NLIHC responded to HUD’s Office of Policy Development and Research (PD&R) request for public comments on its five to ten year research agenda.
HUD’s goal for rental housing is to “meet the need for quality affordable rental homes.” This topic area covers issues related to preserving affordability, improving the quality of rental units and expanding the range of rental homes and neighborhoods available to families. NLIHC recommended that HUD create an integrated, comprehensive address-level database of all federally assisted rental housing units. In order to preserve affordable housing, it is critical that advocates first know how many properties and units are in existence and what subsidies are attached to them. NLIHC encouraged HUD to at least create a unique identifier across all existing datasets to allow for an easier integration of the many databases that are already publicly available.
NLIHC recommends that HUD undertake an analysis of the factors that lead to a multifamily property becoming “troubled” or “at-risk.” HUD recently started using a new data system that includes information on the financial and physical status of each assisted property. This will be used as an early-warning system that will allow HUD field staff to direct services and resources to those properties at the greatest risk of physical or financial failure. This system provides HUD with a wealth of new information on its assisted stock, which should be analyzed carefully in order to better evaluate the factors that lead to a property’s decline. NLIHC suggests that a list of troubled properties be made available to the public so that nonprofit developers and tenant organizing groups might work with HUD and the owners to improve these properties and preserve their affordability.
In addition, NLIHC recommends that HUD to look into the cost effectiveness of the regional administration of vouchers. HUD should encourage regional voucher programs and institute metrics for evaluating the cost effectiveness of this approach.
Finally, NLIHC suggests that HUD conduct more research on the effects of the foreclosure crisis on renters. HUD should use the data it has on properties with FHA-insured mortgages to complete a comprehensive study of the number of renters affected by the foreclosure crisis and the outcomes for those renters after foreclosure. NLIHC also urges HUD to analyze the enforcement of the Protecting Tenants at Foreclosure Act (PTFA).
NLIHC’s comments were submitted online on November 4 and were sent in a letter to HUD Assistant Secretary for Policy Development and Research Raphael Bostic. The letter can be read at: http://www.nlihc.org/doc/PDR_Research_Agenda_Comments_Ltr_11-4-11.pdf