payment. Instead, payments will be automatically deposited into their bank accounts.

“We want to ensure that our senior citizens, individuals with disabilities, and low-income Americans receive Economic Impact Payments quickly and without undue burden,” said Secretary Steven T. Mnuchin. “Social Security recipients who are not typically required to file a tax return need to take no action, and will receive their payment directly to their bank account.”

The IRS will use the information on the Form SSA-1099 and Form RRB-1099 to generate $1,200 Economic Impact Payments to Social Security recipients who did not file tax returns in 2018 or 2019. Recipients will receive these payments as a direct deposit or by paper check, just as they would normally receive their benefits.

####

Census Day is Today!!

censusroadblock

April 1, 2020 is Census Day and NAHRO would like to share the Census Day press release from the United States Census Bureau. An accurate count is essential to ensure the maximum amount of funding and resources are available to your local community!

Census Day Is Here – Make It Count!

April 1, 2020 – Today is Census Day, the day that determines who is counted in the 2020 Census and where they are counted.

The U.S. Constitution mandates a census of the population every 10 years. Responding to the 2020 Census is easy, safe and important, and is key to shaping the future of communities. Census statistics are used to determine the number of seats each state holds in the U.S. House of Representatives and informs legislative district boundaries. They also inform how hundreds of billions of dollars in public funds are allocated by state, local and federal lawmakers to communities for public services and infrastructure like hospitals, emergency services, schools and bridges each year over the next 10 years.

36.2 percent of households across the nation have responded to the 2020 Census since invitations began arriving in mailboxes March 12-20. Response rates are updated in the map daily seven days a week so that the public can see how well their community is doing compared to the nation and other areas.

The Census Bureau is strongly encouraging the public to respond to the 2020 Census online using a desktop computer, laptop, smartphone or tablet. You can respond online or by phone in English or 12 other languages. There are also 59 non-English language guides and videos (plus American Sign Language) available on 2020census.gov ensuring over 99% of U.S. households can respond online in their preferred language. It has never been easier to respond on your own — all without having to meet a census taker. This is really important with the current health and safety guidance being provided by national, state and local health authorities.

When you respond:

  • Respond for where you live as of April 1 (Census Day).
  • Include everyone who usually lives and sleeps in your home as of April 1, even if they are staying somewhere else temporarily. This includes relatives, friends, roommates and anyone else who lives and sleeps in your home most of the time — even children under age five and babies born on or before April 1, even if they are still in the hospital.
  • Count college students where they live while attending school. If they live on campus in university/college housing such as dorms or fraternity/sorority houses, they will be counted by school officials and do not need to respond. However, if they live off campus in private housing or apartments, they should respond to the census on their own using their off-campus address even if they are currently staying elsewhere.
  • Find additional answers about “Who to Count” at 2020census.gov.

You can use the Census ID from your invitation or provide your address when you respond. Then, please make sure your friends, family and social networks know about the importance of responding and encourage them to complete their census. Responding now will minimize the need for a census taker to follow up and visit your home later this year.

Some households — in areas less likely to respond online — have already received a paper questionnaire along with their first invitation. Households that have not responded online or by phone will receive a paper questionnaire April 8-16.

For more information, visit 2020census.gov.

Please note: Based on continuing assessments of guidance from federal, state and local health authorities, the Census Bureau is suspending 2020 Census field operations for two additional weeks to April 15, 2020. The Census Bureau is taking this step to help protect the health and safety of the American public, Census Bureau employees, and everyone who will go through the hiring process for temporary census taker positions. The Census Bureau continues to evaluate all 2020 Census field operations, and will communicate any further updates as soon as possible.

The 2020 Census is open for self-response online at 2020Census.gov, over the phone by calling the number provided in your invitation, and by paper through the mail.

President Signs $2T COVID-19 Relief Bill

 

The third coronavirus (COVID-19) relief bill has passed the Senate and the House, been signed by the President, and is now law. The entire bill includes more than $2 trillion to help the United States economy.

Thank you to everyone that contacted your legislators through the NAHRO’s Advocacy Action Center. Your messages of how important affordable housing is during a pandemic played a critical role in the HUD programs receiving supplemental, relief funding. NAHRO is providing additional coronavirus resources at www.nahro.org/coronavirus.

The relief bill includes additional funds for HUD’s Public and Indian Housing (PIH), Community Planning and Development (CPD), and Office of Housing programs. The HUD funding in the bill is in line with the previously discussed Senate bill – except for the Community Development Block Grant (CDBG) funding, which is $5 billion in the relief bill. All the funding in the bill is in addition to the previously appropriated FY2020 funding. The chart below provides the amounts of the supplemental funding for select HUD programs from the relief bill.

Relief Bill HUD Funding

Program

Relief Bill

Tenant-Based Rental Assistance

$1.25 Billion

HAP Adjustments (included above)

$400 Million

Admin Fee (included above)

$850 Million

Public Housing Op Fund

$685 Million

Native Housing Programs

$300 Million

HOPWA

$65 Million

202 – Elderly

$50 Million

811 – Disabled

$15 Million

CDBG

$5 Billion

Homeless Assistance Grants

$4 Billion

Project-Based Rental Assistance

$1 Billion

In addition to the supplemental funding the relief bill includes several policy provisions including limited statutory and regulatory waivers. HUD is expected to issue notices soon that provide the allocation of the supplemental funding and implements the policy provisions and program waivers, as many of the provision dates are tied to the date of enactment, March 27, 2020. The program policy provisions, along with the funding for each, are described below.

Temporary Moratorium on Eviction Filings

The relief bill includes a provision that requires PHAs to implement a temporary moratorium on evictions. The moratorium applies to Public Housing, Housing Choice Vouchers, Low-Income Housing Tax Credit units, rural housing assistance, and other programs as defined by the Violence Against Women Act. The eviction moratorium will last for 120 days from the enactment of the relief bill, July 25, 2020. The PHA will not be allowed to file an eviction action for nonpayment of rent, fees, or charges and no late fees or penalties may be charged. A 30-day notice to vacate for nonpayment of rent cannot be issued until the expiration of the eviction moratorium. In practice, nonpayment of rent eviction hearings cannot be heard for 5 months from the enactment of the relief bill, August 24, 2020. The moratorium only addresses eviction for non-payment of rent evictions and does not address any other type of eviction. Evictions for issues such as criminal activity or safety of residents are, therefore, allowed.

Tenant-Based Rental Assistance (TBRA)

The relief bill provides $1.25 billion for tenant-based rental assistance.

Administrative Expenses – Of the relief bill’s $1.25 billion for the TBRA account, there is $850 million for additional administrative and other expenses PHAs encounter in administering Section 8 programs, including mainstream vouchers, in response to coronavirus. The bill states that these expenses shall be new eligible activities to be defined by HUD and shall be activities to “support or maintain the health and safety of assisted individuals and families and costs related to retention and support of current participating landlords.” Funds from the FY 2020 appropriations bill may also be used for these expenses.

Housing Assistance Payments (HAP) Adjustments – Of the relief bill’s $1.25 billion for the TBRA account, $400 million will be available for “adjustments in the calendar year 2020 Section 8 renewal funding allocations, including Mainstream vouchers.” These adjustments will be for those PHAs that “experience a significant increase in voucher per-unit costs due to extraordinary circumstances or that, despite taking reasonable cost savings measures,” as determined by HUD, would be forced to terminate voucher assistance.

Need-based allocation – The Department is instructed to allocate the above funding based on need as determined by HUD.

Section 811 – The relief bill allows for any amounts unobligated, including administrative expenses, that remain available after funding renewals and administrative expenses to be used for non-competitive section 811 tenant-based rental assistance to prevent, prepare for, and respond to coronavirus. HUD will award no less than 25 percent of the remaining amounts proportionately to PHAs who received awards in the 2017 and 2019 competitions within 60 days of enactment, May 26, 2020.

Family Unification Program (FUP) vouchers – Funds from tenant-protection vouchers used for youth in the FUP program and funds from FUP funding reserved for youths will not have to be reported to the appropriate congressional committees when grants are awarded.

Waivers – The relief bill allows that the Department may “waive, or specify alternative requirements for, any provision of any statute or regulation [except for requirements related to fair housing, nondiscrimination, labor standards, and the environment] that [HUD] administers in connection with the use of the amounts made available” in this bill or the FY 2020 appropriations act, upon a finding by HUD that waivers “are necessary for the safe and effective administration of these funds to prevent, prepare for, and respond to coronavirus.”

Notice of waivers – HUD must notify the public through the Federal Register or “other appropriate means to ensure the most expeditious allocation of this funding” of waivers or alternative requirements. A public notice at the appropriate government website or through other electronic media determined by HUD may suffice.

Length of waivers – Waivers or alternative requirements will remain in effect for the time and duration specified by HUD by public notice and may be extended by HUD.

Project-Based Rental Assistance

Project-based rental assistance – The relief bill provides $1 billion for project-based rental assistance. These funds are to “prevent, prepare for, and respond to coronavirus,” including funds to maintain normal operation and take other necessary actions, while the program is impacted by coronavirus. The funding is also for owners and sponsors of properties receiving project-based assistance.

Waivers – The Department may “waive, or specify alternative requirements for, any provision of any statute or regulation [except for requirements related to fair housing, nondiscrimination, labor standards, and the environment] that [HUD] administers in connection with the use of the amounts made available” in this bill, upon a finding by HUD that waivers are necessary “to expedite or facilitate the use of such amounts to prevent, prepare for, and respond to coronavirus” and the waivers are consistent with program purposes.

Notice of waivers – HUD must notify the public through the Federal Register or other appropriate means. At a minimum on the Internet at the appropriate government website or through other electronic media decided by HUD.

Public Housing

Public Housing Operating Fund – The relief bill provides $685 million to the Operating Fund. These funds would be distributed by the Operating Fund formula.

Public Housing Subsidy Flexibility The relief bill allows PHAs fungibility of their Operating and Capital Funds so long as the funds are used to prevent, prepare for, and respond to coronavirus. This includes Operating and Capital Funds appropriated to PHAs prior to these bills. The ability to transfer funds between the Operating and Capital accounts will remain available through December 31, 2020. HUD can extend this provision in 12-month increments if needed.

WaiversThe relief bill allows HUD to provide waivers for statutory and regulatory requirements related to the Capital and Operating Fund if those waivers would help PHAs prepare for, prevent, and respond to coronavirus. These waivers will be released in the Federal Register. 

Community Development Programs

HOPWAThe relief bill provides $65 million to HOPWA – $50 million to be distributed by formula and $10 million by one-time, non-renewable grants to existing contracts for permanent support housing that were initially made in FY 2010 and prior years.

The bill allows these funds to be used to help individuals living with HIV-AIDS relocate for the purposes of self-isolation, quarantine, or provide other coronavirus control services as recommended by the CDC.

Community Development Block Grant The Community Development Fund receives $5 billion to be distributed as Community Development Block Grants (CDBG). Of this funding, $2 billion will be distributed to entitlement communities by formula and $1 billion will go directly to states to prepare for and respond to coronavirus based on need. The need-based formula will consider public health needs, the number of COVID-19 cases compared to the national average, and economic and housing disruptions. Allocations must be made within 45 days of enactment of the relief bill, May 11, 2020. HUD would have the discretion to distribute the remaining funds to states or local governments.

The relief bill allows entities an expedited procedure to amend their statements of activities to engage in coronavirus activities. In-person meetings are not required however entities must provide notice a comment period of no less than 5 days to receive public input. Virtual meetings are also allowed.

Homeless Assistance Grants The relief bill provides $4 billion for the Emergency Solutions Grants (ESG) program. Of this, $2 billion will be distributed as formula grants and $2 billion will be distributed to states by a formula developed by HUD. The formula would consider risk of transmission of coronavirus, rising rate of sheltered and unsheltered homeless individuals, disruptions to economic and housing markets, and other factors.

The relief bill allows funding to be used for temporary emergency shelters, costs related to infectious disease prevention, and hazard pay. The Secretary may waive statutory and regulatory waivers as needed to prepare for, prevent, and respond to coronavirus. Up to one percent of the funds can be used to increase prior technical assistance awards that relate to providing health care services. Ten percent of the funds received by grantees can be used for administrative purposes. None of the funds provided can be used to require homeless individuals to enter treatment or perform any other prerequisite activity as a condition or receiving shelter, housing, or other services.

Policy and Legislative Contact Information

Georgi Banna, Esq.

Director of Policy & Program Development

GBanna@nahro.org

Tess Hembree

Director of Congressional Relations

THembree@nahro.org

 

HUD COVID-19 Relief Bill Provisions

The third coronavirus (COVID-19) relief bill has passed the Senate unanimously. The relief bill now moves to the House for passage and then presumably to the President for his signature. The entire bill includes more than $2 trillion to help the United States economy.

Thank you to everyone that contacted your legislators through the NAHRO’s Advocacy Action Center. Your messages of how important affordable housing is during a pandemic played a critical role in the HUD programs receiving supplemental funding. Additional coronavirus resources are available at www.nahro.org/coronavirus.

The relief bill includes additional funds for HUD’s Public and Indian Housing (PIH), Community Planning and Development (CPD), and Office of Housing programs. The HUD funding in the bill is in line with the previously discussed Senate bill – except for the Community Development Block Grant (CDBG) funding, which is $5 billion in the relief bill. All the funding in the bill is in addition to the previously appropriated FY2020 funding. The chart below provides the amounts of the supplemental funding for select HUD programs from the relief bill.

Funding Bill Comparison ($Millions)

Program

Relief Bill

Tenant-Based Rental Assistance

$1.25 Billion

HAP Adjustments (included above)

$400 Million

Admin Fee (included above)

$850 Million

Public Housing Op Fund

$685 Million

Native Housing Programs

$300 Million

HOPWA

$65 Million

202 – Elderly

$50 Million

811 – Disabled

$15 Million

CDBG

$5 Billion

Homeless Assistance Grants

$4 Billion

Project-Based Rental Assistance

$1 Billion

In addition to the supplemental funding the relief bill includes several policy provisions including limited statutory and regulatory waivers. The program policy provisions, along with the funding for each, are described below.

Temporary Moratorium on Eviction Filings

The relief bill includes a provision that requires PHAs to implement a temporary moratorium on evictions. The moratorium applies to Public Housing, Housing Choice Vouchers, Low-Income Housing Tax Credit units, rural housing assistance, and other programs as defined by the Violence Against Women Act. The eviction moratorium will last for 120 days from the enactment of the relief bill. The PHA will not be allowed to file an eviction action for nonpayment of rent, fees, or charges and no late fees or penalties may be charged. A 30-day notice to vacate for nonpayment of rent cannot be issued until the expiration of the eviction moratorium. In practice, nonpayment of rent eviction hearings cannot be heard for 5 months from the enactment of the relief bill. The moratorium only addresses eviction for non-payment of rent evictions and does not address any other type of eviction. Evictions for issues such as criminal activity or safety of residents are, therefore, allowed.

Tenant-Based Rental Assistance (TBRA)

The relief bill provides $1.25 billion for tenant-based rental assistance.

Administrative Expenses – Of the relief bill’s $1.25 billion for the TBRA account, there is $850 million for additional administrative and other expenses PHAs encounter in administering Section 8 programs, including mainstream vouchers, in response to coronavirus. The bill states that these expenses shall be new eligible activities to be defined by HUD and shall be activities to “support or maintain the health and safety of assisted individuals and families and costs related to retention and support of current participating landlords.” Funds from the FY 2020 appropriations bill may also be used for these expenses.

Housing Assistance Payments (HAP) Adjustments – Of the relief bill’s $1.25 billion for the TBRA account, $400 million will be available for “adjustments in the calendar year 2020 Section 8 renewal funding allocations, including Mainstream vouchers.” These adjustments will be for those PHAs that “experience a significant increase in voucher per-unit costs due to extraordinary circumstances or that, despite taking reasonable cost savings measures,” as determined by HUD, would be forced to terminate voucher assistance.

Need-based allocation – The Department is instructed to allocate the above funding based on need as determined by HUD.

Section 811 – The relief bill allows for any amounts unobligated, including administrative expenses, that remain available after funding renewals and administrative expenses to be used for non-competitive section 811 tenant-based rental assistance to prevent, prepare for, and respond to coronavirus. HUD will award no less than 25 percent of the remaining amounts proportionately to PHAs who received awards in the 2017 and 2019 competitions within 60 days of enactment.

Family Unification Program (FUP) vouchers – Funds from tenant-protection vouchers used for youth in the FUP program and funds from FUP funding reserved for youths will not have to be reported to the appropriate congressional committees when grants are awarded.

Waivers – The relief bill allows that the Department may “waive, or specify alternative requirements for, any provision of any statute or regulation [except for requirements related to fair housing, nondiscrimination, labor standards, and the environment] that [HUD] administers in connection with the use of the amounts made available” in this bill or the FY 2020 appropriations act, upon a finding by HUD that waivers “are necessary for the safe and effective administration of these funds to prevent, prepare for, and respond to coronavirus.”

Notice of waivers – HUD must notify the public through the Federal Register or “other appropriate means to ensure the most expeditious allocation of this funding” of waivers or alternative requirements. A public notice at the appropriate government website or through other electronic media determined by HUD may suffice.

Length of waivers – Waivers or alternative requirements will remain in effect for the time and duration specified by HUD by public notice and may be extended by HUD.

Project-Based Rental Assistance

Project-based rental assistance – The relief bill provides $1 billion for project-based rental assistance. These funds are to “prevent, prepare for, and respond to coronavirus,” including funds to maintain normal operation and take other necessary actions, while the program is impacted by coronavirus. The funding is also for owners and sponsors of properties receiving project-based assistance.

Waivers – The Department may “waive, or specify alternative requirements for, any provision of any statute or regulation [except for requirements related to fair housing, nondiscrimination, labor standards, and the environment] that [HUD] administers in connection with the use of the amounts made available” in this bill, upon a finding by HUD that waivers are necessary “to expedite or facilitate the use of such amounts to prevent, prepare for, and respond to coronavirus” and the waivers are consistent with program purposes.

Notice of waivers – HUD must notify the public through the Federal Register or other appropriate means. At a minimum on the Internet at the appropriate government website or through other electronic media decided by HUD.

Public Housing

Public Housing Operating Fund – The relief bill provides $685 million to the Operating Fund. These funds would be distributed by the Operating Fund formula.

Public Housing Subsidy Flexibility – The relief bill allows PHAs fungibility of their Operating and Capital Funds so long as the funds are used to prevent, prepare for, and respond to coronavirus. This includes Operating and Capital Funds appropriated to PHAs prior to these bills. The ability to transfer funds between the Operating and Capital accounts will remain available through December 31, 2020. HUD can extend this provision in 12-month increments if needed.

Waivers – The relief bill allows HUD to provide waivers for statutory and regulatory requirements related to the Capital and Operating Fund if those waivers would help PHAs prepare for, prevent, and respond to coronavirus. These waivers will be released in the Federal Register.

Community Development Programs

HOPWA – The relief bill provides $65 million to HOPWA – $50 million to be distributed by formula and $10 million by one-time, non-renewable grants to existing contracts for permanent support housing that were initially made in FY 2010 and prior years.

The bill allows these funds to be used to help individuals living with HIV-AIDS relocate for the purposes of self-isolation, quarantine, or provide other coronavirus control services as recommended by the CDC.

Community Development Block Grant – The Community Development Fund receives $5 billion to be distributed as Community Development Block Grants (CDBG). Of this funding, $2 billion will be distributed to entitlement communities by formula and $1 billion will go directly to states to prepare for and respond to coronavirus based on need. The need-based formula will consider public health needs, the number of COVID-19 cases compared to the national average, and economic and housing disruptions. Allocations must be made within 45 days of enactment of the bill. HUD would have the discretion to distribute the remaining funds to states or local governments.

The relief bill allows entities an expedited procedure to amend their statements of activities to engage in coronavirus activities. In-person meetings are not required however entities must provide notice a comment period of no less than 5 days to receive public input. Virtual meetings are also allowed.

Homeless Assistance Grants – The relief bill provides $4 billion for the Emergency Solutions Grants (ESG) program. Of this, $2 billion will be distributed as formula grants and $2 billion will be distributed to states by a formula developed by HUD. The formula would consider risk of transmission of coronavirus, rising rate of sheltered and unsheltered homeless individuals, disruptions to economic and housing markets, and other factors.

The relief bill allows funding to be used for temporary emergency shelters, costs related to infectious disease prevention, and hazard pay. The Secretary may waive statutory and regulatory waivers as needed to prepare for, prevent, and respond to coronavirus. Up to one percent of the funds can be used to increase prior technical assistance awards that relate to providing health care services. Ten percent of the funds received by grantees can be used for administrative purposes. None of the funds provided can be used to require homeless individuals to enter treatment or perform any other prerequisite activity as a condition or receiving shelter, housing, or other services.

Policy and Legislative Contact Information

 Georgi Banna, Esq.

Director of Policy & Program Development

GBanna@nahro.org

Tess Hembree

Director of Congressional Relations

THembree@nahro.org

New Proposed Fair Housing Rule

Earlier this week, HUD published a new proposed fair housing rule titled “Fair Housing Act Design and Construction Requirements; Adoption of Additional Safe Harbors.” The Fair Housing Act provides that unlawful discrimination against persons with disabilities includes the failure to properly design and construct certain multifamily dwellings. This proposed rule would amend HUD’s regulations to incorporate the 2009 edition of International Code Council (ICC) Accessible and Usable Building and Facilities (ICC A117.1-2009) as satisfying the design and construction requirements of the Fair Housing Act. The proposed rule would also designate the 2009, 2012, 2015, and 2018 editions of the International Building Code (IBC) as safe harbors under the Fair Housing Act.

Comments on this proposed rule are due on March 16, 2020.

A press release from HUD can be found here.

The proposed rule can be found here.

HUD Webinars for new RAD Notice (Rev. 4)

The HUD Office of Recapitalization sent a RADBlast! email reminding those on the Rental Assistance Demonstration (RAD) email list that HUD will be hosting live public webinars on sections of the new RAD notice. The webinars will be recorded and posted on the RAD Resource Desk.

The schedule can be found below:

  • Public Housing Conversions, September 19, 2019, 2 pm ET; Register here;
  • Section 202 Project Rental Assistance Contract (PRAC), September 26, 2019, 2 pm ET; Register here;
  • Moderate Rehabilitation (Mod. Rehab.), October 3, 2019, 2 pm ET; Register here;
  • Resident Rights in Public Housing Conversions, October 10, 2019, 2 pm ET; Register here;
  • Resident Rights in Section 202 PRAC and Mod. Rehab. Conversions, October 17, 2019, 2 pm ET; Register here.

The new RAD notice (Rev. 4) can be found here.

New RAD Notice, Revision 4 Released

Earlier today, HUD released the new Rental Assistance Demonstration (RAD) notice: “Rental Assistance Demonstration – Final Implementation, Revision 4” (Notice H-2019-09; PIH-2019-23 (HA)). The RAD program allows for units to be converted from certain Department of Housing and Urban Development (HUD) funding streams, such as public housing, to either a Section 8 project-based voucher (PBV) funding stream or a Section 8 project-based rental assistance (PBRA) funding stream. There are several major changes in this notice, including changes to the First Component of RAD (which allows public housing units to be converted to PBV or PBRA) and implementation of the 2018 Appropriations Act provision allowing Section 202 project rental assistance contracts (PRAC) to be converted to PBV or PBRA.

The changes to the First Component of RAD include the following:

  • A policy that RAD rents will be updated every two years (RAD awards after each update will use the updated rents);
  • A newly added “Concept Call” step to the RAD process, to allow PHAs to receive confirmation that project plans are sufficiently advanced to submit a Financing Plan;
  • More stringent notice requirements for residents in developments to be converted (the new notice details resident participation requirements at each step of the RAD process);
  • A policy that all households residing in regular PBV units will have the same resident rights extended to them as households that reside in RAD-PBVs in converted developments;
  • A mechanism for PHAs to enter into partnerships with each other to convert developments;
  • A policy allowing for rent increases in certain scenarios for PBRA conversions, such as developments located in Opportunity Zones;
  • Elimination of the requirement to submit the Capital Needs Assessment (CNA) tool in certain scenarios; and
  • Other changes (including changed requirements for portfolio awards, a change in how PHAs report debts owed, and broadening the use of “tiered environmental reviews”).

At this time, NAHRO staff are still reviewing the new notice. Additional analysis will be provided in future NAHRO publications.

The RAD Notice, Revision 4 can be found here.

[2:17 pm edit – The new notice can also be found on HUD’s RAD website here.]

HUD, FHA Issue Condominium Rule

Last week HUD released the final rule on FHA approval for single-family condominiums. HUD touts the rule as opening the FHA single-family loan products to both younger, first-time home buyers and seniors looking to age-in-place.

The rule sets the policies to update the Single Family Policy Handbook, expand single-unit approval, establish minimum owner-occupancy requirements, limit FHA insurance concentration in condominium projects, and institute commercial/nonresidential space limits.  The rule is effective October 15, 2019, and HUD estimates that 20,000 to 60,000 condominium units could be eligible for FHA-insured financing annually.

HUD’s press release on the Condominium Approval Final Rule can be viewed here.

The Condominium Approval Final Rule is available here.