HUD published the official amounts of national Housing Trust Fund (HTF) allocations to states for FY17 in the Federal Register on June 23. Allocations were posted earlier on HUD’s website (see Memo, 6/19). The total amount available for 2017 is $219,168,374, which includes $12,665,449 of sequestered FY16 funds and $37,298 from American Samoa, Guam, and the Commonwealth of Northern Mariana Islands that declined their small FY16 allocations.
HUD also posted the 2017 version of its Housing Trust Fund Allocation Plan Guide, which states may use to submit their 2017 HTF Allocation Plan. States may also use another format if all elements required by the interim HTF rule are included. The sample form covers all the required elements. HTF Allocation Plans must be submitted to the local HUD CPD Field Office and HUD Headquarters by August 16.
The HTF statute and interim rule require states to draft for public comment an annual HTF Allocation Plan that, among other features, indicates how a state will distribute its HTF dollars, explains the requirements that organizational recipients of HTF dollars must meet, and describes the criteria a state will use for selecting grant recipients. The statute requires state Allocation Plans give priority in awarding HTF dollars to projects based on six factors, which should be clearly described:
- The extent to which rents are affordable, especially for extremely low income households (those with income less than 30% of the area median income or less than the federal poverty guideline).
- The length of time that HTF-assisted apartments will remain affordable. (The regulations require HTF-assisted apartments to be affordable for a minimum of 30 years.)
- The merit of a proposed project (such as projects serving people with special needs, projects that have energy-saving or non-polluting features, or projects accessible to transit or employment centers).
- Geographic diversity, as reflected in the state’s Consolidated Plan.
- An applicant organization’s ability to obligate money and carry out projects in a timely fashion.
- The extent to which a proposed project will use non-federal funds.
Because the HTF Allocation Plan is part of the Consolidated Plan (ConPlan), states are required to submit their HTF Allocation Plan as a component of their annual Action Plan and/or long-term ConPlan using HUD’s eCon Planning Suite. However, the eCon Planning Suite still does not contain all the data fields needed to accommodate the HTF Allocation Plan. The sample form and Notice CPD-17-05 (see Memo, 6/12) note that some of the HTF Allocation Plan requirements will be completed in the eCon Planning Suite in IDIS, the management information system used by HUD’s Office of Community Planning and Development (CPD). Portions of an HTF Allocation Plan not required to be submitted with the eCon Planning Suite will be submitted using a Word document or PDF file.
The sample form, which indicates which IDIS screens to complete, is designed for state staff who enter HTF Allocation Plan information into IDIS. It also has a series of questions for which a state can check a box and add text to address HTF elements not yet activated on IDIS. Unfortunately, in 2016 several states simply used the sample form as their draft HTF Allocation Plan presented to the public for comment. Because the first nine pages are devoted to instructing state staff about which IDIS screens to complete, the sample form is not conducive to public understanding of the HTF. NLIHC has expressed this problem to HUD, suggesting that for purposes of the required public comment, states should also provide a simple narrative similar to the Vermont HTF Allocation Plan.
Housing Trust Fund Allocation Plan Guide 2017 is at: http://bit.ly/2rG967Q
The Federal Register notice is at: http://bit.ly/2rJNYxx
NLIHC’s press statement on the publication of HTF allocations is at: http://nlihc.org/press/releases/7981