Testimony, Comments, Correspondence
Joint Letter to HUD on Build America, Buy America Requirements
NCSHA and nine other organizations sent this January 13, 2023, letter to the Department of Housing and Urban Development regarding the implementation of the Build America, Buy America Act. The letter commended HUD for its work and made several recommendations.ย
Joint Letter to Treasury on Policies Related to Suspected Fraudulent Applications
NCSHA, along with other major national organizations representing Emergency Rental Assistance (ERA) granteesโthe American Public Human Services Association, Council of State Community Development Agencies, National American Indian Housing Council, National Association of Counties, National Community Development Association, and National League of Citiesโsent this December 20, 2022 letter to Treasury urging the Department to clarify its policies related to repayment in the case of suspect fraudulent application for assistance.ย
Novogradac LIHTC Working Group โ NCSHA Comments on Average Income Test Temporary Regulations
NCSHA joined the Novogradac LIHTC Working Group on this December 12, 2022, comment letter to the Internal Revenue Service suggesting technical changes to the Average Income Test (AIT) temporary regulations related to reporting requirements for AIT compliance.
NCSHA Comment Letter on HUD Small Mortgage Lending RFI
On December 5, 2022, NCSHA submitted these comments to HUD in response to its Request for Information Regarding Small Mortgage Lending.ย NCSHA agreed with HUD's conclusion that a primary barrier to small balance mortgage loan lending is the cost to originate and service small mortgage loans in relation to the limited potential compensation afforded by them. NCSHA proposed three recommendations for HUD to consider during any rule-making process surrounding small mortgage lending.
NCSHA Comment Letter on EPA Greenhouse Gas Reduction Fund RFI
On December 5, 2022, NCSHA submitted this letter to the Environment Protection Agency (EPA) in response to its Request For Information on the Greenhouse Gas Reduction Fund (GHGRF). NCSHA urged the EPA to prioritize the use of GHGRF for affordable housing, where such assistance could significantly reduce greenhouse gas emissions and significantly improve the lives of the residents of affordable housing properties and the communities in which they are located.
HOME Coalition Letter to Appropriators for FY23
On November 28, 2022, the HOME Coalition sent this letter to appropriators in both congressional chambers urging them to provide robust funding for the HOME Investment Partnerships program for the remainder of fiscal year 2023. The letter requested no less than $1.9 billion for the program, which is the amount included in the Presidentโs FY23 Budget Request.
ACTION Letter on Housing Credit Priorities in the Lame Duck Session
This November 21, 2022, letter, organized by the ACTION Campaign and signed by more than 2,500 businesses, nonprofits, and organizations from across the nation, urged Congress to pass legislation during the 2022 lame duck session that would expand production of affordable housing by increasing Housing Credit authority by 50 percent and enhancing the use of Private Activity Bond authority for rental housing production by lowering the bond financing threshold from 50 to 25 percent. NCSHA and Enterprise Community Partners co-chair the ACTION Campaign.ย
NCSHA’s 2022 Election Analysis
NCSHA offers these analyses of the 2022 election results.
NCSHA Comment Letter on FHFA Review of Federal Home Loan Banks
On October 31, 2022, NCSHA submitted comments to the Federal Housing Finance Agency (FHFA) as part of FHFAโs recently announced comprehensive review of the Federal Home Loan Banks (FHLBs). Reflecting feedback from HFAs, including those who work closely with their FHLB, NCSHA asked FHFA to maintain the FHLB systemโs regional structure, which helps to ensure that the FHLBs better address the nationโs diverse housing needs. NCSHA also urged FHFA to consider ways the FHLBs can better pair their affordable housing activities with important federal, state, and local government programs, particularly those administered by HFAs, and to recommend to Congress that each FHLB's contribution level for their Affordable Housing Programs be increased from 10 to 15 percent.
