Testimony, Comments, Correspondence
NCSHA Joins Letter in Support of HUD Multifamily Notice on Qualified Contract Loophole
NCSHA and several other leading affordable housing groups signed a letter to HUD providing feedback on a recently posted Housing Notice regarding the Qualified Contract loophole in the Low-Income Housing Tax Credit program
NCSHA Comments to HUD on Proposal to Mitigate Qualified Contract Loss for Properties Seeking FHA Multifamily Rental and Risk Share Insurance
NCSHA sent a letter to Federal Housing Commissioner Julia Gordon expressing support for the proposal that requires developers applying for new allocations of Low Income Housing Tax Credit authority to waive the qualified contract option for their properties as a condition for participating in the Federal Housing Administration (FHA) Multifamily Rental and Risk Share insurance programs.
NCSHA Comments to HUD on the Applicability of Buy America Requirements for FY 2024 HOME and HTF Grants
NCSHA sent a letter to the U.S. Department of Housing and Urban Development (HUD) regarding the delayed FY24 award agreements for HOME Investment Partnerships (HOME) and Housing Trust Fund (HTF) programs requestingย HOME and HTF funding to be exempted from the "Buy America" Provision (BAP) requirements due to the delay in finalizing grant agreements for these programs in the current fiscal year.
NCSHA Comments to FHFA on Application Process for Federal Home Loan Banksโ Affordable Housing Programs
On August 19, 2024, NCSHA submitted the attached letter in response to the Federal Housing Finance Agencyโs (FHFA) Request for Input on potential changes to the application process for the Federal Home Loan Banksโ (FHLBs) Affordable Housing Programs (AHP). The letter recommends that each FHLB consult with HFAs and other bank members when setting the timeline and other policies for its AHP application process so as to maximize the potential for AHP fund to be used in conjunction with financing from the Housing Credit and other federal and state housing programs.
NCSHA Comments to FHFA on GSE Duty to Serve Plans for 2025-2027
On August 12, 2024, NCSHA submitted the attached letter responding to the Federal Housing Finance Agencyโs (FHFA) June 11 Request for Input (RFI) on the government-sponsored enterprises (GSEs) Fannie Maeโs and Freddie Macโs Underserved Markets Plans for years 2025-2027. The letter encourages FHFA and the GSEs to continue to explore potential partnerships with HFAs to meet their Duty to Serve obligations. The letter advances several specific suggestions for potential GSE-HFA collaborations, including expanded activity in the Credit market, funding and equity for preserving affordable housing properties financed through the U.S. Department of Agricultureโs (USDA) Section 514 and 515 programs, promoting rural homeownership, and affordable home improvement financing.
HOME Coalition Comments on HUD HOME Investment Partnerships Program: Program Updates and Streamlining Proposed Rule
The HOME Coalition, led by NCSHA, sent a letter to the US Department of Housing and Urban Development on the proposed rule, HOME Investment Partnerships Program: Program Updates and Streamlining.
NCSHA Comments on HOME Investment Partnerships Program: Program Updates and Streamlining Proposed Rule
NCSHA submitted comments to the US Department of Housing and Urban Development on the proposed rule, HOME Investment Partnerships Program: Program Updates and Streamlining.
NCSHA Comments on FHFA RFI on Federal Home Loan Bank System Mission
On July 11, 2024, NCSHA submitted this letter responding to the Federal Housing Finance Agencyโs May 16 request for input on the mission of the Federal Home Loan Bank System. In its comments, NCSHA urged FHFA to establish an explicit affordable housing mission for the FHLB System and encourage more FHFA-HFA partnerships.
NCSHA Letter on IRS Revenue Procedure 2024-21
On June 14, 2024, NCSHA submitted comments to the Internal Revenue Service on Revenue Procedure 2024-21, which proposes to change the data set used to establish the Mortgage Revenue Bond (MRB) and Mortgage Credit Certificate (MCC) programsโ purchase price safe harbors from the Federal Housing Administrationโs loan limits to median home price data collected by the U.S. Department of Housing and Urban Development. NCSHA urged the IRS not to go forward with the proposed change.
