Resources
NCSHA Comment Letter to FHFA on Proposed Duty to Serve Rule
On July 24, NCSHA sent the attached comments to the Federal Housing Finance Agency (FHFA) in response to FHFA’s proposed rule amending its Enterprise Duty to Serve Underserved Markets regulations. In the letter, NCSHA expressed strong support for FHFA’s proposal to allow the GSEs to receive credit under the Duty to Serve Rule for Housing Credit investments that support housing in all the underserved markets covered by the rule; currently, only Housing Credit investments for homes in eligible rural areas may receive credit. NCSHA also recommends that FHFA expand the Duty to Serve eligibility for GSE purchases and credit enhancements of tax-exempt Housing Bonds and urges the agency to make sure that any new requirements put in place continue to incentivize the GSEs to pursue activities in challenging sectors of the housing market.
NCSHA Comments on HUD Build America, Buy America RFI
NCSHA submitted this comment letter to the U.S. Department of Housing and Urban Development in response to its Request for Information on the availability of domestically manufactured products used in HUD-funded housing programs under the Build America, Buy America Act (BABA). While supporting HUD’s effort to better understand domestic manufacturing capacity, NCSHA urged the department to pursue a broader overhaul of BABA implementation, arguing that the current process is unnecessarily burdensome, increases project costs, and delays the development of affordable housing, and offered a proposal for implementing BABA in a manner that works for housers and manufacturers.
Policy Brief Series: Unpacking the 21st Century ROAD to Housing Act
The 21st Century ROAD to Housing Act is the most comprehensive overhaul of America’s affordable housing programs in decades, making significant changes to existing programs, establishing new temporary pilot programs and policies, and mandating new research and reporting to inform future housing policy. NCSHA published a series of white papers in 2026 providing in-depth analysis of the housing reforms enacted by the legislation.
State Housing Finance Agencies: At the Center of the Affordable Housing System
State housing finance agencies are at the center of the solutions. This report describes how they do it.
NCSHA Letter on Proposed Changes to the Federal Uniform Guidance
NCSHA submitted comments to the Office of Management and Budget (OMB) expressing concerns with proposed revisions to the Uniform Guidance, which governs the administration of federal financial assistance.
Coalition Comment Letter to Federal Banking Regulators on Capital Standards for Housing Credit Properties in Amended Bank Capital Standards
NCSHA joined 26 other housing advocacy organizations to comment on a series of Notices of Proposed Rulemaking (NPRs) issued by federal banking regulatory agencies — the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — modifying the federal bank capital standards. The letter suggests the Regulators the lower the amount of capital banks are required hold on their books for Housing Credit investments and Housing Credit finance properties from 100 percent to 20 percent, and argues that they shouldn’t be set at a level above 50 percent.
Coalition Letter to HUD to Preserve Restore-Rebuild Initiative
NCSHA and a broad group of affordable housing organizations sent this June 18, 2026, letter urging HUD to rescind its May 2026 memorandum terminating the Restore-Rebuild initiative, which allows public housing authorities to develop new housing up to their Faircloth limit and convert those units to long-term Section 8 assistance through the Rental Assistance Demonstration (RAD) program.
Housing Industry Statement and Proposal on Build America, Buy America Implementation
NCSHA led an effort to coordinate housing industry organizations and businesses in support of this position statement on Build America, Buy America (BABA) requirements’ impact on affordable housing production, including a proposal to improve the BABA implementation and waiver processes.
NCSHA Comment Letter to Federal Banking Regulators on Amended Bank Capital Standards
NCSHA commented on a series of Notices of Proposed Rulemaking (NPRs) issued by federal banking regulatory agencies — the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — modifying the federal bank capital standards. In the letter, NCSHA urges the regulators to reduce the amount of capital banks are required to hold for properties financed by the Housing Credit and Housing Bond investments. NCSHA also expresses opposition to a provision in the NPRs that would base the risk-weights for single-family home purchase loans entirely in a loan’s loan-to-value ratio.
