HUD’s Office of Community Planning and Development (CPD) issued Notice CPD-17-5 providing guidance to states for submitting FY17 national Housing Trust Fund (HTF) Allocation Plans. States must submit their HTF Allocation Plans along with their Consolidated Plan FY17 Annual Action Plans. Consolidated Plan regulations have always required submission of Annual Action Plans by August 16. States that have already prepared FY17 Action Plans will need to amend them by August 16 in order to include an HTF Allocation Plan. As previously reported, HUD has shortened the required public comment period to 14 days due to Congress’s delay in enacting the FY17 appropriations act (see Memo, 5/30).
NLIHC has learned that HTF allocation amounts to states will be announced concurrently with the announcement of other CPD formula program amounts, which include the Community Development Block Grant, HOME Investment Partnerships, Emergency Solutions Grants, and Housing Opportunities for Persons with AIDS programs.
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 applications from potential recipients. The statute requires that 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 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.
Notice CPD-2017-5 refers to the components of eCon Planning Suite screens in IDIS, CPD’s management information system. However, the eCon Planning Suite still does not have all of the required HTF Allocation Plan data fields and enhancements; consequently, states will also have to submit their HTF Allocation Plans by email to both their respective CPD Field Office Director and HUD Headquarters.
Separately, HUD published the FY17 HTF income limits and rent limits. NLIHC continues to object to the HUD’s interim rule establishing maximum rents that may be charged to extremely low income renter households at the greater of 30% of the federal poverty guideline or 30% of 30% of the area median income (AMI). There is no basis for this in the HTF statute. Because the federal poverty guideline is higher than 30% of AMI for households of two or more people in 92% of all counties, HTF rents could be unaffordable for most extremely low income households, the very population for whom the HTF was created to serve. NLIHC has urged HUD to change the maximum rent to the “lesser of” 30% of the federal poverty guideline or 30% of 30% AMI.
Notice CPD-2017-5 is at: http://bit.ly/2r2UByt
The HTF (and HOME) rent and income limits are at: http://bit.ly/2sh2tfu