NCSHA Comments to HUD on the Applicability of Buy America Requirements for FY 2024 HOME and HTF Grants
On August 22, 2024, NCSHA sent a letter to the U.S. Department of Housing and Urban Development (HUD) regarding the delayed FY24 award agreements for HOME Investment Partnerships (HOME) and Housing Trust Fund (HTF) programs requesting HOME and HTF funding to be exempted from the “Buy America” Provision (BAP) requirements due to the delay in finalizing grant agreements for these programs in the current fiscal year.
While NCSHA lauds the thoughtfulness of HUD in providing temporary relief from BAP requirements for critical affordable housing supported by HOME and HTF, the letter expressed concern about the gradual implementation of the BAP requirement on procuring domestic goods and materials in certain federally funded infrastructure investments. In particular, the letter referenced Notice CPD-2023-12, which stated the relief only applies to HOME and HTF funding obligated by HUD by August 23, 2024. However, due to congressional delays in passing FY24 appropriations, HUD’s funding shortfall caused delays in issuing grant agreements for programs like HOME and HTF. While some states have received their FY24 awards, others have not, meaning strict enforcement of August 23, 2024, BAP requirements would divide grantees into those under a waiver and those subject to the new rules.
