Testimony, Comments, Correspondence
IRS Regulatory Relief Available During COVID-19 Pandemic
On January 11, IRS issued Notice 2022-05 providing temporary relief to state Housing Credit allocating agencies, owners, and residents of Housing Credit properties in response to the COVID-19 pandemic. Notice 2022-05 is the fourth notice to extend Housing Credit deadlines and provide waivers of certain program rules since the onset of the COVID-19 pandemic. This matrix compares the accommodations IRS provides in Notice 2022-05 to recommendations for COVID-19 guidance NCSHA sent to IRS in letters in August and October 2021 and to existing disaster relief IRS provides under Revenue Procedures 2014-49 and 2014-50, which are applicable in cases of a presidentially-declared major disaster.
NCSHA Joins Coalition Letter Expressing Concerns About Disclosure Legislation
NCSHA recently joined the Government Finance Officers Association, National Association of Counties, U.S. Conference of Mayors, the National League of Cities, and other municipal finance groups as signatories on a letter to congressional leaders expressing concerns about S. 4295, the Financial Data Transparency Act, and its possible inclusion as an amendment to the FY23 National Defense Authorization Act.
NCSHA Comments on HUD HAPSS Draft Solicitation
On September 28, 2022, NCSHA sent the U.S. Department of Housing and Urban Development this letter urging it to withdraw or substantially revise its draft solicitation to procure contractors to provide Housing Assistance Payments contract support services (HAPSS) to HUD to help it administer approximately 17,000 project-based rental assistance contracts.
NCSHA-Led Sign-on Letter to HUD on Improvements to HOME Guidance
This letter, signed by NCSHA and 20 other organizations involved in the HOME Coalition, makes recommendations to HUD on how it should improve and modernize HOME program regulations and other guidance. The letter is in response to the Administration’s commitment in its Housing Supply Action Plan to consider improvements to HOME.
NCSHA Request for Extension of HAPSS Comment Deadline
On August 11, NCSHA submitted comments to the Department of Housing and Urban Development in response to its Request for Information on Housing Assistance Payments Contract Support Services (HAPSS), formerly known as the Performance-Based Contract Administrator (PBCA) program. In its letter, NCSHA requested HUD allow at least a 90-day comment period for stakeholders to respond; the current comment period is only 30 days after publication.
NCSHA Comments on Banking Regulators’ May 2022 Joint Notice of Proposed Rulemaking on CRA Regulations
On August 5, 2022, NCSHA submitted the attached comment letter to the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Federal Reserve on their May 2022 joint notice of proposed rulemaking amending the agencies’ Community Reinvestment Act (CRA) regulations. The letter discusses CRA’s importance in catalyzing bank financing and investments for affordable housing and other crucial community development needs, particularly Housing Credit and Housing Bonds.
ACTION Campaign Comments on CRA
On August 5, 2022, the ACTION Campaign, led by NCSHA and Enterprise Community Partners, submitted comments to the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Federal Reserve System on the joint notice of proposed rulemaking to strengthen and modernize the regulation of the Community Reinvestment Act (CRA).
NCSHA Testimony: Senate Hearing on the Role of Tax Incentives in Affordable Housing
Oregon Housing and Community Services Director Andrea Bell testified on behalf of NCSHA at a Senate Finance Committee hearing on the role of tax incentives in affordable housing. Bell told the committee the Housing Credit and tax-exempt private activity Housing Bonds are the most important production tools available to state HFAs to finance affordable rental housing and help low- and moderate-income families become home buyers.
Sign-On Letter to HUD on Build America, Buy America
NCSHA and seven other organizations sent this July 15, 2022, letter to the Department of Housing and Urban Development regarding implementation of the Build America, Buy America Act. The letter commended HUD for its work and made several recommendations.
