HUD’s Office of Public and Indian Housing (PIH) posted Notice PIH 2022-11 inviting public housing agencies (PHAs) to apply to a new Moving to Work Demonstration (MTW) cohort that will experiment with policies and practices that help residents build financial assets and/or build credit. For the purpose of this new MTW “Asset Building Cohort” (Cohort #4), “asset building” refers to activities that encourage the growth of assisted residents’ savings accounts and/or that aim to build credit for assisted households. PHAs interested in participating in this cohort must submit applications by July 28. PIH will hold an informational webinar about the cohort on May 24.
PIH is offering three asset building options for PHAs that want to participate in the Asset Building Cohort:
- Opt-Out Savings Account Option. A PHA must deposit at least $10 per month for at least one year into an escrow account for the benefit of assisted households (either public housing or Housing Choice Voucher (HCV) households) with the goal of increasing the number of households that have bank accounts, thereby strengthening household stability.
- Credit Building Option. A PHA must report public housing rent payments for at least one year, for residents who given their informed consent, to credit bureaus. The goal is to increase the credit scores of public housing households. A household may withdraw at any time. (This option is not available for HCV households, probably because of the difficulty of having individual landlords report to credit bureaus.)
- PHA-Designed Asset Building Option. This option allows a PHA to design its own local asset building program that encourages the growth of savings accounts and/or aims to build credit for assisted households.
A PHA can choose to implement both the Opt-Out Savings Account and the Credit Building options. If it chooses to do so, PIH suggests it submit an MTW application under the third, “PHA-Designated Asset Building Option.” More details about the options are presented in NLIHC’s “Summary of the Key Features of the MTW Asset Building Cohort.”
An email to stakeholders indicates that PIH anticipates adding 30 PHAs to the Asset Building Cohort: 19 PHAs with at least 1,000 combined units of public housing and HCVs, plus 11 PHAs with between 1,001 and 6,000 combined units of public housing and HCVs.
In short, under MTW, HUD can waive nearly all provisions of the “United States Housing Act of 1937” and the accompanying regulations, including most of the main rules and standards governing HCVs and public housing. MTW agencies are also allowed to shift public housing Capital and Operating Funds and HCV assistance (including Administrative Fees as well as Housing Assistance Payment [HAP]) to purposes other than those for which they were originally appropriated (referred to as “fungibility”). More information about the MTW Demonstration expansion can be found in NLIHC’s “Summary of the Key Features of the MTW Asset Building Cohort.”
Required Public Participation Process
There must be a public participation process that includes publishing a notice that a hearing will be held regarding a full Asset Building Cohort MTW Plan and application package. That hearing is to discuss the Asset Building Cohort MTW Plan and Asset Building Initiatives Information and to invite public comment. A draft MTW Plan and Asset Building Initiatives Information must be available for public inspection for at least 30 days before submission to HUD. A PHA’s Board of Commissioners must approve the MTW Plan and application package by resolution no fewer than 15 days after the public hearing.
An MTW Plan should discuss how a PHA plans to continue to engage assisted households in the implementation and development of its Asset Building Cohort MTW program. A PHA should describe any planned engagement efforts, including any outreach to racial and ethnic minorities, persons with limited English proficiency, persons with disabilities, families with children, and groups representing such persons.
NLIHC has posed several questions and offered a number of suggestions to PIH that could improve protections for residents.
Read Notice PIH 2022-11 at: https://bit.ly/3vGL4vC
Read NLIHC’s “Summary of the Key Features of the MTW Asset Building Cohort” at: https://bit.ly/3vnSS6A
Find more information about the MTW expansion on NLHC’s public housing webpage, https://bit.ly/3rVoezs and on page 4-63 of NLHC’s 2022 Advocates’ Guide.
Visit PIH’s MTW Expansion website at: https://bit.ly/3vGMMNy