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Testimony, Comments, Correspondence

NCSHA Summary of the First Generation Downpayment Fund

This summary provides details of the proposed ā€œFirst Generation Down Payment Fundā€ program. This program has been included in the text of the ā€œBuild Back Better Actā€ that passed the House of Representatives on November 19, 2021. This summary reflects the Senate Banking Committee print of its provisions for the Build Back Better Act it released December 9. Originally published on October 29 and updated on December 13. NCSHA will update this summary as events warrant.

Housing Credit Stakeholder Sign-On Letter to IRS, Treasury on Average Income Test

NCSHA and 32 other Housing Credit Stakeholders organizations sent this letter to the Internal Revenue Service and the U.S. Department of Treasury urging them to issue a finale rule on the Housing Credit Average Income Test (AIT) minimum set-aside considering the modifications outlined in the letter or announce their intention to publish a new proposed rule for public comment.

Housing Credit Stakeholder Sign-On Letters in Support of Fixing Qualified Contracts, Right of First Refusal

These letters from NCSHA and other Housing Credit stakeholders to House Speaker Nancy Pelosi, House Ways and Means Committee Chair Richard Neal, Senate Majority Leader Charles Schumer, and Senate Finance Committee Chairman Ron Wyden express support for provisions in reconciliation legislation to close the qualified contract loophole and mitigate investor challenges to nonprofit developers seeking to exercise their statutorily given right of first refusal.

NCSHA Summary of the Neighborhood Homes Investment Act

This summary provides details from the ā€œNeighborhood Homes Investment Act,ā€ text of which was included in the Build Back Better Act that passed the House of Representatives on November 19, 2021.Ā 

Campaign for Housing and Community Development Funding Letter on FY 2022 Appropriations

This November 19, 2021, letter sent by NCSHA and fellow steering committee members of the Campaign for Housing and Community Development Funding (CHCDF) urges Congress to enact fiscal year 2022 appropriations bills as soon as possible and outlines the devastating impacts on affordable housing and community development programs when multiple, or lengthy, continuing resolutions are in place.

NCSHA Letter to Treasury on Quarterly Reporting

This letter, sent by NCSHA to the Treasury Department on November 16, 2021, urges Treasury to provide a blanket extension for Emergency Rental Assistance quarterly reports until such time as the department is able to streamline quarterly reporting requirements, provide grantees with technical assistance on reporting, and fix technical problems in Treasuryā€™s ERA reporting portal.

CHCDF Sign-On Letter to Congress Urging Enactment of the Build Back Better Act

On November 10, 2021, the Campaign for Housing and Community Development Funding, of which NCSHA is a member, sent this letter to congressional leadership urging them to quickly enact the $154 billion investments in critical housing and community development investments in the Build Back Better Act.

NCSHA Letter to HUD on FHA Proposed 40-Year Loan Modification

On October 29, 2021, NCSHA sent this letter to the U.S. Department of Housing and Urban Development (HUD) to discuss the negative impact that the Federal Housing Administration proposed 40-year loan modification would have on the state HFA Mortgage Revenue Bond programs and request that HUD either exempt state HFAs from this requirement or permit them to request and be granted a waiver.

NCSHA Letter to OCC on Proposed Community Reinvestment Act Reforms

On October 29, 2021, NCSHA submitted this letter to the Office of the Comptroller of the Currency (OCC) on its September 2021 proposed rule to amend its Community Reinvestment Act (CRA) regulations finalized in June 2020. In the letter, NCSHA expressed support for OCCā€™s proposal which would effectively rescind its current CRA rules and replace them with its previous CRA regulations while it works with other federal banking regulators to develop common CRA rules. NCSHA argues that the current CRA guidance could reduce bank investments in Housing Credits, Housing Bonds, and other needed community and economic development activities.