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Jennifer Emerling / There Is More Work To Be Done
Jennifer Emerling / There Is More Work To Be Done
Under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, only some non-citizens such as permanent residents, asylees, and refugees can receive “federal public benefits.” A recent notice announces that HUD will interpret “federal public benefits” to cover any grants it administers that are not explicitly governed by another statute. These include HOME, HOME-ARP, National Housing Trust Fund, CDBG, CDBG-DR, Housing Opportunities for Persons with AIDS formula and competitive programs, Emergency Solutions Grants, Pathways to Removing Obstacles to Housing (PRO Housing), the PRICE manufactured housing program, Continuum of Care, congressional earmarks, and SHOP. Nonprofits that administer these programs are not required to conduct eligibility verification, but states and other governmental entities must ensure compliance, HUD’s notice says. The department plans to issue new guidelines related to verification, including for benefits distributed by nonprofits, and will rely on guidance issued by the Department of Homeland Security once that is published.
Members of Congress are still negotiating the final National Defense Authorization Act, which must pass Congress and be signed by the president by December 31. The Senate passed a version of the NDAA that included the ROAD to Housing Act and several CDFI provisions as amendments, but the House NDAA did not incorporate those.
Two lawsuits challenge HUD’s changes to the funding notice for the Continuum of Care program. A group of states and governors launched one suit on November 25. Then the National Alliance to End Homelessness, the National Low Income Housing Coalition, two Rhode Island nonprofits, and several city and county governments filed suit on December 1. Both actions seek remedies including reinstatement of the original version of the CoC funding notice.
The National Coalition for the Homeless offers an organizing manual for communities that wish to host public events on or near December 21 to remember their neighbors who have died homeless in the past year.
Mortgage companies made up approximately 17% of rural lenders in 2024, but they originated 58% of all rural home-purchase mortgages that year. Source: Housing Assistance Council tabulations of the CFPB’s 2024 Home Mortgage Disclosure Act Data.
To learn more about mortgage lending and financing in your community, visit Rural Data Central.
The House Financial Services Committee held a hearing December 3 titled Building Capacity: Reducing Government Roadblocks to Housing Supply. The event covered dozens of legislative proposals, including several provisions of the Rural Housing Service Reform Act, which HAC supports: expanding the Section 504 home repair loan program, making accessory dwelling units eligible for Section 502 loan guarantees, requiring an annual rural housing report from USDA, studying technology modernization needs, and establishing an expectation for timely application review. Committee chair French Hill (R-AR) said during the hearing that the committee will develop a legislative package during markups to be held later this month.
In a November 26 letter, HUD Secretary Scott Turner “strongly recommend[ed]” that public housing agencies and owners of HUD-assisted rental properties “take advantage of all available tools to improve safety for communities and residents.” He rescinded guidance issued in 2015, 2016, and 2022 related to the use of criminal records for screening prospective tenants.
In March President Trump ordered several agencies, including the U.S. Interagency Council on Homelessness and the CDFI Fund, to be reduced to the bare minimum functions required by law. Twenty-one states filed suit to protect four of the agencies. (The CDFI Fund is not included in this litigation.) On November 21, a federal judge, concluding that the agencies had cut their staffs and activities below the levels needed to comply with the law, vacated the downsizing carried out so far and prohibited such actions in the future. The administration could appeal this decision.
Under U.S. immigration law, when a non-citizen applies for permanent resident status, officials can consider the likelihood that the person may become a “public charge,” someone who uses certain kinds of federal assistance including housing aid. The Department of Homeland Security proposes to rescind a 2022 regulation interpreting the public charge provision and will give its staff “broader discretion” on applying it. DHS says it will develop replacement policy and guidance in the future. Comments are due December 19.
The 2025 Compliance Supplement for the Office of Management and Budget’s guidance on uniform administrative requirements, cost principles, and audit requirements for federal awards is now available. It applies to fiscal year audits for any period beginning after June 30, 2024. Comments are due January 26.
Several recent proposals would reduce regulatory requirements for some lenders.
· Effective immediately, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation have rescinded the interagency Principles for Climate-Related Financial Risk Management for large financial institutions – those with over $100 billion in assets.
· OCC is considering rescinding its Fair Housing Home Loan Data System regulation, saying it is obsolete and duplicates or is inconsistent with other requirements. Comments are due December 18.
· OCC proposes to rescind its Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings, and Insured Federal Branches. Comments are due December 18.
· OCC wants to give community banks – those with less than $30 billion in total assets – “all currently available expedited or reduced filing procedures.” Comments are due January 20.
Stuart Levenbach, an official at the Office of Management and Budget, has been nominated to become the Director of the Consumer Financial Protection Bureau. CFPB’s current Acting Director is Russell Vought, who is also the Director of OMB.
The total number of U.S. households with the most significant housing needs dropped slightly from 2021 to 2023, but increased by 2% in counties outside metropolitan areas, according to HUD’s 2025 Worst Case Housing Needs report. Households with worst case housing needs are defined as renters with very low incomes who do not receive government housing assistance and pay more than one-half of their incomes toward rent, live in severely inadequate conditions, or both. There were 8.46 million renter households with worst case needs nationwide in 2023, close to the 8.53 million record high in 2021.
The National Rural Housing Coalition’s new Stories portal is built to elevate the voices, experiences, and successes of its members – rural housing and community development providers across the country. The Coalition plans to continue adding to the collection.
A recent Redfin analysis found that in many rural areas, housing costs are rising faster than incomes, intensifying affordability challenges. Rural homebuyers need to earn $74,500 to afford a typical home, up from $36,200 before the pandemic. The median home sale price in rural areas is up 61% from before the pandemic, compared with a 49% increase in suburban areas and 46% in urban counties. Meanwhile, the rural median household income has climbed 33%, less than the 37% in suburbs and 39% in urban areas.
A study by the Opportunity Finance Network, CDFI Fund Financial Assistance Awards and OFN Member Loan Funds, examined the impact on OFN members of receiving a first award from the CDFI Fund’s Financial Assistance programs for CDFIs or for Native American CDFIs. Members’ financial strength improved significantly, they were able to attract more additional capital, and their lending volume increased. Those that received larger awards relative to their total assets experienced the greatest proportional growth. Similarly, the Local Initiatives Support Corporation revealed in CDFI Impacts on Wealth and Assets that CDFI financing measurably strengthened the financial health of its borrowers.
A part of a series on innovations in community ownership, Shelterforce’s What Would it Take to Make Community Ownership the Rule, Not the Exception? explores models of community real estate ownership across the country and presents recommendations for steps that may make communal ownership more common and feasible.
The Legal Services Corporation’s Rural Justice Task Force was created to identify the unique challenges faced by rural Americans in accessing the legal system. Justice Where We Live: Promising Practices from Rural Communities reports on the Task Force’s findings. It includes recommendations and successful strategies for practitioners, policymakers, legal service providers, and others to make the legal system more accessible in rural areas.
HAC job listings and application links are available on our website.
· Housing Specialist | Community Builder
HAC’s loan fund provides low interest rate loans to support single- and multifamily affordable housing projects for low-income rural residents throughout the U.S. and territories. Capital is available for all types of affordable and mixed-income housing projects, including preservation, new development, farmworker, senior and veteran housing. HAC loan funds can be used for pre-development, site acquisition, site development, construction/rehabilitation and permanent financing. Contact HAC’s loan fund staff at hacloanfund@ruralhome.org, 202-842-8600.
Please note: HAC is not able to offer loans to individuals or families. Borrowers must be nonprofit or for-profit organizations or government entities (including Tribes).
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