On September 14, HUD published for public review and comment a proposal to end its hold harmless policy used to calculate Section 8 income limits.  For Fiscal Year (FY) 2009, HUD continued its policy of maintaining Section 8 income limits at the previously published level in cases where HUD’s analysis would lead to a lower income limit than was previously published.  The policy was adopted to ensure that Housing Bond and Credit-financed developments would not be subject to income limit and rent increases when the data underlying income limits otherwise indicated decreases.  HUD’s proposal says that the Housing and Economic Recovery Act of 2008 (HERA) changed the tax code to protect Bond and Credit properties from decreases in income limits and rents, should HUD decide to discontinue this policy.  HUD also says maintaining artificially high income limits may have an adverse impact on other federal programs. 
HUD is requesting comments on whether HUD should discontinue its hold harmless policy with respect to Section 8 income limits, which would allow income limits to decrease in some areas.  Comments are due to HUD by October 14, 2009. 
NCSHA will submit comments on this proposed policy change to HUD on behalf of state HFAs.  Please send comments you would like included in NCSHA’s submission to NCSHA’s Ellen Lurie Hoffman by October 7, 2009.