HAC’s Stakeholder Comments on Rural Housing Service Programs

July 12, 2022/in News, Policy Homeowner Housing, Housing Affordability, Rental Housing, U.S. Department of Agriculture

HAC submitted comments to Senators Tina Smith (D-MN) and Mike Rounds (R-SD), the Chair and Ranking Member of the Housing, Transportation, and Community Development Subcommittee of the Senate Banking Committee, in response to their call for recommendations on how to improve the U.S. Department of Agriculture’s (USDA) Rural Housing Service (RHS) programs. RHS programs are a critical source of housing for our nation’s small towns and rural places. HAC hopes that Senators Smith and Rounds will use these stakeholder comments to help improve the efficiency and impact of RHS programs, especially as more multifamily properties leave the USDA portfolio.

Topline Takeaways

Multifamily
HAC strongly recommends that the Senators authorize important multifamily preservation programs and simplify the process for transferring properties to non-profit owners in order to help more properties remain in RHS programs and maintain their affordability. HAC also recommends that the Senators investigate the rental assistance programs available in rural areas and extend these to more rural renters.
Single family
HAC recommends that the Senators improve the Section 504 program which provides grants for single family home repair. Simplifying and making this program’s funds more accessible would help more families stay in their homes and preserve single family homeownership.
Capacity building
Many communities have the willingness and desire to help improve their housing opportunities but lack the technical skill or capacity to accomplish their goals. HAC recommends authorizing capacity building programs that would help communities develop the tools they need to thrive.
RHS staffing and operations
HAC recommends improving the workflow within RHS and updating the technology the RHS staff uses to increase efficiency and help RHS better serve rural communities.

Read HAC’s Comments

HAC Comments on RHS Reforms

Housing Assistance Council Statement on Proposed $54.5 Million Set Aside for Homelessness in Rural Communities

June 30, 2022/in News, Policy Homeless, U.S. Department of Housing and Urban Development, Vulnerable Populations

The Housing Assistance Council (HAC) applauds the new funding package announced by the U.S. Department of Housing and Urban Development (HUD) on June 22, 2022 to provide people experiencing homelessness in the nation’s cities and rural communities with the support they need. In total, HUD’s initiative includes $322 million targeted to addressing unsheltered and rural homelessness. Of this, $54.5 million is set aside for rural communities to help connect individuals and families experiencing homelessness to housing, healthcare and supportive services.

“This is a remarkable investment in terms of its size, targeting and design,” said HAC CEO David Lipsetz. “HUD recognizes that homelessness looks different in rural places than in large cities, and is customizing this initiative to address the unique capacity challenges that rural Continuums of Care face.” In particular, rural communities can apply for capacity-building support—which is not an eligible activity under the annual Continuum of Care competition or the unsheltered homelessness set aside. Funds can also support home repairs, outreach, supportive services and more. By specifically targeting rural communities that have historically not had access to HUD homeless assistance grants, this special funding announcement goes a long way toward ensuring an equitable approach for underserved communities.

HUD’s announcement reflects HAC’s longstanding efforts to educate policymakers on the unique needs of rural communities seeking to address homelessness. “HAC played an essential role informing the drafting and early implementation of the HEARTH Act of 2009, which overhauled HUD’s homeless assistance programs for the first time in two decades,” said Jonathan Harwitz, HAC’s Director of Public Policy, who worked on the HEARTH Act as a Congressional staffer and at HUD. “It is gratifying that HUD’s special funding announcement today reflects HAC’s feedback on HEARTH Act implementation over the past decade.”

Manufactured Housing in the United States Map, 2018

Housing Assistance Council Statement on Proposed $500 Million Investment in Manufactured Housing

June 27, 2022/in Policy Rural Policy

The Housing Assistance Council (HAC) applauds Chairman David Price (D-4^th-NC) and Ranking Member Mario Diaz-Balart (R-25^th-FL) of the Transportation, Housing and Urban Development (THUD) Appropriations Subcommittee for their bipartisan and transformational investment in the Manufactured Housing Improvement and Financing Program. The fiscal year (FY) 2023 budget bill passed this week by both the Subcommittee and the full Appropriations Committee includes $500 million to preserve and revitalize manufactured homes and manufactured housing communities, a long-underappreciated source of affordable housing for millions of Americans.

“The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.” – David Lipsetz, HAC CEO

This new program provides grants for a broad range of activities, from building affordable housing to building the capacity of local affordable housing organizations. The program will improve infrastructure, planning, resident and community services (including relocation assistance and eviction prevention), resiliency activities, and land and site acquisition. The Department of Housing and Urban Development (HUD) would distribute the funds competitively to non-profits, CDFIs, resident-owned manufactured housing communities, states, local governments, Tribes, and other eligible entities.

“Manufactured housing represents the nation’s largest supply of affordable housing. Until this program, the poor, largely-rural families living in these homes have been denied access to the public programs that preserve and maintain housing for those that need it most. Nor have the non-profit and public sector entities who work with manufactured housing received federal funding commensurate with the preservation and revitalization challenge they face for this vital affordable housing stock,” said HAC President & CEO David Lipsetz. “The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.”

HAC is the only national non-profit intermediary dedicated to affordable housing in rural America. With a mission-focus on the most rural and poorest places, HAC has long prioritized manufactured housing given its disproportionate share of the rural housing stock. Nationwide, approximately 6.7 million households live in manufactured or mobile homes, which is six (6) percent of the nation’s housing stock. Yet over 50 percent of all manufactured homes are located in rural areas. which comprises 14 percent of all occupied homes in rural communities – more than twice the national rate.

The proposed program from Chairman Price and Ranking Member Diaz-Balart builds on the Subcommittee’s May 26^th hearing “Manufactured Housing: Supporting America’s Largest Unsubsidized Affordable Housing Stock,” in which HAC’s Director of Research and Information Lance George testified on the challenges facing those seeking to maintain the quality of this essential affordable housing. His testimony established that many manufactured housing residents lease the land on which their homes sit, leaving them vulnerable to evictions and predatory lot rents. And about two-thirds of manufactured home loans are classified as high cost—five times the national average for all homes. His testimony concluded “manufactured housing is already a significant source of affordable housing in rural places, and it should continue to be a high-quality, affordable housing option.” HAC strongly believes the Manufactured Housing Improvement and Financing Program would be a major step toward achieving just that.

HAC’s Research Director to Speak at Congressional Manufactured Housing Hearing

May 26, 2022/in Policy Housing Affordability, Housing Problems

The House Transportation-HUD Appropriations Subcommittee is holding a hearing May 26 on Manufactured Housing: Supporting America’s Largest Unsubsidized Affordable Housing Stock, with HAC’s Director of Research and Information, Lance George, among the witnesses. His testimony explains the importance of manufactured homes as affordable housing in rural America and the challenges facing manufactured housing residents, owners, and communities. It suggests that new research is needed to inform evidence-based solutions and that Congress could help address pressing challenges by providing grants for land acquisition by resident owned cooperatives, other mission-focused nonprofits, and public sector housing agencies, as well as financing for individual homeowners.

Lance George Statement to House THUD Committee - May 26, 2022

Over 300 Organizations Express Support for SHOP and RCB Programs

March 22, 2022/in Advocacy, Policy U.S. Department of Housing and Urban Development

With the help of our network of organizations working across the country in rural areas, more than 300 organizations signed on to support increased funding for SHOP and the Rural Capacity Building (RCB) programs at HUD. HAC has helped almost 10,000 rural families achieve homeownership using the SHOP program, and has provided thousands of hours of customized technical assistance to more than 750 local organizations using the RCB program. Check out the letter below to learn more. Thanks to Habitat for Humanity, Community Frameworks, and Tierra del Sol for their partnership on this effort!

FY23 SHOP and RCB Organizational Sign-on Letter

Some Rural Housing Programs Increase in Omnibus Funding Bill

March 9, 2022/in News, Policy Federal Funding, U.S. Department of Agriculture

Information on FY22 HUD funding

UPDATE March 11, 2022 – Both the House and Senate have passed the omnibus bill and President Biden will sign it into law, avoiding a government shutdown and funding federal programs through fiscal year 2022, which ends on September 30, 2022.

March 9, 2022 – Several USDA rural housing programs will receive modest funding increases in the omnibus appropriations bill for fiscal year 2022. The bill’s text, released overnight, does not include the significant boosts for rental housing that were included in House and/or Senate versions, instead compromising on smaller raises.

The bill expands eligibility for Section 542 vouchers, which have previously been available only to tenants living in Section 515 properties where the mortgage has been prepaid since September 30, 2005. This language is revised to apply to tenants in properties where Section 515 loans are “prepaid or otherwise paid off after September 30, 2005″ (emphasis added), potentially extending eligibility to tenants of every property that has left the portfolio since that date. USDA could set some limits on this expansion, as it has for tenants in properties with prepaid mortgages, who can obtain vouchers only if they live in the property on the date the prepayment occurs.

Other provisions in the final bill are retained from past appropriations measures. These include language allowing rental property owners to request 20-year Rental Assistance contracts, subject to appropriations. The bill also retains provisions calling for incentives to nonprofits to preserve rental housing, reuse of recaptured Section 521 Rental Assistance (RA), and use of recaptured RA from farmworker housing in other farmworker housing when possible.

The bill continues the 10-20-30 requirement that at least 10 percent of most USDA Rural Development programs, including most housing programs, be set aside for persistent poverty counties (counties where the poverty rate has been at least 20 percent for 30 years).

The omnibus establishes one new program related to rural housing and community development: an Institute for Rural Partnerships, which “shall dedicate resources to researching the causes and conditions of challenges facing rural areas, and develop community partnerships to address such challenges.” The institute will be housed at the University of Vermont and three land-grant universities to be selected by USDA. Each institution will receive a $10 million grant.

The continuing resolution that currently funds the federal government ends at midnight on March 11. The House is expected to pass the omnibus bill on March 9. Another continuing resolution, lasting just a few days, may be needed to give the Senate enough time to act.

USDA Rural Dev. Prog. (dollars in millions)	FY20 Final Approp.	FY21 Final Approp.	Amer. Rescue Plan Act	FY22 Admin. Budget	FY22 House Bill	FY22 Senate Bill	FY22 Final
502 Single Fam. Direct	$1,000	$1,000	$656.6^a	$1,500	$1,500	$1,250	$1,250
502 Single Family Guar.	24,000	24,000	–	30,000	30,000	30,000	30,000
504 VLI Repair Loans	28	28	18.3^a	28	28	28	28
504 VLI Repair Grants	30	30	–	30	40	30	32
515 Rental Hsg. Direct Lns.	40	40	–	40	40	92	50
514 Farm Labor Hsg. Lns.	28	28	–	28	28	28	28
516 Farm Labor Hsg. Grts.	10	10	–	10	15	10	10
521 Rental Assistance	1,375	1,410	100	1,450	1,450	1,450	1,450
523 Self-Help TA	31	31	–	32	32	32	32
533 Hsg. Prsrv. Grants	15	15	–	15	25	15	16
538 Rental Hsg. Guar.	230	230	–	230	230	250	250
Rental Prsrv. Demo. (MPR)	28	28	–	32	60	32	34
542 Rural Hsg. Vouchers	32	40	–	45	45	45	45
Rental Prsrv. TA	1	2	–	0	2	2	2
Rural Cmnty. Dev’t Init.	4	6	–	6	6	6	6

a. The American Rescue Plan Act of 2021 provides $39 million in budget authority to refinance Section 502 direct loans and Section 504 loans for homeowners impacted by the coronavirus pandemic. USDA expects this funding to generate $656.6 million in Section 502 direct loans and $18.3 million in Section 504 loans.

August 5, 2021 – The Senate Appropriations Committee passed its FY22 USDA funding bill on August 4. While the House bill proposes a substantial increase in funding for the Multifamily Preservation and Revitalization program, the Senate bill would increase Section 515 funding rather than MPR. The Senate bill suggests increases in some other programs, but most of its figures are lower than the House’s.

The Senate bill would retain a provision in FY21 appropriations law, dropped by the administration’s budget and the House, that allows rental property owners to request 20-year terms for Rental Assistance contracts, subject to annual appropriations. The Senate and House would both keep provisions calling for incentives to nonprofits to preserve rental housing, reuse of recaptured Rental Assistance (RA), and use of recaptured RA from farmworker housing in other farmworker housing when possible, although those were left out of the administration’s budget request.

July 27, 2021 – The House passed H.R. 4502, a “minibus” package of seven appropriations bills, including USDA’s (see table below) and HUD’s.

July 1, 2021 – The full House Appropriations Committee approved its FY22 USDA funding bill on June 30, including increases in some rural housing programs as described below. The bill will be considered later this summer by the full House. The Senate has not yet released a proposal.

The House committee also released its report on the bill, providing additional information and directives from the committee, including a paragraph about farmworker housing.

Farm Labor Housing.—The Committee encourages USDA to explore opportunities to leverage its resources including its Food and Nutrition Programs, Community Facilities Programs, Housing Preservation Grants, and other programs, and to create partnerships with the Department of Labor’s Farmworker Housing outreach and technical assistance program, Health Resources and Services Administration’s Health Center Program, and the Administration for Children and Families Migrant and Seasonal Head Start Program, to coordinate and align resources to address the housing, nutrition and healthcare needs of this vulnerable population of essential workers who play a critical role in America’s food security. The Committee further encourages USDA to explore including service coordinators as an allowable expenditure for farm labor housing projects.

June 24, 2021 – As congressional action begins for fiscal year 2022 federal funding, the House Appropriations Committee has released a bill proposing increases in several of USDA’s rural housing programs.

Like the administration’s budget, the House bill would raise funding for Section 502 direct and guaranteed mortgage loans, Rental Assistance, and self-help housing. While the budget would increase the Multifamily Preservation and Revitalization (MPR) program to $32 million from $28 million in FY21, the House bill would provide a far larger boost, to $65 million. The House would also grow the Section 504 grant program for elderly low-income homeowners and the Section 533 Housing Preservation Grants program.

The House bill retains several provisions that are in current appropriations law but were dropped in the administration’s budget. These call for incentives to nonprofits to preserve rental housing, reuse of recaptured Rental Assistance (RA), and use of recaptured RA from farmworker housing in other farmworker housing when possible. Like the budget, however, it eliminates a provision from the FY20 and FY21 appropriations laws that allowed property owners to request RA contracts with 20-year terms.

The House Agriculture Appropriations Subcommittee will review the draft bill at a mark-up on June 25, 2021. The full House Appropriations Committee will consider it on June 30. The Senate has not yet begun its appropriations process.

USDA Rural Dev. Prog. (dollars in millions)	FY20 Final Approp.	FY21 Final Approp.	Amer. Rescue Plan Act	FY22 Admin. Budget	FY22 House Bill
502 Single Fam. Direct	$1,000	$1,000	$656.6^a	$1,500	$1,500
502 Single Family Guar.	24,000	24,000	–	30,000	30,000
504 VLI Repair Loans	28	28	18.3^a	28	28
504 VLI Repair Grants	30	30	–	30	c
515 Rental Hsg. Direct Lns.	40	40	–	40	40
514 Farm Labor Hsg. Lns.	28	28	–	28	b
516 Farm Labor Hsg. Grts.	10	10	–	10	b
521 Rental Assistance	1,375	1,410	100	1,450	1,450
523 Self-Help TA	31	31	–	32	32
533 Hsg. Prsrv. Grants	15	15	–	15	c
538 Rental Hsg. Guar.	230	230	–	230	230
Rental Prsrv. Demo. (MPR)	28	28	–	32	60
542 Rural Hsg. Vouchers	32	40	–	45	45
Rental Prsrv. TA	1	2	–	0	2
Rural Cmnty. Dev’t Init.	4	6	–	6	6

a. The American Rescue Plan Act of 2021 provides $39 million in budget authority to refinance Section 502 direct loans and Section 504 loans for homeowners impacted by the coronavirus pandemic. USDA expects this funding to generate $656.6 million in Section 502 direct loans and $18.3 million in Section 504 loans.

b. The House bill provides a total of $17.8 million in budget authority for the Section 514 and 516 farm labor housing programs. When the Appropriations Committee prepares a report on the bill, that document will state the program amounts.

c. The House bill provides a total of $65 million for Section 504 grants and Section 533 grants. When the Appropriations Committee prepares a report on the bill, that document will show how the total is to be divided between the two programs.

HUD Programs Slated for Funding Increases

March 9, 2022/in News, Policy Federal Funding, U.S. Department of Housing and Urban Development

Information on FY22 USDA funding

UPDATE March 11, 2022 – Both the House and Senate have passed the omnibus bill and President Biden will sign it into law, avoiding a government shutdown and funding federal programs through fiscal year 2022, which ends on September 30, 2022.

March 9, 2022 – Many HUD programs will receive more funding in fiscal year 2022 than in 2021 under the provisions of the omnibus appropriations bill released overnight. Generally, however, the final figures fall below the highest increases proposed by the Biden administration, the House, or the Senate.

The SHOP program was increased from $10 million in FY21 to $12.5 million – the first increase in the program since FY15. The spending agreement also encourages HUD to consider increasing the per-unit cap for the combined cost of land acquisition and infrastructure improvements under the SHOP program, which is currently $15,000 per unit.

The bill includes funds for 25,000 new rental vouchers, a step towards the 300,000 new vouchers that would have been provided by the Build Back Better Act.

The substantial increase in CDBG funding was driven nearly entirely by the return, after a 10-year absence, of $1.5 billion for the Economic Development Initiative for the purpose of funding Community Projects/Congressionally Directed Spending (popularly known as “earmarks”).

The continuing resolution that currently funds the federal government ends at midnight on March 11. The House is expected to pass the omnibus bill on March 9. Another continuing resolution, lasting just a few days, may be needed to give the Senate enough time to act.

HUD Program (dollars in millions)	FY20 Final Approp.	FY21 Final Approp.	FY22 Admin. Budget	FY22 House Bill	FY22 Senate Bill	FY22 Final
CDBG	$3,425	$3,475	$3,770	$4,688	$4,190	$4,841
HOME	1,350	1,350	1,850	1,850	1,450	1,500
Self-Help Homeownshp. (SHOP)	10	10	10	15	15	12.5
Veterans Home Rehab	4	4	4	–	4	4
Tenant-Based Rental Asstnce.	23,874	25,778	30,442	29,216	27,719	27,370
VASH setaside	40	40	–	20	50	50
Tribal VASH	1	5	5	5	5	5
Project-Based Rental Asstnce.	12,570	13,465	14,060	14,010	13,970	13,940
Public Hsg. Capital Fund	2,870	2,942	3,678	3,718	3,794	3,388
Public Hsg. Operating Fund	4,549	4,864	4,917	4,922	5,044	5,064
Choice Neighbrhd. Initiative	175	200	250	400	200	350
Native Amer. Hsg.	825	825	1,000	950	1,000	1,002
Homeless Assistance Grants	2,777	3,000	3,500	3,420	3,260	3,213
Hsg. Opps. for Persons w/ AIDS	410	430	450	600	450	450
202 Hsg. for Elderly	793	855	928	1,033	956	1,033
811 Hsg. for Disabled	202	227	272	352	227	352
Fair Housing	70.3	72.6	85	85	85	85
Healthy Homes & Lead Haz. Cntl.	290	360	400	460	400	415
Housing Counseling	53	57.5	85.9	100	57.5	57.5

October 20, 2021 – The Senate Appropriations Committee has released nine proposed appropriations bills, including the Transportation-HUD bill, for the fiscal year that began on October 1. The committee would increase many programs above their FY21 funding levels, though generally it would not raise them to the figures proposed in the House bill. The Self-Help Homeownership Opportunity Program (SHOP) is an exception, set in both the House and Senate bills at $15 million rather than the $10 million it received in FY21. Native American housing would also receive more under the Senate bill than from the House. Details are provided in the table below.

Federal programs are currently funded through a continuing resolution that keeps them at FY21 levels. It will expire on December 3, 2021.

July 29, 2021 – The full House passed H.R. 4502, a “minibus” containing several FY22 appropriations bills, including the bills for both HUD and USDA.

July 16, 2021 – The House Appropriations Committee has approved the Transportation-HUD funding bill. It is expected to be considered by the full House as part of a “minibus” package of several FY22 appropriations bills, which will also include the Agriculture bill.

July, 2021 – On July 16, 2021 the House Appropriations Committee will consider a fiscal year 2022 funding bill for the Departments of Transportation and Housing and Urban Development. The bill was approved on July 12 by the T-HUD Appropriations Subcommittee.

The House bill would set funding levels for many HUD programs at or above the amounts requested in the President’s budget and would provide substantial increases above FY21 levels for almost all programs. Details are provided in the table below.

Self-Determination in Tribal Housing: Reflections on NAHASDA’s Impact

February 10, 2022/in High Needs, News, Policy, Rural News High Need Regions, Native American Lands

Twenty-five years ago, the Native American Housing Assistance and Self-Determination Act (NAHASDA) overhauled federal housing policy for tribal lands. One of its primary goals was to respect the sovereignty of tribes by giving them more power to determine how their federal housing funding is spent. Reauthorizing NAHASDA and making targeted improvements to build upon its first twenty-five years of achievements is one of HAC’s 2022 Rural Housing Policy Priorities.

We asked four experts on housing in Indian Country to reflect on NAHASDA and its impact.

Tony Walters

Tony Walters, Executive Director, National American Indian Housing Council

Washington, DC

Tony Walters explains that NAHASDA “definitely has been a success.” By expanding the capacity of tribal housing authorities to meet the needs of their communities, the act has improved the quality and quantity of tribal housing.

Under NAHASDA, tribal housing authorities receive dedicated, reliable funding. As Walters points out, this steady stream of funds has “put tribes into a position where they can build homes quickly.” It has also increased their capacity, making other federal housing programs (like the Low-Income Housing Tax Credit) more accessible. While tribes undoubtedly need increased resources to offset thirty years of flat funding, NAHASDA has put many tribal housing authorities closer to their goal of being “one stop shops” for all the housing needs of Tribe members. Simply put, there’d be fewer homes without NAHASDA, Walters explains.

Additionally, self-determination has given tribes more ability to tailor housing development to their specific needs. Unlike the former system of federally built homes, the current system allows tribes the flexibility to include important “cultural elements” like community centers and to decide the specific number and location of new homes.

“Housing is the foundation of any community,” Walters notes. While NAHASDA has helped strengthen the foundations of many communities, Walters cautions that increased funding, capacity, and cooperation between government programs are needed to prevent tribal housing projects from “falling through the cracks.” The solution, as Walters sees it, is to expand on the work of NAHASDA by strengthening capacity building and increasing resources.

Twila Martin-KeKahbah

Twila Martin-Kekahbah, Turtle Mountain Band of Chippewa Indians and HAC board member

Belcourt, ND

Twila Martin-Kekahbah opposed NAHASDA when it was proposed, and still believes that the law has failed to live up to its intentions. While the homes built under the law are successes, they’re nowhere near what is needed.

As she explains, the law recognizes the importance of tribal sovereignty, but it doesn’t provide the level of financial support or assistance necessary to help tribes build their capacity. In other words, NAHASDA’s model of self-determination doesn’t work if tribes don’t have the funding or capacity to act on it. Martin-Kekahbah noted that under NAHASDA, federal experts withdrew from areas where they’d been running housing programs, leaving tribal housing authorities unprepared for the responsibilities before them.

While the intentions of the act were noble, she is left asking a challenging question: “Why would housing be so bad right now if NAHASDA was so great?”

Rebecca Patnaude-Olander

Rebecca Patnaude-Olander, Executive Director, Turtle Mountain Housing Authority

Belcourt, ND

Rebecca Patnaude-Olander explained that NAHASDA’s self-determination only allows her housing authority to “be self-determining within guidelines” established by the statute. The Turtle Mountain Housing Authority spends 90% of its budget on operations and upkeep of existing units, with very little left over for new development. While the choice of how to spend federal funds is useful, with so little funding, it’s a “moot point.”

Patnaude-Olander also noted concerns over the structure of funding under NAHASDA. Funding is tied to the homes in a housing authority’s portfolio, which in the case of the Turtle Mountain Housing Authority is “basically the housing stock built under the Housing Act of 1937.” When homes leave the portfolio for any reason—including when they are paid off by tribal families under previous home ownership programs or when it’s no longer feasible to continue to rehab an older unit—funding is affected and may decrease. This makes it even harder to maintain existing units, let alone develop new ones. Additionally, she noted that the law creates a “Catch 22”: many units are vacant because they are too expensive to repair, but vacant units may be subject to losing their federal funding, leaving even fewer resources to address tribal housing needs.

Still, Patnaude-Olander doesn’t have an entirely negative view of NAHASDA. As she explains, without NAHASDA, her community wouldn’t have the ability to maintain its current housing. Plus, the law’s built-in consultation mechanisms give tribes “a seat at the table” for new federal regulations. Still, the model is far from true self-determination. After all, NAHASDA’s housing programs, like all programs, “need the necessary funding allocated to effectively run them.”

Dave Castillo

Dave Castillo, CEO, Native Community Capital and HAC board member

Tempe, AZ

Dave Castillo began his career the year after NAHASDA was signed into law. As he explains it, his colleagues held the expectation that this law would open a new era in tribal housing. “NAHASDA created opportunity,” he explains, but it required tribes to seize it.

The opportunity created by NAHASDA hasn’t yet been fully actualized, in Castillo’s view. With a “severe lack of precedent” developing new properties, instead of just maintaining them, and without the necessary capacity building, many tribal housing authorities were unable to take full advantage of the opportunities before them.

Additionally, NAHASDA hasn’t completely succeeded at bringing more funding to tribal housing. Under the law’s “regressive” funding formula, housing authorities lose funding when homes leave their portfolio. Also, since there is an expectation that tribes will leverage their NAHASDA allocation with other grants or private investment—which has been difficult if not impossible to attract—many innovative tribal housing initiatives have stalled. To make matters worse, the legislation’s goal of stimulating mortgage lending on tribal trust lands has been undercut by a loophole which gives banks credit for loans made to tribal members living off-reservation.

While Castillo has seen little “recognition of [NAHASDA’s] shortcomings,” (reauthorization of the law has failed every year since 2013) the law still contains valuable opportunities. For example, it requires federal agencies to negotiate new housing rules with tribes, a process known as “negotiated rulemaking.” In the end, Castillo takes a nuanced view on NAHASDA’s legacy. It provides an incredible opportunity, yet “we are failing” to meet Indian Country’s housing needs, even with NAHASDA.

HAC’s Recommendations to the CFPB on HMDA Rule Assessment

January 20, 2022/in Advocacy, Federal Register Comments, News, Policy Homeowner Housing

HAC submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) Request for Information regarding the Home Mortgage Disclosure Act (HMDA) Rule Assessment. HAC and our rural stakeholders have relied on HMDA data for decades to improve our understanding of rural mortgage markets. The CFPB will use these stakeholder comments to help better evaluate the effectiveness of these changes in meeting the purposes and objectives of Title X of the Dodd-Frank Act.

Key takeaways:

Reporting Threshold
HAC strongly urges the CFPB to return to the 25-origination reporting threshold, for closed-end loans, as opposed to the new 100-origination threshold, in order to more accurately capture rural markets that are disproportionately served by small financial institutions.
Reliability Index
HAC Recommends that the CFPB resource and publish a HMDA “Reliability Index.” While not a fix for overly limited reporting thresholds, the development of an indicator would be helpful for the CFPB, data users, and consumers.
Additional Data
HAC applauds increased HMDA data reporting, but additional data and reporting are still needed. While the new housing data points – specifically those on manufactured housing – enhance the HMDA data usefulness, more data could improve an understanding of certain underserved markets. This is particularly true when it comes to tribal lands and specific loan programs.
Data Browser
HAC applauds CFPB’s HMDA data browser, which offers improved access to HMDA data over previous interfaces.

HAC’s 2022 Rural Housing Policy Priorities

January 10, 2022/in Policy

Federal policy has an important and lasting impact on rural places. For the last 50 years, the Housing Assistance Council (HAC) has been the voice for the poorest of the poor in the most rural places. Our deeply rooted work in communities across the country informs our research and drives our policy positions. Our independent and non-partisan work with members of Congress, federal agencies, affordable housing and community development organizations, and other stakeholders ensures the most vulnerable rural populations – especially those in high-needs regions like the Mississippi Delta, rural Appalachia, farmworker communities, the Southwest border colonias and Indian Country – have improved access to safe and affordable housing opportunities.

Rural America is home to about 20 percent of the U.S. population and covers more than 90 percent of the U.S. landmass. Its small towns and rural regions are demographically and economically varied, and face a wide array of local challenges and opportunities for developing their communities and housing. While each place is unique, HAC has documented several themes. Persistent poverty is a predominantly rural condition. Habitable rural housing is in severely short supply. The adequate housing that does exist is often unaffordable because rural incomes are low and run well below the national median. Rural housing lacks adequate plumbing and kitchen facilities at a rate above the national average. Overcrowding is not uncommon in some rural regions. Decades of stagnant rural house prices have denied owners the wealth and mobility so often associated with buying a home. Complicating these challenges, a lack of reliable rural data obscures rural realities.

In addressing these issues, HAC’s policy priorities include:

Building the capacity of local affordable housing and community development organizations deeply rooted in rural places;
Expanding access to credit and safe, affordable lending in underserved rural communities;
Improving the overall quality, availability and affordability of housing to buy and rent in small towns and rural places; and
Preserving, increasing and tailoring resources for federal affordable housing programs serving rural populations.

We invite you to view our 2022 Policy Priorities and explore the various policy issues facing rural communities.

HAC's Policy Priorities for 2022

HAC’s Stakeholder Comments on Rural Housing Service Programs

Topline Takeaways

Multifamily

Single family

Capacity building

RHS staffing and operations