Tag Archive for: Federal Register comments

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HAC Comments Support USDA Housing Research

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In February, USDA requested comments on opportunities, challenges, and emerging areas in statistical data, analysis, and research produced by some of its offices, including the Economic Research Service (ERS). The department said the information it collects will help inform USDA as it considers future program direction, new initiatives, and potential funding opportunities.

HAC submitted a response to USDA emphasizing the following points, focusing on ERS because its work covers rural housing and community development.

  • ERS is an immensely valuable institution and resource for rural America.
  • USDA should invest more in housing data and research.
  • ERS should expand its relationship with Rural Development and specifically the Rural Housing Service to provide increased and better data on housing resources the agency administers.
  • USDA should provide more publicly available data to help inform strategies to address the “maturing mortgage crisis” within the Section 515 Rural Rental Housing Loan Program – especially data on why properties left the portfolio.
  • Data on properties and residents that are leaving the USDA Section 515 rental stock is vital to preservation efforts.
  • More detailed data on the ownership structure of USDA Section 515 properties would enhance production and preservation efforts for this key housing resource.
  • The Housing Assistance Council increasingly utilizes sub-county data for analyses when available.
  • ERS should continue its research and provide data on philanthropic investments to rural America.
  • USDA should coordinate with the Department of Labor and other federal agencies and institutions to develop much-needed data resources that inform an understanding of how agricultural workers obtain and access housing.
  • USDA should report Section 502 Direct Loan activity to the Consumer Financial Protection Bureau and the Federal Financial Institutions Examination Council through the Home Mortgage Disclosure Act.
  • USDA should work with HUD and the Census Bureau to put “rural” back into the American Housing Survey.

HAC CEO Responds to FY 2027 Budget Proposal

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On Friday, April 3rd, the White House released its full Fiscal Year (FY) 2027 Budget Proposal. While there are a few improvements over FY 2026 for housing affordability programs, the Housing Assistance Council (HAC) is gravely concerned about the number of programs that are slated for underfunding or elimination.

“The FY 2027 budget includes positive steps, such as restored support for USDA’s Section 502 Direct program,” said David Lipsetz, President & CEO of the Housing Assistance Council. “We welcome support for low-income homeownership during an affordability crisis. However, the proposal falls short of what is needed by failing to preserve the nation’s aging stock of rural rental housing and eliminating proven initiatives.”

At the U.S. Department of Agriculture (USDA), funding for both USDA’s Section 515 Rural Rental Housing and its Multifamily Preservation and Revitalization programs would remain at FY 2026 levels, but the budget fails to provide returns on investment or asset management fees for nonprofit and public agency owners.  Additionally, although the budget continues to support Stand‑Alone Rental Assistance to protect tenants when USDA mortgages mature, it proposes eliminating Section 542 vouchers without clearly addressing the impact on current households currently in the voucher program.

If enacted, the Administration’s budget proposal would be particularly damaging to people experiencing homelessness and unaffordable housing by eliminating a number of Department of Housing and Urban Development (HUD) programs that have a proven track record when it comes to serving Americans. The proposal eliminates the HOME Investment Partnerships Program, the Community Development Block Grant (CDBG), the Continuum of Care Program, the Housing Opportunities for Persons with AIDS (HOPWA) Program, Native American programs and Native Hawaiian Housing Block Grants, and fair housing activities.

HAC commends the Administration’s focus on rural-serving Community Development Financial Institutions (CDFIs) in its Treasury Department funding proposal. But our organization recognizes we live in a deeply interconnected nation. We have argued that if rural areas are left behind, the whole nation suffers. The opposite is true also; thus we cannot condone the Administration’s dramatic funding reduction and consolidation of the current CDFI grant programs into a single Rural Community Development Fund.

Perhaps most concerning, the proposal severely cuts funding for capacity building and technical assistance for rural communities. More than anywhere in America, small towns and rural places can struggle to maintain the expertise needed to succeed in the complex world of housing and community development. The budget calls for eliminating Rural Capacity Building at HUD and both the Rural Community Development Initiative and Preservation Technical Assistance at USDA. Such cuts to technical assistance and capacity building programs will prevent community organizations from getting new housing projects off the ground, while also limiting the critical resources they need to complete ongoing projects.

HAC urges Congress to strengthen the FY 2027 budget by restoring technical assistance for rural housing preservation, ensuring rental assistance transitions do not leave tenants behind, fully funding all programs at HUD, and providing nonprofit owners with the tools they need to sustain affordable housing over the long term. In addition, HAC also urges Congress to continue the efforts begun in the Fiscal Year 2026 appropriations bill by specifically adding language to compel the Administration to spend appropriated funding. Read HAC’s full analysis of the Administration’s Fiscal Year 2027 budget proposal for USDA and for HUD.

PRT, HAC, HOPE Release Opportunity Zone 2.0 Recommendations

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The Housing Assistance Council (HAC) in collaboration with Partners for Rural Transformation (PRT) and Hope Credit Union/Hope Enterprise Corporation/Hope Policy Institute (HOPE) Wednesday released recommendations for the Opportunity Zone 2.0 designations to drive investments into rural communities facing persistent poverty.

PRT President Farah Ahmad said: “Opportunity Zones hold tremendous potential to drive investment into rural communities facing persistent poverty across the country – if they are done correctly. This guide offers a framework for state policymakers and local practitioners to ensure that this once-in-a-decade opportunity is not missed in the rural communities millions of people call home.”

HAC President and CEO David Lipsetz said: “Investment in persistently poor rural places is an essential step to address our nation’s affordable housing crisis. State officials have an important opening this year to identify the right places for this investment. This guide explains what’s at stake and how they can take action.”

HOPE Senior Advisor for Policy and Advocacy Diane Standaert said: “With this upcoming round of Opportunity Zone selections, states have a once-in-decade chance to get it right for rural places. HOPE’s experience demonstrates how it’s possible to align community-driven solutions, private investors, and public policy to drive transformative change in rural communities, including those experiencing persistent poverty. With advance planning as recommended in this guide, states can ensure they do not overlook solutions for economic opportunity in the rural areas that need it most.”

Created by the Tax Cuts and Jobs Act of 2017, Opportunity Zones spur economic growth and job creation in low-income communities while providing tax benefits to investors. The first round of Opportunity Zones generated $120 billion in new investments across the country. However, only a fraction of that, about $6 billion, flowed into rural communities by 2022, and even less reached areas experiencing persistent poverty.

The program was amended in the One Big Beautiful Bill Act (OBBBA) and added new incentives for rural communities, including a 30% step-up in basis points for investments and a 50% threshold for showing substantial improvement to rehabilitation projects. However, an overly broad definition of “rural” risks funding being diverted away from targeted rural and Native communities. For example, Atlantic City meets the definition of a “rural Opportunity Zone” under the OBBBA.

Activating Rural Investments in the Next Round of Opportunity Zones: Recommendations for States  can be found here. The recommendations follow four guidelines:

  • Engage Rural Communities, Native Communities, and Practitioners: Hearing directly from rural communities through organizations like Community Development Financial Institutions and non-profit developers will help state and local leaders designate Opportunity Zones that will have the greatest impact.
  • Create a Map that Targets Unique Rural Needs and Development Goals: Mapping tools can assist state and local leaders in designating rural areas where investment is needed most and illuminate the opportunities to leverage additional investment incentives.
  • Create Priorities in State Funding Programs: States can take a more active role in driving investment into rural communities facing persistent poverty by prioritizing projects within preexisting state programs to attract additional resources and investors.  
  • Create an Assessment Tool: Establishing a clear decision-making rubric can ensure high-impact selections are made in a transparent manner.

PRT, HAC, and HOPE hosted a webinar on the guide for state policymakers, regional development hubs, and local non-profits on March 12. The recording is available here.   

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HAC Opposes HUD Proposal to Eliminate Disparate Impact Fair Housing Rules

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The Department of Housing and Urban Development has proposed to change its Fair Housing Act regulations. The revisions would eliminate HUD’s rules on disparate impact — the legal concept that conduct is discriminatory if it has inequitable effects, even if there was no intent to discriminate. HAC does not support the proposed change and strongly urges HUD to retain and enforce its current rule. HAC argues that:

  • “Housing affordability and fair housing connect through the principle of ‘disparate impact.’”
  • Rural borrowers more often receive loans with more costly terms and rural residents are disproportionately members of protected classes.
  • Court decisions have not invalidated disparate impact liability.
  • HUD has an explicit statutory responsibility to ensure equal opportunity and freedom from discrimination.
HAC Disparate Impact Comments 2026 Final
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HAC Opposes Proposed Changes to ECOA Equal Lending Rule

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The Consumer Financial Protection Bureau has proposed to change its rules for the Equal Credit Opportunity Act, which requires fairness in lending, including mortgage lending. The revisions would eliminate use of disparate impact — the legal concept that conduct is discriminatory if it has inequitable effects, even if there was no intent to discriminate — and would revise provisions on discouragement of applicants or prospective applicants and on special purpose credit programs. HAC’s response argues that disparate impact is a necessary tool to identify discrimination in mortgage lending, including discrimination against rural residents.

CFPB ECOA disparate impact HAC Final
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HAC Supports Rural Provisions in Capital Magnet Fund Interim Rule

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The CDFI Fund has released for comment an interim rule for the Capital Magnet Fund (CMF) program. The Capital Magnet Fund offers competitively awarded grants to CDFIs and nonprofit affordable housing organizations to finance affordable housing solutions and community revitalization efforts that benefit individuals and families with low-incomes and low-income communities nationwide. HAC has received several CMF awards, most of which have been used for the preservation of USDA’s Section 515 multifamily properties amid the maturing mortgage crisis. HAC is broadly supportive of the CMF interim rule, and submitted comments on several rural elements, including:
  • Support for the addition of a national Rural Service Area. This change will make it easier to use CMF in rural areas, and will all organizations who serve rural areas across the country to be nimble and flexible with their CMF funds.
  • Support for aligning CMF income targeting with other federal programs, with the caveat that the application competition should prioritize applications that propose deeper income targeting. Not all CMF deals include LIHTCs, especially in rural places. We encourage the CDFI Fund to consider how to continue to encourage this deeper income targeting in the CMF application scoring process, since raising the Very Low-Income threshold could result in fewer households under 50 percent AMI being served.
  • Support for the use of the Duty to Serve definition for rural areas. HAC has done extensive research on the myriad of rural definitions, and feels that the Duty to Serve definition is the most precise rural definition available.
HAC CMF Rule Comments 08.26.24
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HAC Comments on Proposed New Rule for HOME Investment Partnerships Program

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In late May, HUD published a proposed rule which would enable much needed revisions and updates to the requirements governing the HOME Investment Partnerships program. The proposed rule would make changes across the HOME program, from homeownership to rental, and included a specific focus on improving Community Housing Development Organization (CHDO) availability and capacity in rural areas. In response, HAC submitted comments on the proposed rule, applauding many of the proposed changes and pushing for additional rural-focused priorities. Specifically, key takeaways in HAC’s comments included:
  • The reality of the rural landscape must be taken into consideration as this new rule is finalized. Affordability is the greatest issue facing rural communities, like it is for the country at large. But rural areas are also disproportionately impacted by persistent poverty, substandard and overcrowded housing, and a lack of local capacity and access to capital.
  • Varying HOME program administration across Participating Jurisdictions (PJs) has been the most significant barrier for the small rural communities we serve. Over the last decade, we have observed that rural organizations experience significant challenges in effectively accessing HOME funds. Primarily, these difficulties arise from how PJs have adapted their programs, largely as a response to the 2013 regulation changes and subsequent funding reductions. PJs will need significant training in the impacts of this new rule to ensure it is implemented effectively.
  • Regulatory change alone cannot solve all the challenges within the HOME program. Because of the highly prescriptive nature of the HOME statute, a variety of statutory changes are also needed to fully transform the program such that it more positively impacts rural America.
  • Rural Community Housing Development Organizations will benefit from the proposed changes, but more is needed to move the needle. HAC applauds changes to Board Member requirements, organizational capacity requirement, and capacity building funds. We do, however, have concerns around the proposal to allow for statewide CHDOs, intended to improve rural program outcomes. Statewide CHDOs could inadvertently further disadvantage small, rural groups who are hoping to access the CHDO set-aside by forcing them to potentially compete with high-capacity, statewide organizations.
  • Streamlining and improved flexibility across the program is welcome. Helpful changes are proposed with respect to homebuyer housing, rental housing, Community Land Trusts, tenant-based rental assistance, tenant protections, maximum per-unit subsidy limits, and green and resilient property standards. These changes will help small, lower capacity groups to access and see success with the HOME program.
HAC HOME Rule Comments 07.29.24 FINAL
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HAC Comments on Duty To Serve Plan Modifications – December 2023

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The Federal Housing Finance Agency (FHFA) put out a call for comments on the Enterprises’ (Fannie Mae and Freddie Mac’s) proposed 2023 Duty to Serve Plan modifications. Both Enterprises proposed cutting a variety of their loan purchase goals in rural areas, citing market conditions as the justification. HAC pushed back on these proposed cuts in our comments. Specifically, HAC made in following points in our comment:

  • HAC is generally agnostic as to which section of Freddie Mac’s Duty to Serve plan USDA Section 515 purchases fall under, but strongly supports their continued inclusion and tangible results. We support mainlining the Section 515 purchases currently included in the rural section of the plan because they focus on rural-targeting of properties.
  • HAC opposes cuts to loan purchase goals in high-needs rural regions and from small, rural financial institutions.
  • HAC opposes cuts to loan purchase goals for manufactured housing communities.
  • HAC supports Fannie Mae’s new proposed objective to better serve the manufactured housing needs of Native communities.
  • HAC support permitting the Enterprises to make investments in CDFIs – a decision which relies on approval from the FHFA.
HAC DTS Plan Modification Comments 12.06.23 FINAL
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
Policy News from the Administration

HAC’s Comments on Rental Assistance Decoupling – August 2023

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The Fiscal Year 2023 President’s Budget included a request to decouple USDA Section 521 Rental Assistance from Section 515 Multifamily Loans to facilitate the rehabilitation and preservation of the multifamily portfolio. To explore the potential impacts, Congress directed USDA to conduct a series of stakeholder meetings and provide a report on how decoupling would be implemented. HAC submitted comments in support of decoupling, with a focus on the topics below.

  • Making Long Term Affordability Parameters the Top Priority
  • Considering A Pilot Concept When Implementing Decoupling
  • Clarifying the Annual Rent Increase Process for Decoupled RA Units
  • Establishing A Plan for Units Without Rental Assistance in Decoupled Properties
  • Maintaining Support for the Entire Suite of Preservation Programs, Even If Decoupling Becomes an Option
  • Establishing A Plan for Prepayments, Since the Bulk of Units Are Lost to Prepayments
  • Improving Data Transparency At RHS

Read HAC’s full comments.

HAC Decoupling Comments 2023

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