NCSHA Washington Report | August 26, 2022

“IMMENSELY AGAINST multifamily development!”

That’s apparently the subject line of an irate email message from the famous Silicon Valley venture capitalist Mark Andreeson and his wife protesting their upscale California town’s plan to allow some small-scale multifamily construction.

Andreeson has been skewered in some circles for hypocrisy, because he once blogged that America should be building more things, including housing, and because he recently cut the largest investment check of his storied career — $350 million — to back a new multifamily investment platform with the modest aim of “bringing every aspect of the living experience together.”

The company, called Flow, is the brainchild of the fallen founder of WeWork, Adam Neumann. While most details are undisclosed, Neumann has “been quietly acquiring majority stakes in more than 4,000 apartments valued at more than $1 billion in Miami, Atlanta, Nashville, Tenn., Fort Lauderdale, Fla., and other U.S. cities,” according to the Wall Street Journal.

Andreeson says Flow will deliver “a community-driven, experience-centric service with the latest technology in a way that has never been done before to create a system where renters receive the benefits of owners.” Sounds good.

Except it also sounds like Andreeson is IMMENSELY IGNORANT about multifamily renting. “Apartments,” he blogs, “don’t generate any bond between person and place and without community, no bond between person to person.”

Nevermind the studies showing renters spend more time in social activities than homeowners and are just as likely as owners to belong to a sports or religious group. Or research that “growing up in [Housing Credit] housing has a large positive effect on both education and earnings” and “those who spend more time in [Housing Credit] housing as children have better outcomes regardless of what neighborhood they live in.”

In fact, Flow might learn a few things about building assets and community from innovations percolating in affordable rental housing. HUD recently announced an effort called Bridging the Gap “to help renters achieve financial well-being and homeownership through saving, credit building, and banking.” The initiative knits together existing HUD programs in financial counseling and asset building with planned initiatives to reflect rental payment history in home mortgage underwriting.

HUD also announced an “historic expansion” of its flagship asset-building program, Family Self-Sufficiency (FSS), with $113 million in funding, available now for the first time to Section 8 multifamily properties as well as public housing communities. Every government dollar invested in FSS generates $2.25 in savings and income for program participants, according to research by Abt Associates.

We see no reason to wish Flow flops. While WeWork was revealed in its implosion to be more like a familiar commercial real estate services offering than a transformative tech disruptor, the company clearly tapped into something a lot of people wanted — and appears today to have a viable post-founder future.

As they seek now to transform part of our industry, here’s hoping Neumann and his investors become IMMENSELY MORE INFORMED on the benefits of conventional, affordable multifamily rental housing along the way. 

Stockton Williams | Executive Director

State HFA Emergency Housing Assistance

In This Issue

• NCSHA Welcomes New Members
• NCSHA, Other Stakeholder Groups Send HOME Guidance Recommendations to HUD
• HUD Extends PBCA/HAPSS Draft Solicitation Public Comment Period to September 28
• HUD Announces $41 Million for Housing Counseling Agencies and Intermediaries
• HUD Issues NOFA, Stability Vouchers to Reduce Rural Homelessness
• FHFA and Ginnie Mae Announce Revised Capital, Liquidity, and Net Worth Requirements
• FHA and Ginnie Mae Request Input on Title I Manufactured Housing Programs
• Looking Ahead

NCSHA Welcomes New Members
These organizations joined NCSHA as affiliate members in July and August: Arnall Golden Gregory LLP; Framework Homeownership; The Mitas Group, Inc.; and Newark Housing Authority. If you work with a partner interested in joining NCSHA, please contact Phaedra Stoger.

NCSHA, Other Stakeholder Groups Send HOME Guidance Recommendations to HUD
On August 25, NCSHA and 20 other organizations involved in the NCSHA-led HOME Coalition sent the Department of Housing and Urban Development (HUD) a letter recommending specific steps HUD should take to improve and modernize HOME program regulations and other guidance. The groups commend the Biden-Harris Administration for its commitment, stated in the Housing Supply Action Plan the administration released in May, to consider changes to HOME guidance that would strengthen and streamline the program. The letter provides consensus from a broad swath of HOME stakeholders on improvements to the program’s operations, including recommendations related to cross-cutting requirements and enhancements to rental finance, provision of tenant-based rental assistance, and homeownership programs. 

HUD Extends PBCA/HAPSS Draft Solicitation Public Comment Period to September 28
On August 24, HUD extended the comment period for the Housing Assistance Payment Contract Support Services (HAPSS) draft solicitation to 4:00 p.m. ET on September 28. NCSHA, several HFAs, other industry groups, and some federal legislators requested an extension. In its announcement, HUD said, “We value detailed feedback on the draft solicitation, and this extension will allow many of our stakeholders the time they need to submit thoughtful comments.” To help inform NCSHA’s comments on the draft solicitation, send Garth Rieman your comments by September 16.

HUD Announces $41 Million for Housing Counseling Agencies and Intermediaries
On Wednesday, HUD announced $41.3 million in grants provided to 173 housing counseling agencies and intermediaries. This is second-year funding for agencies awarded grants under the September 18, 2021, two-year Comprehensive Notice of Funding Opportunity. Of the amount, $38.6 million will support counseling services offered by HUD-approved agencies, while the remaining $2.75 million was awarded to six agencies for the ongoing education and development of housing counselors. Eighteen HFAs were awarded a total of more than $8 million during this funding round. See the complete list of agencies receiving grant funding.

HUD Issues NOFA, Stability Vouchers to Reduce Rural Homelessness
HUD has published a Notice of Funding Opportunity (NOFO) to provide $322 million for activities to reduce unsheltered homelessness, particularly in rural areas and communities with very high levels of unsheltered homelessness. The NOFO includes $54.5 million for grants to support eligible rural Continuums of Care (CoCs). The CoC program is designed to encourage communitywide cooperation among nonprofits, local and regional governments, and tribes to combat homelessness in their communities. Recipients will partner with health and housing agencies to leverage existing healthcare and housing resources. In a related announcement, HUD says it will provide $43 million in housing stability vouchers to public housing authorities that work with CoCs to reduce unsheltered homelessness. The deadline to apply for both the NOFO and the new stability vouchers is October 20.

FHFA and Ginnie Mae Announce Revised Capital, Liquidity, and Net Worth Requirements
The Federal Housing Finance Agency (FHFA) and Ginnie Mae recently released revised capital, liquidity, and net worth requirements for Fannie Mae and Freddie Mac sellers and servicers and Ginnie Mae issuers. The Enterprises’ requirements are summarized in this fact sheet, and Ginnie Mae’s are detailed in All Participant Memorandum 22-09. While largely aligned, differences are summarized in this high-level side-by-side comparison. Of note, small sellers originating less than $1 billion of mortgages in the last four quarters are excluded from the origination liquidity eligibility requirement. The effective dates vary but most are either September 30 or December 31, 2023, depending on the requirement.

FHA and Ginnie Mae Request Input on Title I Manufactured Housing Programs
Recently, the Federal Housing Administration (FHA) and Ginnie Mae jointly released a Request for Input (RFI) on their Title I Manufactured Housing Programs. Under Title I, FHA insures loans made by approved institutions for the purchase of manufactured homes and/or lots, and Ginnie Mae permits the securitization of such loans. The RFI seeks specific input on the current manufactured housing environment, the FHA Title I Manufactured Housing Program, and Ginnie Mae’s Manufactured Housing Program. Responses are due September 26. To help inform NCSHA’s comments, send Rosemarie Sabatino any input on the RFI by September 15.

Looking Ahead…

Legislative and Regulatory Activities

• September 15 | Comments Due to NCSHA | Ginnie Mae/FHA Request for Input on Title I Manufactured Housing Programs
• September 16 | Comments Due to NCSHA | HUD’s Draft Solicitation on Housing Assistance Payments Contract Support Services (HAPSS)
• September 26 | Comments Due | Ginnie Mae/FHA Request for Input on Title I Manufactured Housing Programs
• September 28 | Comments Due | HUD’s Draft Solicitation on Housing Assistance Payments Contract Support Services (HAPSS)
• October 7 | Comments Due to NCSHA | FHFA Proposed Affordable Multifamily Housing Goals for Fannie Mae and Freddie Mac
• October 17 | Comments Due | FHFA Proposed Affordable Multifamily Housing Goals for Fannie Mae and Freddie Mac
• October 20 | Applications Due | HUD Continuum of Care (CoC) Program Supplemental Funding Opportunity to Address Unsheltered and Rural Homelessness

NCSHA, State HFA, and Industry Events

• September 14 – 16 | 2022 New Mexico Housing Summit | Albuquerque, NM
  Stockton Williams and Jennifer Schwartz will speak at this event.
• September 27 – 29 | Oklahoma Housing Conference | Oklahoma City, OK
  Stockton Williams will speak at this event.
• September 29 – 30 | Novogradac 2022 Affordable Housing Tax Credit and Bonds Conference | Nashville, TN
  Jennifer Schwartz will speak at this event.
• October 18 | Ohio Housing Council Fall Symposium | Columbus, OH
  Jennifer Schwartz will speak at this event.
• October 19 – 21 | Affordable Housing Investors Council 2022 Affordable Housing Summit | Minneapolis, MN
  James Tassos will speak at this event.
• October 22 – 25 | NCSHA Annual Conference & Showplace | Houston
• November 8 | ProLink Technology Live 2022 | Virtual
  Jennifer Schwartz will speak at this event.

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