Testimony, Comments, Correspondence
NCSHA Asks Veterans Affairs to Maintain Partial Claim Payment Option
On October 17, 2022, NCSHA sent this letter to the U.S. Department of Veterans Affairs (VA) urging the Secretary to extend temporarily the October 28 expiration date of the VA Partial Claim Payment for homeowners who have been pre-qualified by their stateās Homeowner Assistance Fund program.Ā
NCSHA Comments on FHFA Proposed 2023 and 2024 Multifamily Housing Goals for Fannie Mae, Freddie Mac
On October 17, 2022, NCSHA submitted these comments in response to the Federal Housing Finance Agencyās (FHFA) proposed multifamily goals for Fannie Mae and Freddie Mac for 2023 and 2024. In the letter, NCSHA expressed support for FHFAās proposal to change the goals from requiring that a set number of units financed by the firms meet the goals to requiring that a certain percentage of the units financed meet the goals. NCSHA also asked FHFA to increase the specific goal thresholds it proposes.
Joint Letter to Treasury Requesting an Extension to ERA Reporting Deadline for Quarter 3 of 2022
NCSHA, along with other major national organizations representing Emergency Rental Assistance (ERA) grantees ā the 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 Cities ā sent this October 11, 2022, letter to the Treasury Department requesting an extension of the ERA reporting deadline for Quarter 3 of 2022.Ā
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 Administrationās commitment in its Housing Supply Action Plan to consider improvements to HOME.Ā
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.Ā
NCSHA Comments on Banking Regulatorsā 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 agenciesā Community Reinvestment Act (CRA) regulations. The letter discusses CRAās importance in catalyzing bank financing and investments for affordable housing and other crucial community development needs, particularly Housing Credit and Housing Bonds.
