Policy News town

HAC’s Comments on Greenhouse Gas Reduction Fund

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HAC has submitted its second comment letter to the Environmental Protection Agency (EPA) about the the new $27 billion Greenhouse Gas Reduction Fund (GGRF) created by the Inflation Reduction Act. In late April, EPA released an implementation framework explaining that it plans to divide the program into three competitions. The $14 billion National Clean Investment Fund will fund two or three national nonprofits to partner with private capital providers to deliver financing at scale to businesses, communities, community lenders, and others. The $6 billion Clean Communities Investment Accelerator competition will fund two to seven hub nonprofits to build the capacity of lenders such as CDFIs and housing finance agencies to finance clean technology projects. The $7 billion Solar for All competition will make grants to states, Tribal governments, municipalities, and nonprofits to prepare low-income and disadvantaged communities for residential and community solar. EPA expects to issue Notices of Funding Opportunity as early as June.

HAC first commented in December after EPA asked for general feedback. In its second letter, HAC repeats some of the suggestions made in December and makes some additional points about the implementation framework, asking EPA to:

  • Address the unique needs of rural and persistent poverty communities.
  • Ensure that nonprofit CDFIs and their nonprofit housing development partners are explicitly eligible for GGRF resources.
  • Increase clarity and reduce administrative burden on recipients.
  • Exempt housing from Build America, Buy America requirements.

Read HAC’s full comments here.

HAC GGRF Comment Letter
HAC President & CEO, David Lipsetz, testifies in front of the Senate Committee on Banking, Housing, and Urban Affairs Subcommittee on Housing, Transportation, and Community Development

HAC’s CEO Testifies to Senate Banking Subcommittee on Rural Housing Reforms

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HAC was honored to be invited to testify on May 2, 2023 before the Housing, Transportation, and Community Development Subcommittee of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to discuss commonsense, bipartisan reforms to the U.S. Department of Agriculture’s Rural Housing Service (RHS) programs. HAC’s President & CEO, David Lipsetz, was one of five witnesses on the hearing panel.

The hearing was held to discuss the bipartisan Rural Housing Service Reform Act of 2023, which has been introduced by Subcommittee Chairwoman Tina Smith (D-MN) and Senator Mike Rounds (R-SD). The RHS Reform Act includes a slate of provisions to improve the multifamily, single-family, and capacity building programs at RHS. Senators Smith and Rounds engaged deeply with stakeholders on the creation of the bill, including offering a call for policy recommendations in the summer of 2022. HAC’s response to that comment opportunity can be seen here. We were thrilled to see many of our recommendations included in the bill, and applaud Senators Smith and Rounds on their thoughtful engagement with stakeholders and their commitment to improving the RHS programs.

Highlights from the RHS Reform Act include:

  • Multifamily

    • Authorizing the Multifamily Preservation and Revitalization (MPR) program and Multifamily Preservation Technical Assistance Program
    • Allowing for the decoupling of a Section 515 mortgage and Section 521 Rental Assistance
    • Allowing Section 542 rural vouchers to be adjusted based on changes in tenant income
    • Streamlining the process for Section 515 nonprofit transfers and increasing the Section 515 nonprofit set aside

  • Single Family

    • Establishing the Native CDFI Section 502 relending program
    • Increasing the threshold for the mortgage requirement on a Section 504 home rehab loan from $7,500 to $15,000
    • Extending the loan term for a Section 502 loan up to 40 years

  • Capacity Building

    • Authorizing the Rural Community Development Initiative (RCDI) and waiving the matching funds requirement for groups working in areas of persistent poverty
    • Requiring RHS to publish more data on their housing programs
    • Authorizing funding for much needed technology upgrades at RHS
Watch the Recording Read David’s Testimony HAC’s 2023 Policy Priorities

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HAC’s Comments on Affirmatively Furthering Fair Housing

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In February 2023, the U.S. Department of Housing and Urban Development (HUD) requested public comments on a proposed regulation that is intended to ensure that HUD and entities receiving funding from HUD will “Affirmatively Further Fair Housing” (AFFH). This rule would implement the Fair Housing Act’s requirement for HUD and its awardees to proactively take meaningful actions to overcome patterns of segregation, promote fair housing choice, eliminate disparities in housing-related opportunities, and foster inclusive communities that are free from discrimination. The 2023 proposed rule is based on a 2015 rule that was never fully implemented.

HAC supports many aspects of HUD’s proposal. HAC also supports suggestions for improvements made in comment letters prepared by the National Community Reinvestment Coalition and National Housing Law Project, and HAC — along with many other organizations — signed those letters. In addition, to emphasize some points that are particularly relevant to AFFH efforts in rural America, HAC submitted its own comment letter.

In its letter, HAC makes three primary points regarding state and local governments’ development of AFFH Equity Plans:

  • Community engagement must be offered in many different ways.
  • Analyses must be conducted in smaller geographic areas.
  • Data on USDA-supported housing must be specifically included.

Read HAC’s full comments here.

HUD AFFH 2023 Comment Letter
HAC in the News

Advocates eye farm bill to avert drop in affordable rural housing – CQ Roll Call

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By Caitlin Reilly

Posted April 11, 2023 at 5:00am

Housing advocates are turning to this year’s farm bill in an effort to steer rural communities away from an affordable housing cliff ahead.

Without action from Congress, rural communities stand to lose more than 100,000 affordable rental units in the next decade as federally subsidized loans used to build the apartments are paid off, ending landlords’ obligations to keep rents low. In a second blow for those renters, they will lose their eligibility for the Agriculture Department’s rental assistance.

“It’s a big problem, and it’s going to only get worse,” said Sarah Saadian, senior vice president of public policy at the National Low Income Housing Coalition.

“The heyday or the peak of rural housing was in the ’70s and ’80s, when their rental housing program was nearly a billion-dollar program, and it’s been cut really dramatically over the last several decades,” Saadian said in an interview. “All of those properties that were built at that time are now reaching the end of the maturity on their 515 mortgage, or the 515 loans that USDA provides in order to get those properties built.”

Advocates are pushing Congress to include provisions in the farm bill that would decouple the two programs, allowing the Agriculture Department to provide rental assistance even after a building’s owner has paid off the subsidized mortgage.

Read the full article

“The biggest issue in rural housing is the rapid loss of the 515 units due to mortgage maturity, prepayments, foreclosures. That is the 800-pound gorilla, or really the $31 billion gorilla over the next 30 years to preserve.”

Policy News field

HAC Comments on HUD’s CDBG-DR Disaster Recovery Program

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Responding to two requests for information from HUD, on February 21 HAC submitted comments on some of the specifically rural concerns involved in using the Community Development Block Grant Disaster Recovery (CDBG-DR) program.

The program does not receive regular annual funding in HUD’s appropriations bills. Instead, Congress provides funds to help with recovery from specific disasters after they occur. As a result, HUD has not been able to write regulations for the program. The department is now developing a “Universal Notice” that would standardize the CDBG-DR allocation and implementation process. HUD asked for input on the program’s rules and waivers and on its allocation formula. HAC combined its responses and submitted one letter.

Key Takeaways

  • To make CDBG-DR most effective in rural and Tribal areas, HUD must build local capacity itself, or require state grantees to do so.
  • To achieve geographic equity in the distribution of CDBG-DR resources, HUD must account for the difficulties of appraising rural properties, as well as for a variety of nontraditional housing and nontraditional forms of ownership that are common in rural places.
  • HUD, FEMA, the U.S. Department of Agriculture, and other agencies involved in the disaster recovery process should develop a single set of standardized forms and templates for applicants to use.

To learn more about HAC’s full recommendations, read our full comment letter. Other comments are posted here and here.

HAC Comments on CDBG-DR
Policy News field

Housing Assistance Council Statement on $54 Million Funding Package for Homelessness in Rural America

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Last week, the U.S. Department of Housing and Urban Development (HUD) announced a historic $315 million package of grants to help communities across the country provide both housing and supportive services to those experiencing homelessness. The Housing Assistance Council (HAC) celebrates the inclusion in this package of more than $54 million targeted to rural communities.

“The announcement of $54.4 million in grants to combat rural homelessness is a critical step toward achieving the goal of reducing homelessness by 25% by 2025, set forth in the Administration’s recently released Federal Strategic Plan to Prevent and End Homelessness,” said David Lipsetz, CEO of the Housing Assistance Council. “While the most recent count showed less than a half-percent increase in homelessness overall from 2020 to 2022, predominantly rural Continuums of Care experienced a 6% increase. These targeted grants across over half the country—27 states, which are collectively home to over two-thirds of rural Americans—can help reverse this troubling trend.”

Continuums of Care, the entities that coordinate federal homelessness response efforts, to build their capacity to address the unique homelessness and housing challenges in rural America. In particular, rural communities can apply for capacity-building support—not usually an eligible use of HUD homeless funding, but an important factor in many small towns and rural places. Importantly, this initiative also targets rural communities that have historically not had access to HUD homeless assistance grants.

“The announcement provides a model for bipartisan, evidence-based policymaking in the current political environment,” added Lipsetz. “First, Democrats and Republicans on Congressional Appropriations Committees joined together to authorize HUD to deploy unspent funds for this purpose. Second, while rural communities typically struggle to access competitive federal funding despite demonstrable need because of capacity constraints, HUD not only set aside funding for rural America but specifically sought applications to serve communities that had not previously received Homeless Assistance Grants.”

Policy News field

HAC Comments on Community Investment Focus on Capacity Building and Capital Access

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Several federal government agencies recently formed an Interagency Community Investment Committee (ICIC), focused on the operations and execution of federal programs that facilitate the flow of capital and the provision of financial resources into historically underserved communities, including communities of color, rural communities, and Tribal nations. The ICIC requested public input on ways the agencies can promote economic conditions and systems that reduce racial disparities and produce stronger economic outcomes for all communities. According to the request for comment, responses may be used to inform ICIC’s future actions to improve the operations and delivery of federal community investment programs through stronger federal collaboration. The committee is composed of representatives from the Department of the Treasury, Small Business Administration, Department of Commerce, Department of Transportation, Department of Housing and Urban Development, and Department of Agriculture.

Key Takeaways

  1. Support capacity building for local organizations embedded in their communities.
  2. Provide equitable access to capital for rural America.
  3. Address rural needs, particularly in persistent poverty areas, directly.
  4. Accelerate interagency coordination and sharing of best practices.
  5. Improve data and information accuracy and availability.

Read HAC’s comments, submitted on December 19, 2022. Other comments are posted here.

HAC Comments on Community Investment Focus on Capacity Building and Capital Access
Policy News field

HAC Submits Comments on Colonia Census Tract Definition

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HAC submitted comments in response to the October 5, 2022 Notice of Proposed Rulemaking (NPRM) on the Enterprise Duty to Serve Underserved Markets Amendments published by the Federal Housing Finance Agency (FHFA). HAC has conducted significant research on housing finance, including numerous aspects of Fannie Mae’s and Freddie Mac’s statutory Duty to Serve Underserved Markets. The regulatory change under consideration, in fact, is based on HAC research for Fannie Mae. Thus HAC is well positioned to comment on this proposal.

HAC generally supports FHFA’s proposed definition and use of “colonia census tracts” to target efforts by Fannie Mae and Freddie Mac (the Enterprises) to meet the credit needs of these high-poverty rural areas. As the NPRM explains, the colonia census tract model is based on Colonias Investment Areas, a concept developed by HAC for use by Fannie Mae in meeting its Duty to Serve the colonias. HAC’s research makes clear that using census tracts containing colonias as a basis for identifying and evaluating colonias activities would not only provide clarity, but would also meet the goals of the Duty to Serve statute and regulations.

Key Takeaways

  1. Census tracts are the best available geography for a revised colonia definition, as HAC’s research has demonstrated, and HAC supports FHFA’s proposal to base its definition on tracts.
  2. Focusing activities in the places FHFA identifies as colonias census tracts would meet the goals of the Duty to Serve requirement.
  3. Alternative definitions have proven to be too broad or too difficult to use.
  4. HAC recommends providing greater weight to Duty to Serve activities in colonia census tracts in rural areas than to those in urban or suburban places, because rural tracts have greater needs.
  5. The colonias census tract database should be updated more often than every ten years if interim changes warrant.

To learn more about HAC’s full recommendations, read our full comment letter.

HAC Final Comments on the Colonias Definition
Policy News town

HAC Submits Comments on Proposed Duty to Serve Modifications

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The Federal Housing Finance Agency (FHFA) requested comments on Fannie Mae and Freddie Mac’s (the Enterprises) proposed modifications to their Duty to Serve 2022 Underserved Markets Plans. If implemented robustly, Duty to Serve has the potential to improve the lives of people living in the most underserved communities. HAC’s comments highlighted two proposed modifications:

Key Takeaways

  1. USDA Section 515 preservation is critical to the Duty to Serve mission. Freddie Mac’s proposal to remove the Section 515 purchases from their Plan should be rejected.
  2. Equity investments in CDFIs are the single most impactful action that the FHFA could currently take to improve Duty to Serve outcomes. Fannie Mae’s proposal to add equity investments in Native CDFIs to their plan is a step in the direction of better serving Indian Country. For more suggestions on how the Enterprises could better serve Indian Country, see HAC’s comments from the July 2022 Native American Housing Listening Session.

Read HAC’s full comments.

HAC Duty to Serve Plan Modification Comments

HAC also signed on to a letter from the Underserved Mortgage Markets Coalition with a longer set of comments on the proposed modifications.

All the comments received by the FHFA can be viewed here.

 

Policy News field

HAC Submits Comments on the Greenhouse Gas Reduction Fund

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HAC submitted comments in response to the October 21, 2022 Notice of Proposed Rulemaking on the Greenhouse Gas Reduction Fund (GHGRF) published by the Environmental Protection Agency (EPA). GHGRF is a new program created by the Inflation Reduction Act and will be administered by EPA. This first-of-its-kind program will provide $27 billion in competitive grants to mobilize financing and leverage private capital for clean energy and climate projects that reduce greenhouse gas emissions, with an emphasis on projects that benefit low-income and disadvantaged communities. A wide range of activities, including those related to housing, could qualify for GHGRF.

GHGRF funds are divided into three pools. There are $7 billion for competitive grants to enable low-income and disadvantaged communities to deploy or benefit from zero-emission technologies, including distributed technologies on residential rooftops. Nearly $12 billion will be used for competitive grants to eligible entities to provide financial and technical assistance to projects that reduce or avoid greenhouse gas emissions. Another $8 billion is for competitive grants to eligible entities to provide financial and technical assistance to projects that reduce or avoid greenhouse gas emissions in low-income and disadvantaged communities.

HAC’s comments focused on four main points.

Key Takeaways

  1. Leverage the extensive existing network of CDFIs to ensure rapid, equitable, and widespread investment.
  2. Address the unique needs of rural and persistent poverty communities.
  3. Recognize the key role of housing assistance in meeting GHGRF’s goals.
  4. Include equity principles in all elements of the GHGRF program design.

To learn more about HAC’s full recommendations, read our full comment letter.

GGRFCommentHACFinal

 

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