HUD Extends HOME COVID-19 Waivers
HUD recently issued two new memoranda to revise, extend, and update the pair of memoranda issued on April 10, 2020, suspending certain statutory and regulatory requirements for the HOME Investment Partnership program and HOME-Assisted Tenant-Based Rental Assistance for Emergency and Short-Term Assistance in response to the COVID-19 pandemic.
The first memorandum revises and extends certain statutory suspensions and regulatory waivers provided by the April 10, 2020, “Availability of Waivers and Suspensions of the HOME Program Requirements in Response to COVID-19 Pandemic” memorandum and adds a new statutory suspension and regulatory waivers. The memorandum revises the income documentation waiver to exclude Federal Pandemic Unemployment compensation provided under the CARES Act and the Lost Wages Supplemental Payment Assistance provided under the Stafford Act, revises requirements for Housing Quality Standard inspections and annual re-inspections, expands the four-year project completion requirement waiver, and expands the use of HOME funds for operating reserve assistance for troubled HOME projects to cover additional HOME-assisted rental projects and imposes additional requirements on owners receiving HOME operating reserve assistance.
This memorandum adds a new statutory suspension and regulatory waiver of the maximum per-unit subsidy limit and a new regulatory waiver of the income documentation requirement for owners of a HOME project in a sixth year of the period of affordability. Additionally, the memorandum extends the on-site inspections of HOME-assisted rental housing, nine-month deadline for sale of homebuyer units, and the time frame for a participating jurisdiction’s response to findings of noncompliance waivers from the original deadline of December 31, 2020, to September 30, 2021.
The second memorandum revises and extends all statutory suspensions and regulatory waivers provided in the April 10, 2020, “Suspensions and Waivers to Facilitate the Use of HOME-Assisted Tenant-Based Rental Assistance (TBRA) for Emergency and Short-Term Assistance in Response to COVID-19 Pandemic” memorandum through September 30, 2021. It also revises or clarifies the eligible TBRA costs and maximum TBRA subsidy, tenant protections—lease, Housing Quality Standards, annual inspection of units occupied by recipients of HOME TBRA, and income determination waivers.
NCSHA sent a letter to HUD in November urging immediate action on the extension of these waivers.