HUD Issues HTF Allocation Plan Guidance
On April 26, HUD issued Notice CPD-16-07 providing guidance to Housing Trust Fund (HTF) grantees on the submission requirements for Fiscal Year (FY) 2016 HTF Allocation Plans. The Notice includes important information on the HTF allocation plan process, including how HUD will notify states of their allocation, required elements of the allocation plan, and guidance on revising state strategic plans and describes changes HUD has made to the consolidated plan regulations to account for the HTF allocation plan process. The Notice also details the process by which HUD will review and approve or disapprove of HTF allocation plans.
States will need to review their current strategic plan to determine how the additional HTF resources will impact that plan and amend the strategic plan accordingly even if the state is not due to submit a full five-year consolidated plan in 2016. States will also need to include their HTF allocation plan in their annual action plan. If a State has not finalized its HTF allocation plan by the time it submits its action plan for FY 2016, the state may submit the HTF allocation plan as an amendment to its action plan, so long as the amendment is submitted by August 16, 2016.
The HTF Allocation Plan must set forth the criteria for the selection of applicants based on factors including geographic diversity, applicant capacity, the extent to which the project has project-based rental assistance, duration of affordability, priority housing needs of the state, use of non-federal funding sources, eligible activities, and other priorities detailed in the notice.
HUD has not fully updated its eCon Planning Suite (the system used to submit Consolidated Plans and Action Plans) to reflect HTF allocation plan data fields, and HUD does not expect to finalize this until after states submit their first HTF allocation plans. As such, states will need to submit all required information that cannot be added to eCon Planning Suite by emailing their final HTF allocation plans to the applicable Field Office CPD Director and the Office of Affordable Housing Programs (HTF@hud.gov) as a Microsoft Word document or PDF file. HUD will notify HTF grantees once it has updated the eCon Planning Suite.
If a state submits its HTF allocation plan with its annual action plan, HUD will review and approve the HTF allocation plan as part of its review of the action plan. If a state submits its HTF allocation plan as an amendment to the action plan at a later date, HUD will review and approve the HTF allocation plan separately within 45 days of receiving the allocation plan.
As NCSHA has previously reported, HUD expects to publish state-by-state HTF formula allocations by the end of April and disburse FY 2016 HTF funds to states this summer. In order to be eligible for these HTF funds, states must designate an agency to administer the program, as well as prepare and submit an HTF allocation plan.