NCSHA Washington Report | October 24, 2025
The Council of Large Public Housing Authorities, pointing to “chronic disinvestment and aging developments” and “evidence that the unmet capital needs in public housing are growing,” says in a report released yesterday that it will take $169.1 billion to fix and modernize this stock of roughly one million homes serving some of the poorest Americans.
Largely as a result of Congress’ failure for years, under both Republican and Democrat control, to adequately fund upkeep, more than 30 percent of public housing homes failed their latest HUD property inspections, up from 15 percent in 2019, “and likely require immediate investment” to stem further deterioration, according to analysis by the National Housing Preservation Database.
Since Congress effectively stopped funding new construction of public housing more than 25 years ago, the stock has shrunk by more than 250,000 homes. The losses are part of a larger trend that has seen the number of apartments renting for under $600 nationwide plunge by 2.5 million over the past decade.
A bright spot has been the Rental Assistance Demonstration (RAD) program, through which local housing authorities “convert” properties’ underlying financing to tap a wider range of capital sources that can help sustain them. The program has generated $25 billion in funding for improvements, most of which would have been inaccessible under the traditional operating model.
State housing finance agencies have been major funders of these kinds of transformations from RAD’s inception and now finance an average of 10,000 homes involved in the program per year, with Housing Credits, Housing Bonds, and various subsidies.
HFAs are often at the forefront of innovative iterations in public housing preservation financing, such as “blended” transactions in which the Delaware State Housing Authority and Ohio Housing Finance Agency recently have been involved. (Many agencies are also partners in large-scale redevelopments of public housing communities, like one that broke ground in Durham, NC, backed by the North Carolina HFA last month.)
Importantly, RAD has earned bipartisan support in Congress, most recently in the Senate-passed ROAD to Housing Act, which would make the demonstration program permanent. The bill also beefs up renter protections and may even open a regulatory lane that could lead to some new public housing construction.
The greater involvement of private enterprise in public housing through RAD makes some uneasy about the long-term implications for properties that exist to serve economically vulnerable people. A thoughtful assessment of the inherent tensions published last year concluded “RAD has been overwhelmingly successful at allowing public entities to maintain control of public housing land and facilitating public housing residents’ return to their properties upon conversions,” while urging continued efforts “to enforce RAD’s goal of preserving housing for existing residents without displacing them.”
The Council of Large Public Housing Authorities cites RAD as just one of many strategies that need to scale up to keep America’s public housing in decent condition. As daunting as the price tag appears to be, the ultimate cost of not paying it may be much higher.
Stockton Williams | Executive Director
In This Issue
- NCSHA Supports Improvements to CRA Regs
- Flood, Cleaver Introduce HOME Reform Act
- IRS Corrects 2026 Housing Credit Volume Cap Amounts
- HUD Delays HOME Implementation
- Senate Housing Subcommittee Discusses Ways to Increase Affordable Housing Supply
- Republican Legislators Sign CDFI Fund Support Letter
- NCSHA in the News
- Looking Ahead
NCSHA Supports Improvements to CRA Regs
Restoring and maintaining regulatory certainty is paramount to ensuring the Community Reinvestment Act (CRA) fulfills its critical mission, NCSHA argued in a letter submitted to federal banking regulators Wednesday. The letter was in response to a review the agencies — the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — are conducting of their CRA regulations under the Economic Growth and Regulatory Paperwork Reduction Act. To ensure certainty, NCSHA urged the agencies to finalize a rule they proposed this summer to rescind a 2023 overhaul of the CRA regulations, which is mired in legal challenges, and restore the previous CRA regulatory framework. Such a change also would restore the explicit investment test for large banks, incentivizing bank investments in Housing Credits, Housing Bonds, and other impactful affordable housing initiatives. NCSHA’s letter also asks the agencies to maintain the definition of ‘affordable housing’ included in the 2023 rule and publish a non-exhaustive list of all CRA-eligible activities.
Flood, Cleaver Introduce HOME Reform Act
This week Chairman Mike Flood (R-NE) and Ranking Member Emanuel Cleaver (D-MO) of the Housing and Insurance Subcommittee of the House Financial Services Committee introduced the HOME Reform Act of 2025 (H.R. 5798), bipartisan legislation that would make several significant changes to the HOME Investment Partnerships Program, including to the application of various cross-cutting federal requirements such as Build America, Buy America; Davis-Bacon labor rules; and environmental reviews. This development comes on the heels of the Senate passing the ROAD to Housing Act, which includes HOME reauthorization and reform legislation authored by Senator Catherine Cortez Masto (D-NV). Refer to NCSHA’s blog for details on the proposed changes in the HOME Reform Act.
IRS Corrects 2026 Housing Credit Volume Cap Amounts
The Internal Revenue Service has published an updated version of Revenue Procedure 2025-32 to correct previously released annual allocation amounts for the Low-Income Housing Tax Credit volume cap. The corrected 2026 figures are $3.416 per capita or $3,953,600 for small states. These revised amounts replace earlier, incorrect figures and will establish each state’s Housing Credit ceiling for the 2026 calendar year. State agencies and industry stakeholders should use these corrected numbers for planning and allocation purposes.
HUD Delays HOME Implementation
The U.S. Department of Housing and Urban Development (HUD) issued this week a final rule for the HOME program, further delaying until April 30, 2026, implementation of certain provisions of its January 2025 final rule. Most aspects of the final rule went into effect in April 2025; however, HUD delayed implementation of provisions related to tenant protections and maximum per-unit subsidy amounts. The new rule does not make any program changes but provides additional time for participating jurisdictions and developers to prepare for previously adopted requirements. This extension is intended to facilitate a smoother transition and ensure stakeholders have adequate time to align their systems, policies, and projects with the updated HOME regulations.
Senate Housing Subcommittee Discusses Ways to Increase Affordable Housing Supply
The Senate Housing Subcommittee on Housing, Transportation, and Community Development held a hearing Tuesday to consider new strategies for increasing the supply of affordable housing. In their opening statements, Chairwoman Katie Britt (R-AL) and Ranking Member Tina Smith (D-MN) both voiced strong concern about the lack of available affordable housing and expressed interest in working together to tackle the issue. Witnesses included Dr. Lawrence Powell of the Center for Insurance and Research at the University of Alabama School of Business, Dennis Shea of the Bipartisan Policy Center, and Mary Tingerthal, former Minnesota Housing commissioner and NCSHA Board member and the founder of Construction Revolution.
The subcommittee members and witnesses discussed a wide array of policy solutions to address affordable housing supply challenges, including home resiliency improvements to limit damage from disasters, expanding development of modular homes and other manufactured housing, and the role of zoning. All the participants acknowledged multiple approaches would be necessary to overcome the challenges. Tingerthal and Shea advocated for Congress to pass the ROAD to Housing Act. When questioning the witnesses, Senator Catherine Cortez Masto (D-NV) brought up passage of the Affordable Housing Bond Enhancement Act (S. 1511), and specifically its provision to increase the loan limit for Mortgage Revenue Bond home improvement loans, as a step Congress can take to increase the supply of affordable for-sale homes.
Republican Legislators Sign CDFI Fund Support Letter
More than 100 Republican Senators and House members signed a letter sent Thursday to Treasury Secretary Scott Bessent and Office of Management and Budget Director Russell Vought supporting the office of the Community Development Financial Institutions Fund (CDFI Fund) within Treasury and urging them to ensure all statutory responsibilities of the office are implemented. The letter, originated by Senate Finance Committee Chairman Mike Crapo (R-ID) and Representative Young Kim (R-CA), responded to reports all CDFI Fund staff had received reduction-in-force job termination notices and to the administration’s previous proposals to eliminate some CDFI Fund programs.
NCSHA in the News
Mainebiz, 10.22.25, MaineHousing program receives national recognition
Boston Real Estate Times, 10.20.25, MassHousing Receives National Housing Award for Excellence from the National Council of State Housing Agencies
RiverBender.com, 10.19.25, Illinois Housing Development Authority Wins National Awards for Innovative Housing Programs
WBOY, 10.16.25, PHFA Honored with National Council of State Housing Agencies’ Award for Program Excellence
Westlaw Today, 10.15.25, ROAD to Housing Bill clears Senate
Legislative and Regulatory Activities
- October 27 | Comments Due to NCSHA | FHFA Proposed Strategic Plan for 2026–30
- October 27 | Comments Due to NCSHA | FHFA Proposed Affordable Housing Goals for 2026–28
- November 2 | Comments Due | FHFA Proposed Affordable Housing Goals for 2026–28
- November 5 | Comments Due | FHFA Proposed Strategic Plan for 2026–30
NCSHA, State HFA, and Industry Events
- October 27 – 29 | Kansas Housing Conference | Overland Park, KS
- November 5 | NAAHL/CAHL 2025 Policy and Practice Conference | Washington, DC
Stockton Williams will speak at this event. - November 6 | U.S. Chamber of Commerce Housing Summit | Washington, DC
Stockton Williams will speak at this event. - November 12 – 13 | 2025 WHEDA Conference | Madison, WI
Jennifer Schwartz will speak at this event. - November 17 – 19 | AHF Live | Chicago, IL
Jennifer Schwartz will speak at this event. - December 5 | Early-Bird Registration Deadline: NCSHA’s HFA Institute 2026 | Washington, DC
- January 11 – 16 | NCSHA’s HFA Institute 2026 | Washington, DC
