Policy News from the Administration

HAC Comments on OMB Guidance on Grants and Agreements – December 2023

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The Office of Management and Budget (OMB) put out a call for comments on their guidance for Grants and Agreements, with a lens toward making grants processes more equitable. HAC submitted comments in support of more proactive geographic equity in the federal grants process. In addition to recognizing capacity building and access to capital as two essential equity issues in rural places, HAC’s comments focused on the recommendations below.

  • Instituting a Rural Impact Analysis for New Regulations
  • Investing in Capacity Building and Rural Intermediaries
  • Eliminating, Reducing or Modifying Cost-sharing and Matching Requirements that Disparately Impact Rural Communities
  • Streamlining and Increasing Uniformity in Applications
  • Including or Increasing Administrative and Predevelopment Costs as Eligible Activities in Rural Places
  • Recognizing the Rural Challenges in Metrics and Data Reporting
HAC Comments on OMB Guidance on Grants and Agreements 12.04.23

HAC News: November 30, 2023

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Vol. 52, No. 24

TOP STORIES

HAC provides preliminary analysis of new CRA rule’s rural implications

The new Community Reinvestment Act rule announced in October includes some important provisions for rural housing and community development. A new post on HAC’s website offers a preliminary look at these changes. For example, community development and retail lending are now given equal weight in the exams for large and intermediate sized banks. Also, it is now clear that all of a bank’s community development activities, even those not located in the bank’s defined Assessment Areas, count for CRA purposes. Other revisions are explained as well.

Research posters from HAC conference posted online, awards announced

Explore research posters online from the 2023 National Rural Housing Conference’s research poster session! The posters examine some of the most pressing issues facing rural America. HAC is thrilled to announce our poster contest award winners:

Fannie Mae extends pilot that reports positive rent payments to credit bureaus

Fannie Mae’s Positive Rent Payment pilot is being extended through December 2024, after its first year saw credit scores increase for almost 58% of participants. Fannie Mae will cover the costs of collecting and disseminating rent payment data for a 12-month period for multifamily property owner/operators of Fannie Mae financed properties who use an approved vendor to collect the data. Owners can enroll online. An explanation for renters is also posted online.

RuralSTAT

Rural America has historically had high homeownership rates. Rates in rural places and nationwide, however, are substantially lower for nonwhite residents than for white non-Hispanic households. Source: HAC tabulations of the U.S. Census Bureau’s 2021 American Community Survey.

OPPORTUNITIES

Environmental justice grants competition opens

EPA’s Community Change Grants program offers funds for environmental and climate justice activities to benefit disadvantaged communities through projects that reduce pollution, increase community climate resilience, and build community capacity to address environmental and climate justice challenges. Eligible applicants are community-based nonprofit organizations that partner with other CBOs, Tribes, local governments, or institutions of higher education. One of the program’s two tracks offers the option to focus on Tribes, U.S. territories, small unincorporated areas, or communities near the U.S.-Mexico border. Technical assistance is available. Applications will be accepted and reviewed on a rolling basis until November 21, 2024. For more information, email CCGP@epa.gov.

Grants offered for states and Tribes to create home efficiency rebate programs

State energy offices and Tribal entities are eligible for Department of Energy grants to create programs for Home Electrification and Appliance Rebates for high-efficiency electric homes and Home Efficiency Rebates for energy-saving retrofits in single-family and multifamily buildings. Rolling application processes are now open for states for both programs, and for Tribes for the Home Electrification and Appliance Rebates program. The American Council for an Energy-Efficient Economy offers information on ways to make these programs work for low-income residents.

Guidance available on tax credits for energy efficiency and community energy projects

The 2022 Inflation Reduction Act created new tax credits and improved existing ones for both property owners and builder/developers, for both housing retrofits and new construction. An overview of new programs is offered by Novogradac. A more detailed chart, published by Home Innovation Research Labs, covers eligibility, requirements, possible combinations with other programs, and more. A Treasury Department post focuses on use of these resources for multifamily housing.

The Section 45L New Energy Efficient Home Tax Credit for developers, including those using the Low Income Housing Tax Credit, is summarized by Novogradac and IRS guidance is offered in Notice 2023-65.

The Department of Energy continues to accept applications for the Low-Income Communities Bonus Credit program, which provides up to a 20 percentage point boost to the Investment Tax Credit for qualified solar or wind facilities in low-income communities. The IRS released final rules and guidance on the program, also called Section 48(e), in August.

Nominations open for historic preservation award

The Advisory Council on Historic Preservation and HUD offer the 2024 ACHP/HUD Secretary’s Award for Excellence in Historic Preservation, which will recognize developers, organizations, and agencies for success in advancing historic preservation goals while providing affordable housing and/or expanded economic opportunities for low- and moderate-income people. Eligible projects must promote the use of historic buildings for affordable housing, community development, and/or expanded economic opportunities; include HUD funds, financing, or other assistance; meet preservation guidelines; and contribute to local and/or Tribal community revitalization efforts. Nominations are due December 18.

REGULATIONS AND FEDERAL AGENCIES

Revisions proposed for Section 502 direct, Section 504, and Section 306C

USDA proposes to amend the regulations for these programs “to reduce the regulatory burdens on applicants, borrowers, and partners by enhancing program delivery, expanding customer service, promoting consistency between the direct and guaranteed SFH loan programs where feasible and aligning the programs with current housing market conditions and mortgage loan practices.” Comments are due January 19. For more information, contact Sonya Evans, USDA, 423-268-4333.

HUD proposes eviction notice for assisted tenants

A proposed rule would require that when tenants who live in public housing or in properties receiving HUD project-based rental assistance face eviction for nonpayment of rent, PHAs and owners would need to provide written notice at least 30 days before beginning a formal eviction procedure. Comments are due January 30. Contacts for more information vary by program and are listed in HUD’s notice.

Treasury clarifies timing for spending Coronavirus State and Local Fiscal Recovery Funds

In an interim final rule, the Treasury Department proposes to amend the definition of “obligation” in its regulations for the Coronavirus State Fiscal Recovery Fund and the Coronavirus Local Fiscal Recovery Fund. The changes, which will clarify when monies must be committed and spent, are effective November 20, but Treasury will accept comments until December 20. For more information, contact Jessica Milano, Treasury, 844-529–9527.

EVENTS

HUD to offer “Manufactured Housing and Tribal Communities” webinar

The session, set for December 6, will discuss specific considerations and recommendations for Tribal grantees interested in developing manufactured housing. It is the latest in a series of HUD manufactured housing webinars. Recordings and materials of past sessions will be posted online.

PUBLICATIONS AND MEDIA

USICH releases homelessness research agenda

On November 30, the U.S. Interagency Council on Homelessness published the first federal homelessness research agenda in more than a decade. The document, titled From Evidence to Action, is intended to shape federal investments in homelessness research and offer a roadmap to understand what works to prevent and end homelessness in the United States. It acknowledges that guidance must be tailored for specific populations and geographies including remote, rural, and Tribal lands.

ERS publishes rural data overview

USDA’s Economic Research Service has released its 2023 Rural America at a Glance report. The annual publication describes important demographic, economic, social, and housing trends over the last year. This year it shows that rural employment and annual growth rates are nearly back to pre-pandemic levels. A recorded webinar covering the report will also be available online.

HAC

HAC’s office is moving

After 43 years in our current D.C. location, HAC is moving. Our new street address, effective on January 1, 2024, will be 1828 L Street, N.W., Suite 505, Washington, DC 20036. Our phone number will remain 202-842-8600.

HAC is hiring

Need capital for your affordable housing project?

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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The New CRA Rule: A Preliminary Look at Potential Implications for Bank Investment in Rural Community Development

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On October 24, 2023, the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC) issued a final rule overhauling the regulations that implement the Community Reinvestment Act (CRA), which encourages federally insured banks to meet the credit needs of the communities in which they do business, especially low- and moderate-income (LMI) communities. This is the most significant joint effort in over three decades to modernize the way regulators evaluate bank performance under the CRA.

HAC is committed to helping our partners understand the potential impact of this new CRA rule. The rule, however, is nearly 1,500 pages in length, is highly complex, and will take effect over a nearly three-year period. Accordingly, this and forthcoming analyses must be considered preliminary.

The Evaluation Framework

Banks receive CRA ratings of “Outstanding,” “Satisfactory,” “Needs to Improve,” or “Substantial Non-Compliance.” The final rule continues the regulators’ longstanding approach of tailoring the CRA examination tests to bank size and type.[1] The final rule raises the current asset threshold for each of the bank size categories.

  • Large Banks (over $2 billion in assets) are subject to two tests of equal weight.
    • A Retail Lending Test evaluates a bank’s origination and purchase of loans, including home mortgage loans and multifamily loans if it offers them.
    • A Community Development (CD) Test consists of a CD Financing Subtest (40 percent of the total) and a CD Services Subtest (10 percent of the total).
    • A HAC analysis in 2016 found that 2.4 percent of banks headquartered in rural or small-town census tracts that consistently received “Outstanding” or “Satisfactory” ratings were subject to the large bank exam.
  • Intermediate Banks ($600 million-$2 billion in assets) are also subject to equally weighted Retail Lending and CD Tests.
    • The Retail Lending Test evaluates a bank’s origination and purchase of loans, including home mortgage loans and multifamily loans if it offers them.
    • Intermediate Banks may opt in or out of the new rule’s CD Test and CD Financing and CD Services Subtests.
    • Intermediate Banks that opt out are subject to the current CD Test, which has three subtests:
      • CD Lending
      • CD Investment
      • CD Services
    • HAC’s 2016 analysis found that 5.4 percent of banks headquartered in rural or small-town census tracts which consistently received “Outstanding” or “Satisfactory” ratings were subject to the intermediate bank exam (then known as the intermediate small bank exam).
  • Small Banks (less than $600 million in assets) may opt into the new rule’s Retail Lending Test – or may choose to continue to be evaluated under the current small bank test. They are not subject to a CD test.
    • HAC’s 2016 analysis found that 79.4 percent of banks headquartered in rural or small town census tracts that consistently received “Outstanding” or “Satisfactory” ratings were subject to the small bank exam.
  • Limited purpose banks—with just one primary product line such as credit cards (e.g., Amex Bank, Capital One)—are subject only to the CD Financing Subtest.
  • A Strategic Plan option allows banks of all sizes to choose to seek the regulators’ approval of a CRA strategic plan tailored to the bank’s lines of business and specific credit needs identified through a formal input process by the communities the bank serves.

Historically, bank examiners would conduct both quantitative and qualitative assessments of CRA performance under both the Retail Lending and CD Test and its subtests. Banks would be measured against benchmarks for lending and CD investment volume among other metrics relative to their size, business model, and comparable institutions. Quantitative ratings would be supplemented with qualitative assessments including taking account of the bank’s “performance context”—e.g., the economic conditions in the places it served—and determining whether a bank’s lending and CD investments were especially “responsive to a community’s credit and community development needs.” This qualitative element also allowed examiners to consider the terms and flexibility of bank CRA capital offered in particular LMI communities. Rural geographies benefitted especially from a qualitative component to CRA evaluation given their relatively greater capacity-constrained CD ecosystems and limited deal flow and transaction size.[2]

The final rule maintains the combined quantitative and qualitative CRA evaluation framework, but modifies and augments it in several important ways. The remainder of this analysis focuses on the rule’s approach to the new CD Test and Subtests and the potential ramifications for affordable housing and community development in rural America.

Opportunities for Rural Community Development Under the New CD Test

CRA-motivated bank investments, loans, and services have always played a role in rural community development.[3] But it has been challenging under the current CRA framework to increase bank commitments in rural communities, for a number of reasons—some of which are unique to rural areas and some of which are shared with urban and suburban communities.

First, as noted above, the large majority of banks headquartered in rural areas and small towns—and most likely to have branch and ATM networks there—are small banks not subject to a community development test at all. Intermediate-small and large banks were evaluated under the current rule primarily on their CD investments, lending, and services within their Assessment Areas (AAs), selected by the banks themselves and defined as the geographic areas that could reasonably be served by each of a bank’s locations, including its main office, any branches, and deposit-taking ATMs. Relatively few of their AAs encompassed rural geographies. As HAC’s research highlighted, large and intermediate bank support for rural communities faced an obstacle in their uncertainty about whether they would receive CRA credit for work outside their AAs.

The final rule makes major progress on addressing this challenge. While the new CD Test requires large banks and opting-in intermediate banks to meet the CD Financing and Services needs of their facility-based AAs, it also creates a “nationwide AA” to ensure that all CD Financing and Services activities contribute to an institution’s CRA rating.[4]

Second, the final rule highlights several factors that examiners will specifically take into account when conducting the qualitative “impact and responsiveness review” of a bank’s CD Financing and Services. These include whether the investment, loan, or service benefits or serves:

  • one or more Persistent Poverty Counties (PPCs);
  • residents of Native Land Areas; or
  • one or more geographic areas with low levels of community development financing.

Each of these factors will tend to reward bank CD Financing and Services in rural areas given their 1) demonstrable overrepresentation among PPCs, and Native Land Areas; and 2) likely overrepresentation among geographic areas with low levels of community development financing given consistent findings of underinvestment from other sources, such as philanthropy.[5]

Additional impact and responsiveness review factors specifically mentioned by the rule include bank financing that:

  • supports a Community Development Financial Institution (CDFI);
  • takes the form of a grant or donation; or
  • invests in a Low Income Housing Tax Credit (LIHTC) or New Markets Tax Credit (NMTC) project.

Given the scarcity of other public and private sector community development resources in rural areas, coupled with often challenged local economies, rural communities especially need the patient, flexible capital provided by CDFIs. Similarly, they have a disproportionate demand for grant funding and equity investments in CD projects and organizations rather than loans. Accordingly, an evaluation framework that specifically recognizes the impact and responsiveness of these approaches has the potential to benefit rural America.

For rural places, these factors may also interact positively with the above-mentioned addition of a “nationwide AA.” For example, a bank that today might hesitate to invest in a LIHTC or NMTC project outside of its facility-based footprint may choose to do so under the final rule, leading to a more geographically equitable distribution of resources over the long term.[6]

Third, CRA-motivated investment in all communities—urban, suburban, rural and small town—suffered under the prior CD Test from a lack of clarity around what loans, investments, or services were eligible for CRA credit. Other than a few long-deemed eligible activities, such as LIHTC or NMTC investments, banks and their community partners were often uncertain about the CRA impact of a new, innovative, or complex CD or affordable housing activity—often the very kinds of financial products and services needed by the most distressed rural communities.

The final rule states that the regulators will jointly “maintain a publicly available, non-exhaustive illustrative list of examples of community development activities that qualify for CRA consideration, including examples of qualifying affordable housing activities. The list will be periodically updated.” Additionally, the rule sets forth a formal process by which a bank can seek advance confirmation that a community development will be considered CRA-eligible.

Conclusion

As previously noted, the new CRA rule is a massive and complex document, representing a major shift in the implementation of this landmark statute. HAC and others will continue to analyze the rule—as well as early feedback from our partners as the transition period begins—and provide periodic updates. In the meantime, we urge our partners to consider approaching current or potential CRA-motivated funders of your work to inquire whether the aspects of the final rule described here might provide incentives for them to begin, increase, or modify favorable their CD financing and services investments in rural communities.

Footnotes

[1] The current CRA examination process is described in Making CRA Work in Rural America: Finding “Outstanding” Financial Institutions, part of HAC’s three-part series of reports “CRA in Rural America” published in 2016.

[2] When in 2019-2020, then-Comptroller of the Currency Joseph Otting put forth a CRA modernization rule shifting CRA evaluation to an entirely metrics-based approach, HAC submitted comments (as did numerous other affordable housing groups) expressing concern about the negative impact removing the qualitative element would have on banks’ incentive to invest in the most distressed rural and urban LMI communities.

[3] Indeed, CRA-motivated investments are a major driver of affordable housing and community development investment in general. For example, CohnReznick estimates that approximately $24.5 billion of capital was committed to housing tax credit investments in 2022 and that the CRA-motivated capital was the source for approximately 82 percent of that amount.

[4] Large national banks play an outsized role in CRA-motivated affordable housing and community. National banks control about 70 percent of the banking systems total assets. Over 99 percent of investments in LIHTC in 2022 from national banks were made by banks with over $10 billion in assets.

[5] The regulators note that currently there is not sufficiently comprehensive local CD financing data to implement this review factor, but expect to be able to do so in the near future, aided in significant part by the more detailed and robust bank CD data reported under the final rule itself.

[6] It should be noted that HAC joined other commenters on the proposed rule expressing concern that collapsing the prior CD Investment and Lending Subtests into a single CD Financing test might incentivize banks to make loans rather than equity investments in LIHTC and NMTC. The final rule’s inclusion of the equity review factor was designed to address this concern. It remains to be seen if banks do in fact maintain their investments in the LIHTC and NMTC markets.

HAC News: November 16, 2023

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Vol. 52, No. 23

TOP STORIES

Temporary government funding extended

President Biden is expected to sign into law a continuing resolution passed by the House on November 14 and the Senate on November 16. It extends fiscal year 2023 funding levels to January 19 for several agencies including USDA and HUD, and to February 2 for the rest of the federal government. The National Flood Insurance Program is also extended through February 2 and the Farm Bill through September 30, 2024. Congress now will resume efforts to pass individual appropriations bills.

RuralSTAT

Single-family detached units make up about 60% of homes nationwide, but over 72% in rural America. Manufactured or mobile homes are nearly twice as common in rural areas as in the entire U.S., while structures with two or more units are less than half as common. Source: HAC tabulations of the U.S Census Bureau’s 2017-2021 American Community Survey.

OPPORTUNITIES

HAC assists Section 515 preservation/transfers in more places

HAC and other organizations offer technical assistance to nonprofits on acquisition, transfer, and preservation of USDA Section 515 multifamily properties, including assistance with third party costs. HAC’s Section 515 TA service area has expanded and now includes AK, AL, AR, AZ, CA, CO, FL, GA, HI, ID, KY, LA, MS, MT, NC, NM, NV, OK, OR, PR, SC, TN, TX, UT, VI, WA, and WY. Current owners of Section 515 properties who are interested in transferring ownership to a nonprofit organization, or nonprofits who are interested in acquiring one, can reach out to Kristin Blum at HAC or find another TA provider on the Contact tab at this link. TA is also available for development of Section 514/516 farmworker properties in some states; click the Contact tab at this link.

HUD offers funding to address youth homelessness

Nonprofits, PHAs, Tribal housing entities, and state, local, or Tribal governments are eligible for Youth Homelessness System Improvement grants. Projects can include youth action boards; regional committees to direct efforts across multiple systems including education, justice, and child welfare; data collection and use; leadership development; and improvement of homeless assistance projects to better serve youth. Additional points are offered for applications that cover either an entire state or geographic areas in two or more Continuums of Care. The deadline is February 15. For more information, contact Nili Soni, HUD, 202-402-2973, YHSI@hud.gov.

CAPITOL HILL

Senators hope to help rural places access federal resources

The Rural Partnership and Prosperity Act, S. 3309, introduced November 15 by U.S. Senators Bob Casey (D-PA) and Deb Fischer (R-NE), would create a grant program to address rural communities’ needs like affordable child care, housing, and job training; provide guidance to help rural communities navigate existing federal funding opportunities; and improve supportive services offered by the federal government to rural communities. Supporting the measure, HAC President and CEO David Lipsetz noted, “This bill would empower rural regions by supporting locally-led planning and capacity building efforts, and providing flexible funding to meet critical needs.”

REGULATIONS AND FEDERAL AGENCIES

Comments invited on proposed changes to 2023 Duty to Serve plans

Both Fannie Mae and Freddie Mac propose to decrease loan purchase targets across multiple components of their Duty to Serve plans, citing reduced overall volume due to interest rates and market conditions as their reasons. Several of the changes would impact rural housing. Comments are due December 6. For more information, email DutyToServeStakeholders@FHFA.gov.

EVENTS

Energy efficiency webinar to include rural strategies

Bringing Energy Efficiency to Underserved Households: Examples to Emulate will explore a new toolkit from the American Council for an Energy-Efficient Economy highlighting best practices for increasing energy efficiency program participation among underserved residential customers. The webinar, set for November 30, will cover strategies for programs to better reach all underserved households as well as specific strategies for reaching renters, income-eligible households, and rural households.

PUBLICATIONS AND MEDIA

Low Income Housing Tax Credit recommendations updated

The National Council of State Housing Agencies provides recommended voluntary standards related to allocation, underwriting, and compliance monitoring for state agencies that administer the Low Income Housing Tax Credit. Recommended Practices in Housing Credit Administration: 2023 Update includes sections on facilitating rural and Native American housing development with the credit.

Research considers disasters and assisted housing

Natural Hazards and Federally Assisted Housing, a report from the National Low Income Housing Coalition and the Public and Affordable Housing Research Corporation, analyzes the risks that natural hazards pose to federally assisted housing and its residents. The study notes that federally assisted homes in rural areas are more vulnerable to damages from natural hazards than homes in urban areas are, and discusses several factors that contribute to rural vulnerability.

Flood Damage and Federally Backed Mortgages in a Changing Climate, by the Congressional Budget Office, considers the costs of one specific type of disaster – floods – related to owner-occupied homes backed by Fannie Mae, Freddie Mac, VA, or FHA. USDA mortgages were excluded because of data limitations. CBO found that expected flood damage is concentrated in certain geographic areas, such as the Atlantic and Gulf Coasts. About half of flood damage is estimated to occur in areas where homeowners are not required to carry flood insurance.

Disasters and the Rental Housing Community: Setting a Research and Policy Agenda, published by the Brookings Institution, points out the gaps in public responses to disasters for renters, rental properties, and rental housing stakeholders. Recommendations to address key challenges include: 1) universal renter protections; 2) the prioritization of low-income renters in all disaster programs; and 3) requirements for state and local governments to enforce tenant protections and support tenants and rental housing in exchange for access to federal disaster funding.

Research considers why Black families less likely to leave wealth for heirs

A new Urban Institute report, Intergenerational Wealth Transfers: Do Expectations of Leaving an Inheritance Differ Between Black and White Families?, shows that while Black families are as likely as whites to expect and desire to leave a sizeable estate to their descendants, Black families have less wealth to leave to younger generations because of the compounded effects of systemic racism. Barriers to wealth transfer include title issues such as heirs’ property and access to estate planning.

Farmworkers’ wages far lower than those of comparable workers

The Economic Policy Institute reports that in 2022, farmworkers earned 40% less than comparable nonagricultural workers. Another recent EPI post explains the varied data about the number of farmworkers employed in the U.S., concluding that 2.4 million is the best available estimate.

HAC

HAC’s office is moving

After 43 years in our current D.C. location, HAC is moving. Our new street address, effective on January 1, 2024, will be 1828 L Street, N.W., Suite 505, Washington, DC 20036. Our phone number will remain 202-842-8600.

HAC is hiring

Need capital for your affordable housing project?

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).

Want to reprint a HAC News item?

Please credit the HAC News and provide a link to HAC’s website. Thank you!

 

Report Released on Natural Hazards and Federally Assisted Housing

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The National Low Income Housing Coalition (NLIHC) and the Public and Affordable Housing Research Corporation (PAHRC) released today a joint report, Natural Hazards and Federally Assisted Housing, that analyzes the risks that natural hazards pose to federally assisted housing and its residents. Federally assisted housing and its residents must be protected against climate change and the growing threat of natural hazards through better planning and stronger investments in resilience.

HAC News: November 2, 2023

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Vol. 52, No. 22

TOP STORIES

Second continuing resolution needed by November 17

The federal government is currently funded by a continuing resolution that ends November 17, and a second CR will be necessary to keep programs running while full-year appropriations bills are prepared. Both the House and Senate are trying to move forward on enacting FY24 funding bills, but progress is slow and most of the bills, including those for USDA and HUD, differ widely between the two chambers. On November 1, the Senate passed a “minibus“ that includes funding for USDA, Transportation-HUD, and Military Construction-VA. The House may vote November 2 or 3 on some of its funding bills, including Transportation-HUD. In September the House voted on, but did not pass, its USDA appropriations bill. President Biden will veto the House THUD and USDA bills if passed in their current forms.

Final Community Reinvestment Act rule released

The federal banking regulatory agencies – the Federal Reserve Board, FDIC, and Office of the Comptroller of the Currency – have issued a final revised Community Reinvestment Act rule, most of which will take effect on April 21, 2024. The rule modernizes the CRA evaluation framework in several ways that will benefit rural areas. Two modifications to the reliance on facility-based assessment areas should increase community development activities in rural areas: the rule uses counties rather than census tracts as the defining geography for facility-based assessment areas, and it enhances CRA credit for bank community development activities outside of facility-based assessment areas. For large banks, it gives equal weight to community development activities and retail lending. Community development activities in persistent poverty counties, Native lands, and colonias, all of which are disproportionately rural, are designated as impact factors. And it emphasizes “responsiveness to community need” and other qualitative factors as well as metrics.

HAC’s decennial Taking Stock report analyzes rural America

Taking Stock: Rural People, Rural Places, Rural Housing, released at the 2023 National Rural Housing Conference, is the fifth in a series of decennial reports covering social, economic, and housing trends. For the first time the report includes interactive, digital, and new media resources. Chapters cover “The New (and Evolving) Rural America,” “Rural People and Places,” “The Rural Economy,” and “Rural Housing.”

President Biden launches “Investing in Rural America” events

On November 1, President Biden launched a two-week Investing in Rural America Event Series. Cabinet members including Secretary of Agriculture Tom Vilsack, as well as other administration officials, will visit a variety of rural places to announce funding awards in economic development (including housing), infrastructure (including community facilities), high-speed internet, agriculture, and renewable energy.

National Rural Housing Conference convenes stakeholders to “Build Rural”

Nearly 700 rural housing practitioners and policymakers came together in Washington, DC on October 24-27 for the 2023 National Rural Housing Conference. Recordings of the plenary sessions are available online, including a discussion with Senators Tina Smith (D-MN) and Mike Rounds (R-SD), a presentation by Professor Kathryn Edin on the injustice of place, an overview of HAC’s new Taking Stock report, and more. Anyone who registered for the conference can access workshop materials and more through the conference app or by logging into the Attendee Hub. HAC thanks our many sponsors, scholarship contributors, and partners for helping to make the event possible.

November is National Native American Heritage Month

 

November is National Veterans and Military Families Month

 

RuralSTAT

In 1790, nearly 95% of the U.S. population, over 3.7 million people, lived in rural places. By 2020 the rural population grew to more than 60 million people but accounted for just 18.1% of all U.S. residents. Source: HAC tabulations of historic Census Bureau data.

OPPORTUNITIES

HUD offers funding for Section 811 housing for persons with disabilities

Nonprofits and limited partnerships can apply for capital advances and rental assistance under the Section 811 Supportive Housing for Persons with Disabilities Program, which supports the development of, and ongoing rental assistance for, permanent supportive rental housing for very low-income persons with disabilities. The deadline for both capital advances and Project Rental Assistance Contracts is February 12. For more information, contact HUD staff, 811CAPAdvance@hud.gov or 811PRANOFO@hud.gov.

ROSS service coordinator funds available

HUD’s Resident Opportunity and Self-Sufficiency Service Coordinator Program funds service coordinators for public and Indian housing. Nonprofits, PHAs, Tribal governments and Tribal housing entities, resident associations, and some owners of multifamily housing are eligible to apply by December 18. For more information, contact HUD staff, 202-402-3624, ROSS-PIH@hud.gov.

Government entities can apply for hazard mitigation funds

FEMA’s Building Resilient Infrastructure and Communities (BRIC) grant program provides funds to states, U.S. territories, federally recognized Tribal governments, and local governments for hazard mitigation activities including capacity building, hazard mitigation projects, and management costs. Apply by February 29. For more information, contact FEMA staff, 1-877-585-3242, femago@fema.dhs.gov.

Initiative will help rural communities plan to address substance use issues

Reaching Rural: Advancing Collaborative Solutions, a one-year initiative sponsored by a group of federal agencies, will help individuals or cross-sector teams develop plans to address substance use issues in their communities. The planning fellowships do not offer funding but include an opportunity at the end of the year to apply for grants of up to $100,000 to launch projects. An informational webinar will take place on November 14 and applications are due December 15. For more information, email COSSUP@iir.com.

REGULATIONS AND FEDERAL AGENCIES

Community Facilities program input requested

USDA Rural Development is considering changes to its Community Facilities direct loan and grant programs, including expanded eligibility for housing funding. Comments can be presented at an online listening session on November 7 or submitted in writing by December 8. For more information, contact Surabhi Dabir, USDA, 202-568-9315.

HUD has new Buy America info page and webinars, OMB issues new memo

A new Build America, Buy America Act page was recently launched on the HUD Exchange to provide resources for entities receiving funding from HUD’s Community Planning and Development programs, which include HOME, CDBG, SHOP, Continuum of Care, Veterans Housing, and more. Three quick guides are offered, and more are planned in both English and Spanish. Submit questions on CPD topics here. Also, several webinars are scheduled, including one on November 2.

A more general BABA section on HUD’s website provides information such as what types of assistance are not covered by the Buy America preference and an illustration of HUD’s phased implementation schedule.

The Office of Management and Budget, which oversees BABA for all federal agencies, issued a new implementation guidance memorandum on October 25, M-24-02, replacing M-22-11 issued in April 2022. The new memo aligns with OMB’s recent final rule on the subject.

Use of CDBG funds for housing, including manufactured housing, described

HUD Notice CPD-23-10, Use of CDBG Funds in Support of Housing, describes how Community Development Block Grant grantees can use this funding to support and promote the development of decent, accessible, equitable, and affordable housing in their communities. It includes changes relating to manufactured housing, and those provisions will be the subject of a November 8 webinar.

HUD considers allowing agencies to opt out of in-person housing counseling

A proposed change in HUD’s housing counseling regulations would allow counseling agencies to provide their services virtually rather than in-person. Agencies that choose not to provide in-person services would be required to refer clients to local providers that provide such services, when requested. Comments are due December 26. For more information, contact David Valdez, HUD, 713-718-3178.

Multifamily insurance changes proposed by USDA

Revisions to the requirements on multifamily housing insurance coverage and deductibles are intended to bring the 2004 regulations in line with current affordable housing industry standards. Comments are due December 26. For more information, contact Michael Resnik, USDA, 202-430-3114.

Broadband expansion in HUD-assisted communities planned, comments requested

HUD plans to expand its ConnectHomeUSA initiative to between 50 and 100 new communities to further the collaborative efforts by government, industry, and nonprofits to accelerate broadband internet adoption and use in HUD-assisted homes. Comments are due December 18. HUD will accept applications between December 19, 2023 and February 15, 2024. For more information, contact Dina Lehmann-Kim, HUD, 202-402-2430.

Duty to Serve and other housing activities evaluated

A new Federal Housing Finance Agency report describes Fannie Mae’s and Freddie Mac’s affordable housing activities during 2022. Both entities met their single-family and multifamily affordable housing goals. Under the Duty to Serve requirements, both received “low satisfactory” ratings for affordable housing preservation activities and “high satisfactory” ratings for rural housing activities. For manufactured housing, Fannie Mae’s performance was rated “low satisfactory” and Freddie Mac’s was rated “high satisfactory.”

EVENTS

Monthly virtual trainings set for Section 502 guarantee program

Free virtual trainings on topics related to USDA’s Section 502 guarantee program will begin on November 8 with Program Overview: 101. Future sessions are planned through September 2024. In-person training will also be offered in spring 2024.

Manufactured housing webinar series begins

HUD’s four-part webinar series aims to help increase understanding of how manufactured housing can be a sustainable solution to meeting a community’s affordable housing needs. Introduction to Manufactured Housing was held November 1. Overview of the Updated CPD Notice on CDBG Housing Activities is set for November 8. Future sessions will include “Using Federal Funding Sources to Develop Manufactured Housing” and “Manufactured Housing and Tribal Communities.” For more information, contact the series registrar, info@capitalaccessinc.com.

HUD session to cover cash aid and housing

Cash Assistance and Housing, a hybrid event to be held in Washington, DC and online on November 16, will examine guaranteed income programs, which provide direct payments to local participants, and their impact on housing opportunities in Philadelphia and Denver.

PUBLICATIONS AND MEDIA

Policies and biases left the rural economy behind, research concludes

The booming knowledge economy of the last four decades has contributed to the increasing disparity in opportunity between rural and nonrural places, according to an analysis by the Center on Rural Innovation. The Equity of Economic Opportunity in Rural America argues that policies and biases have concentrated knowledge economy resources and investment in nonrural places, making it more difficult for rural areas to compete. Investing in rural knowledge economies is the best way to address these root causes and help rural economies catch up, the report concludes.

Study suggests changes for HUD program addressing homelessness after disasters

Plugging the Gaps: Recommendations for HUD’s RUSH Program, published by the National Low Income Housing Coalition and the National Housing Law Project, reports on HUD’s new Rapid Unsheltered Survivor Housing (RUSH) program, which is intended to help people experiencing or at risk of homelessness in disaster-affected areas. Its recommendations include ensuring equity in allocation decisions, providing RUSH funds up front instead of by reimbursement, and imposing requirements for timely use of funds.

Analysis considers why census found huge increase in Native Americans

The 2020 census counted 9.6 million people with fully or partly Native American heritage, compared to 5.2 million in 2010. A Washington Post data analysis, The Native American Population Exploded, the Census Shows. Here’s Why, examines the reason for the jump and concludes it was not due to procreation or to immigration of Natives from other countries, but instead to the way the race question was phrased on the census form and, even more importantly, how responses were coded.

HAC

HAC is hiring

  • The Rental Housing Development and Preservation – Housing Specialist will provide technical assistance support to nonprofit organizations involved in multifamily housing programs, with a specific focus on USDA 515 and HUD rural housing programs. This position is remote work eligible.
  • The Rental Housing Development and Preservation Housing Specialist – Senior Level Position is a senior-level role that combines expertise in multifamily housing programs, specifically focusing on USDA 515 and HUD rural housing programs, with the responsibility of providing technical assistance, with a particular focus on transfers of USDA 515 properties. This position is remote work eligible.
  • The Senior Accountant is responsible for applying technical and leadership skills to guide accounting practices and recording of transactions. This position is hybrid, based in Washington, DC.
  • The Executive Assistant supports the work of HAC’s Chief Executive Officer, senior leadership, and board of directors. The position is a blend of administrative work and project assignments. This position is based in Washington, DC.

Need capital for your affordable housing project?

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).

Want to reprint a HAC News item?

Please credit the HAC News and provide a link to HAC’s website. Thank you!

Taking Stock of Rural America

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5 DECADES OF TAKING STOCK IN RURAL AMERICA

RURAL PEOPLE, RURAL PLACES, RURAL HOUSING

First published in 1984, Taking Stock is a decennial research publication of the Housing Assistance Council. The 2023 edition of Taking Stock continues this legacy of presenting social, economic, and housing trends for rural places and rural people.


Visit TakingStockRural.org


In the early 1980s, the Housing Assistance Council (HAC) published its initial Taking Stock report. This seminal work was one of the first comprehensive assessments of rural housing and rural poverty conditions in the United States. The first Taking Stock also exposed the plight and housing need of the nation’s high poverty rural areas. HAC’s decennial Taking Stock analysis continued in 1990, 2000, and 2010 and has increasingly expanded to cover a broader scope of social, economic, and housing trends in rural areas. The 2023 edition of Taking Stock continues its legacy of presenting a composite picture of trends and issues important to rural people, places, and housing.

HAC News: October 12, 2023

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Vol. 52, No. 21

TOP STORIES

Government funded through November 17

On September 30, Congress passed a continuing resolution and the President signed it into law. It funds the federal government through November 17, keeping most programs at FY23 levels, and also extends the National Flood Insurance Program to the same date. If there is no agreement by then on full-year funding, the government could face a shutdown threat again. The House and Senate have other priorities to address and also have very different funding proposals for most agencies. The only USDA or HUD appropriations bill that has received a floor vote so far, the House’s Agriculture bill, did not pass.

Next HAC News to be published November 2

The HAC News will be published in three weeks rather than two because on October 26 HAC’s staff and many of our readers will be busy at the 2023 National Rural Housing Conference. Look for the next issue in your email on Thursday, November 2!

October is National Domestic Violence Awareness and Prevention Month

President Biden’s proclamation includes a reminder that for 24/7 immediate and confidential support, survivors can connect with the National Domestic Violence Hotline at thehotline.org, call 1-800-799-7233 (TTY 1-800-787-3224), or text “START” to 88788. Resources on the Violence Against Women Act, which includes legal protections related to assisted housing, are available from HUD and from the National Housing Law Project.

October 22-28 is National Lead Poisoning Prevention Week

HUD has posted resources and links to more from EPA and the Centers for Disease Control.

RuralSTAT

The average cost of homeowners insurance and a flood insurance policy could account for around 7% of the median household income in the eastern Kentucky counties impacted by the 2022 flood. Only 5% of damaged homes had flood insurance, and households earning $30,000 or less per year accounted for 60% of damaged homes. Source: Federal Reserve Bank of Cleveland, Resilience and Recovery: Insights from the July 2022 Eastern Kentucky Flood.

OPPORTUNITIES

HUD offers fair housing initiatives funding

The application deadline is November 30 for four separate opportunities: the Education and Outreach Initiative, the Education and Outreach Initiative – Test Coordinator Training, the Fair Housing Organizations Initiative, and the Private Enforcement Initiative. For more information, contact Stephanie Thomas, HUD.

Agencies launch tools to find energy and environment funding

HUD’s Build for the Future Funding Navigator offers information on funding opportunities aimed at decarbonization, sustainable development, and community resilience. The Energy Department’s Funding and Incentives Resource Hub is intended to help identify rebates, funding, and other incentives for energy efficiency upgrades, renewable energy and decarbonization projects, and other sustainability initiatives.

REGULATIONS AND FEDERAL AGENCIES

USDA, HUD, and others address discrimination based on shared ancestry, ethnic characteristics, or religion

Eight federal agencies have clarified in writing that the Civil Rights Act prohibits discrimination based on shared ancestry or ethnic characteristics in federally funded programs and activities (HUD, USDA, White House). This includes forms of antisemitic, Islamophobic, and related discrimination and bias. HUD and USDA offer fact sheets that include examples of discriminatory actions.

Comments sought on flood risk management

FEMA proposes to amend its regulations to implement the Federal Flood Risk Management Standard and update its decision-making process for floodplain reviews. To supplement the regulations, it also suggests a policy that would further clarify how it would apply the FFRMS. Comments are due December 1. For more information, contact Portia Ross, FEMA, 202-709-0677.

Guidance released on HUD-assisted tenants’ income and assets

HUD Notice PIH 2023-17 offers guidance for public housing agencies and owners of HUD-assisted rental properties to implement Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016. These provisions change the requirements for tenant income reviews and tenant assets for public housing and Section 8 participants.

HUD suggests no changes to Section 3 benchmarks

HUD proposes to keep using its 2020 benchmarks to gauge compliance with Section 3, which requires employment and other economic opportunities generated by federal housing and community development programs to be directed toward low- and very low-income persons to the greatest extent feasible. The department requests public comments, particularly on experiences with the benchmark goals, with no specific submission deadline. For more information, contact Nathan Roush, HUD, 678-732-2045. General email inquiries regarding Section 3 may be sent to Section3@hud.gov.

OMB to revise guidance on grants and agreements

The Office of Management and Budget suggests revisions to several parts of its Guidance for Grants and Agreements in Title 2 of the Code of Federal Regulations, including Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). Comments are due December 4. For more information, email mbx.omb.offm.grants@omb.eop.gov.

USDA extends deadline for manufactured housing comments

Comments are now due October 31 rather than October 16 on USDA’s proposed rule that would expand use of the Section 502 direct and guaranteed programs for manufactured housing. For more information, contact Sonya Evans, USDA, 423-268-4333.

EVENTS

Register for the National Rural Housing Conference

Register now to join stakeholders in the field of rural affordable housing, community development, and placemaking at the 2023 National Rural Housing Conference October 24-27 in Washington, DC. The 2023 conference theme is Build Rural – both a literal and figurative appeal to explore and provoke action to build and renew rural communities by addressing housing affordability and preservation, community infrastructure and essential facilities creation and revitalization, resident led placemaking, capacity building, and community inclusion and justice efforts.

Webinar on rural housing set for November 6

Rural Housing Webinar, offered free by SaveYour.Town, will discuss demographic changes and what to do about them, creative ways to tailor housing solutions locally, and converting existing buildings into new housing through adaptive reuse.

PUBLICATIONS AND MEDIA

Climate Vulnerability Index shows disproportionate risk for Black and Native Americans

The Environment Defense Fund and Texas A&M researchers created the U.S. Climate Vulnerability Index, a new mapping and data tool, which outlines 184 climate risks for every census tract in the country. Socioeconomic and health disparities result in Black and Indigenous residents being most susceptible to death due to extreme heat. Systemic disinvestment in Black communities results in disproportionately higher risks of climate change effects. Seven of the ten most at-risk counties have a higher proportion of Black residents than the U.S. average of 12%.

Study examines philanthropy for the rural U.S.

“Giving for Rural Communities” is part of a State of American Philanthropy series published by Inside Philanthropy. The paper describes rural philanthropy, reviews rural issues and philanthropic responses, considers fundamental questions about rural designation and giving data, and offers recommendations to support the continued evolution of the field.

Recommendations address heirs’ property

Preserving Generational Wealth by Untangling Titles for Heirs Property Homeowners explains how heirs’ property develops as landowners die without wills. The paper, published by the JPMorgan Chase & Co. Policy Center, offers strategies to resolve existing heirs’ property cases and to prevent development of such title problems in the future.

States improving fair housing provisions in tax credit plans

Many states’ Qualified Allocation Plans show significant improvement in provisions related to fair housing since 2015, the Poverty and Race Research Action Council reports in Building Opportunity III: Affirmatively Furthering Fair Housing in the Low Income Housing Tax Credit program. Some states, however, still lag behind.

Kentucky flooding and housing studied

In July 2022, serious flooding turned 13 eastern Kentucky counties into federally declared disaster areas. The impact on housing is the focus of Resilience and Recovery: Insights from the July 2022 Eastern Kentucky Flood, a report from the Federal Reserve Bank of Cleveland. In addition to findings on the prohibitive cost of flood insurance and the shortage of affordable housing, the report notes that floods increase population out-migration, which, in turn, impacts the local labor force; and that the pre-existing weakness of local labor markets will likely impact housing recovery, particularly due to a lack of skilled tradespeople.

U.S. gets failing grade on human right to housing

The U.S. receives an F in “affordability” and still has much room for improvement in other areas, according to the Human Right to Housing Report Card 2023 issued by the National Homelessness Law Center and University of Miami Law School Human Rights Clinic. The report card assesses the U.S. government’s performance on ensuring that adequate, affordable housing is available to all. It also cites numerous areas of hope, drawn from federal interventions to protect vulnerable homeowners, renters, and unhoused persons during the pandemic.

Social services organizations important in rural economic development work, survey finds

Large metropolitan areas have a disproportionately large share of community economic development (CED) groups’ revenues, expenditures, and assets compared to these places’ share of poverty, a recent survey found, while medium-sized metro areas have a disproportionately small share. Nationwide, the number of CED groups outside metro areas and their revenues are roughly comparable to their share of national poverty, with an outsized share of their revenues from government, probably because many are social services groups. These findings and others are reported by the National Alliance of Community Economic Development Associations (NACEDA) in Community Economic Development Organizations, Geography, and Financial Resources.

HAC

HAC is hiring

  • The Rental Housing Development and Preservation – Housing Specialist will provide technical assistance support to nonprofit organizations involved in multifamily housing programs, with a specific focus on USDA 515 and HUD rural housing programs. This position is remote work eligible.
  • The Rental Housing Development and Preservation Housing Specialist – Senior Level Position is a senior-level role that combines expertise in multifamily housing programs, specifically focusing on USDA 515 and HUD rural housing programs, with the responsibility of providing technical assistance, with a particular focus on transfers of USDA 515 properties. This position is remote work eligible.
  • The Senior Accountant is responsible for applying technical and leadership skills to guide accounting practices and recording of transactions. This position is hybrid, based in Washington, DC.
  • The Financial Controller is responsible for day-to-day management of HAC’s finance and accounting processes. This position is eligible for a hybrid schedule.
  • The Senior Human Resources and Payroll Administrator oversees all aspects of human resources and payroll practices and processes. This position is eligible for a hybrid schedule.
  • The Executive Assistant supports the work of HAC’s Chief Executive Officer, senior leadership, and board of directors. The position is a blend of administrative work and project assignments. This position is based in Washington, DC.

Need capital for your affordable housing project?

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).

Want to reprint a HAC News item?

Please credit the HAC News and provide a link to HAC’s website. Thank you!

HAC News: September 28, 2023

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Vol. 52, No. 20

TOP STORIES

Government may shut down

As of Thursday morning, September 28, Congress has not been able to agree on a funding measure to keep the government operating beyond the end of the fiscal year on September 30. What HAC knows about the possible effects on housing assistance is explained on our website and is currently the same information we reported in the HAC News of September 18. We expect USDA RD will soon release more details about potential impacts on its rural housing programs. As we learn more, we will update the website and post notices on our Facebook and LinkedIn pages.

Shutdown would threaten flood insurance

The National Flood Insurance Program, run by FEMA, provides coverage for a large proportion of all U.S. homes with flood insurance. Its authorization will expire on September 30 unless Congress reauthorizes it in a continuing resolution or other legislation. If it lapses, contracts entered into before September 30 will remain in effect until 30 days past their renewal dates and FEMA will continue paying claims as long as it has funds available. NFIP will not be able to issue new insurance or renew existing contracts when they expire, however, and the National Association of Realtors® estimates that a lapse in NFIP authorization could threaten 1,300 property transactions per day.

RuralSTAT

No geography – central cities, urban suburbs, rural suburbs, or places outside metro areas – comes close to having enough affordable, available, and adequate housing units for renters with extremely low (below 30% of area median income) or very low (below 50% of AMI) incomes. Outside metro areas, there are only 44.2 such units for every 100 extremely low-income renters and 66.5 for every 100 very low-income renters. Source: HUD, Worst Case Housing Needs: 2023 Report to Congress.

OPPORTUNITIES

HUD opens Healthy Homes and Weatherization Cooperation Demo

Nonprofits and state, local, and Tribal governments that have active Department of Energy Weatherization Assistance Program grants or subgrants or HUD Healthy Homes Production grants are eligible for HUD’s Healthy Homes and Weatherization Cooperation Demonstration to explore the potential advantages of coordinating these home intervention services. Applications are due October 31. For more information, contact Brenda M. Reyes, HUD, 202-402-6745.

Small cities main street grants deadline is October 12

HUD’s HOPE VI Main Street Program provides grants to communities with populations under 50,000 to assist in the renovation of historic, traditional central business districts or  “Main Street “ areas by replacing unused, obsolete commercial space in buildings with affordable housing units. Applicants must be local governments whose jurisdiction includes a Main Street area; nonprofits, for-profits, and others can be subcontractors. For more information, contact Susan Wilson, HUD, 202-402-4500.

Coronavirus funds can be used for disasters, transportation, and community development

Comments are due November 20 on a Treasury Department interim rule expanding allowable uses of State and Local Fiscal Recovery Funds to include disaster relief, surface transportation, and CDBG-eligible community development. For more information, contact Jessica Milano, Treasury, 844-529-9527.

Deadline extended for USDA Discrimination Financial Assistance Program

The original October 31, 2023 application deadline has been changed to January 13, 2024 for farmers, ranchers, and forest owners who experienced discrimination when seeking USDA farm loans before January 2021.

REGULATIONS AND FEDERAL AGENCIES

HUD extends NSPIRE compliance date for additional programs

HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE) final rule will take effect on October 1, 2024 rather than October 1, 2023 for the Housing Choice Voucher and Project Based Voucher programs. HUD recently made the same change for the HOME, Housing Trust Fund, Housing Opportunities for Persons With AIDS, Emergency Solution Grants, and Continuum of Care programs. For more information, contact Dana M. Kitchen, HUD, 202-708-1112.

DDAs and QCTs designated

HUD has released its 2024 lists of Difficult Development Areas and Qualified Census Tracts for the Low-Income Housing Tax Credit program. For more information, contact Michael K. Hollar, HUD, 202–402–5878.

USDA requests input on research access

USDA will hold virtual listening sessions on September 27 and October 12 on public access to the results of research funded wholly or in part by any USDA component agency. Written comments are due November 15. For more information, contact Cynthia Parr, USDA, 301-837-8917.

FHFA considers private transfer fee covenants for shared equity loans

FHFA proposes to allow Fannie Mae, Freddie Mac, and the Federal Home Loan Banks to buy and sell mortgages with certain types of private transfer fee covenants (PTFCs), which require the buyer or seller to pay a private fee when a property is sold. Currently the only PTFCs permitted are for homeowners’ associations. The revised regulation would also allow PTFCs related to resale restrictions in shared equity loan programs such as community land trusts. Comments are due November 27. For more information, contact Ted Wartell, FHFA, 202–649–3157.

EVENTS

Register for the National Rural Housing Conference

Register now to join stakeholders in the field of rural affordable housing, community development, and placemaking at the 2023 National Rural Housing Conference October 24-27 in Washington, DC. The 2023 conference theme is Build Rural – both a literal and figurative appeal to explore and provoke action to build and renew rural communities by addressing housing affordability and preservation, community infrastructure and essential facilities creation and revitalization, resident led placemaking, capacity building, and community inclusion and justice efforts.

Creative placemaking webinar scheduled

The National Endowment for the Arts is offering a free webinar on November 1 to address funding and support for creative placemaking work – how to find it, who to ask, partnerships, and most effective approaches for building local funding and decision-making support.

PUBLICATIONS AND MEDIA

Complete Worst Case Housing Needs report published

The executive summary of HUD’s 2023 Worst Case Housing Needs report, released in August, showed that worst case needs were at a record high level in 2021. The just-published full report provides additional details, including data for rural suburbs within metropolitan areas and for places outside metro areas. It also includes a new element, an examination of the intersection between worst case needs and housing overcrowding.

Disasters impacting insurance for homeowners and rental properties

Researchers and others have begun to examine climate change’s effect on the cost and availability of property insurance around the country. Recent items include The 9th National Risk Assessment: The Insurance Issue by the First Street Foundation, which estimates that millions of properties nationwide may face rising insurance rates and non-renewals due to the growing risks of wildfires, wind, and flooding. In many places the insurance industry is limiting or withdrawing coverage, leaving homeowners to rely on state-backed “insurers of last resort,” which are also raising their rates. As this homeownership cost rises, the report states, property values will fall. For rental properties, The State of Multifamily Risk Survey and Report from the National Multifamily Housing Council shows an average 26% increase in insurance premiums nationwide, with “triple-digit increases” for some. Majorities of NMHC’s survey respondents increased their deductibles to maintain insurance affordability or accepted new policy limitations reducing insurers’ exposure.

Ethnically and racially uneven investments in rural water infrastructure found

In The Ethnically and Racially Uneven Role of Water Infrastructure Spending in Rural Economic Development, researchers report their findings that, while water infrastructure investments were associated with economic development outcomes in rural communities, these investments did not counteract compounded effects of systemic racism, particularly for rural Indigenous and Hispanic communities.

Homeless data improvements recommended

Calculating Change: Future Directions for Homelessness Data Use and Reporting, a National Alliance to End Homelessness report, advocates for increased data efforts in service programming in order to identify and respond to challenges in the field. Along with recommendations to expand data collecting techniques, NAEH offers suggestions to local stakeholders and Continuums of Care struggling to navigate their Homeless Management Information Systems. At an October 11 webinar titled Calculating Change: The Continuing Conversation on Homelessness Data Reform, panelists will discuss the report and ways the field can improve its approaches to data.

Report covers adults’ recovery from substance use and mental health problems

The federal Substance Abuse and Mental Health Services Administration released Recovery from Substance Use and Mental Health Problems Among Adults in the United States, a report that provides policy recommendations and data on the 20.9 million adults in recovery from substance use disorders and 38.8 million adults in recovery from mental health problems. Policy recommendations include access to affordable, safe, and stable housing options and community support.

HAC

HAC is hiring

  • The Rental Housing Development and Preservation – Housing Specialist will provide technical assistance support to nonprofit organizations involved in multifamily housing programs, with a specific focus on USDA 515 and HUD rural housing programs. This position is remote work eligible.
  • The Rental Housing Development and Preservation Housing Specialist – Senior Level Position is a senior-level role that combines expertise in multifamily housing programs, specifically focusing on USDA 515 and HUD rural housing programs, with the responsibility of providing technical assistance, with a particular focus on transfers of USDA 515 properties. This position is remote work eligible.
  • The Senior Accountant is responsible for applying technical and leadership skills to guide accounting practices and recording of transactions. This position is hybrid, based in Washington, DC.
  • The Financial Controller is responsible for day-to-day management of HAC’s finance and accounting processes. This position is eligible for a hybrid schedule.
  • The Senior Human Resources and Payroll Administrator oversees all aspects of human resources and payroll practices and processes. This position is eligible for a hybrid schedule.
  • The Executive Assistant supports the work of HAC’s Chief Executive Officer, senior leadership, and board of directors. The position is a blend of administrative work and project assignments. This position is based in Washington, DC.

Need capital for your affordable housing project?

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).

Want to reprint a HAC News item?

Please credit the HAC News and provide a link to HAC’s website. Thank you!

Resilience and Recovery: Insights from the July 2022 Eastern Kentucky Flood

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A new report from the Cleveland Federal Reserve Bank focuses on the 13 counties declared federal disaster areas and examines the flood’s impact on the region’s housing.

Key findings

  • Cost of flood insurance can be prohibitive. The average cost of homeowners insurance and a flood insurance policy could account for around 7 percent of the median household income in the counties impacted by the 2022 eastern Kentucky flood. These policies can be expensive, particularly for low-income households, leading them to go without. Evidence of these difficult decisions can be found in the fact that only 5 percent of damaged homes had flood insurance, and households earning $30,000 or less per year accounted for 60 percent of damaged homes.
  • Floods exacerbate affordable housing shortages. Nearly 9,000 housing units were affected by the flood, with 74 percent of the damage occurring in just four counties (Breathitt, Knott, Letcher, and Perry), comprising 22 percent of their occupied housing units. Research finds that low-income households and renters are more likely to suffer permanent displacement because they often have fewer relocation options and lower-quality housing is more likely to be demolished instead of being rebuilt. These points are particularly relevant in these 13 flood-impacted counties where, in 2021, 37 percent of households, including 55 percent of renters, made less than $25,000 per year.
  • Floods increase population out-migration, which, in turn, impacts the local labor force. In the four hardest hit counties (Breathitt, Knott, Letcher, and Perry), an analysis of United States Postal Service (USPS) Vacancy Data shows that residential vacancies increased by 19 percent from the third to the fourth quarter in 2022. This is in addition to an average population decline of 600 people per year going back to 1984. Fewer residents mean fewer people available to fill jobs.
  • The pre-existing weakness of local labor markets will likely impact housing recovery, particularly due to a lack of available workforce in skilled trades. Prior to the July 2022 flood, the region experienced unemployment rates consistently higher than the national rate. In the region, the construction sector, key to the housing recovery, has declined by 24 percent (1,759 jobs) from its 2001 peak to 2022. Only coal mining and financial activities employment saw greater declines. This shortage of skilled trades workers, such as carpenters, electricians, and plumbers, has led to a backlog of people waiting to get their homes repaired or replaced.

For more information and to read the report, visit Resilience and Recovery: Insights from the July 2022 Eastern Kentucky Flood.

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