HAC Comments on Proposed New Rule for HOME Investment Partnerships Program
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:
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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.
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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.
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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.
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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.
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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.
