At its meeting on November 15-16 in Washington, DC, the Board of Directors of NLIHC adopted the Coalition’s 2015- 2016 public policy agenda, reaffirming NLIHC’s commitment to fund the National Housing Trust Fund, to assure sufficient funding for low income housing programs, to preserve and improve public and Section 8 project-based housing, and to advance efforts to affirmatively further fair housing. The Board adopted two new public policy positions, based on the recommendation of the NLIHC Policy Advisory Committee.
First, NLIHC took a position in favor of income averaging in Low Income Housing Tax Credit (LIHTC) properties, which is a variation on the Administration’s income averaging proposals in its FY14 and FY15 budget requests. NLIHC proposes a third income option for developers, which would permit LIHTC units in a property to serve households with an average income of 60%, thereby allowing some units to serve households with incomes up to 80% of area median, if at least 30% of the project’s units serve household with incomes at or below 30% of area median. Under NLIHC’s proposal, such developments would also receive a 30% basis boost.
NLIHC adopted this position based on NLIHC research on LITHC properties serving extremely low income households (ELI), that is, households with incomes at or below 30% of area median. One finding is that some LIHTC properties are able to do so when cross-subsidization is possible. Because the income averaging proposal relies on households at or close to the 80% of area median income level to rent LIHTC units, NLIHC understands that this proposal will be effective only in some high-cost markets.
Second, the board approved a proposal for NLIHC to develop and advance an alternative model for determining Fair Market Rents (FMRs) in rural areas, including analysis of using rent reasonableness, rent comparability studies conducted for other federal or state programs, and the discretion of the HUD Secretary to approve alternatives. The issue of FMRs being out of sync with actual rents in rural areas has been raised by several of NLIHC state coalition partners, who brought it to the attention of the NLIHC Policy Advisory Committee.
The NLIHC Board of Directors adopts a public policy agenda every two years just before the start of a new Congress. The agenda is developed in consultation with the NLIHC Policy Advisory Committee, which is composed of representatives of NLIHC’s diverse membership.
To read the full policy agenda, go to http://nlihc.org/sites/default/files/NLIHC_2015-2016_Policy_Agenda.pdf. To learn more about the new positions, contact Linda Couch, Senior VP for Policy, at email@example.com.