NLIHC Submits National Housing Trust Fund Comments

NLIHC sent formal comments supporting some features of the interim national Housing Trust Fund (HTF) regulations while urging key improvements. HUD published a notice in the Federal Register seeking comments regarding the 2015 interim rule implementing the national Housing Trust Fund (HTF), see Memo, 4/26. In its preamble to the interim rule, HUD stated its intention to open the interim rule for public comment once funding was made available and the grantees gained experience administering the HTF.

In response to HUD’s request for feedback regarding the interim HTF rule, NLIHC urged HUD to:

  • Change the rent HTF-assisted tenants pay to the lesser of 30% of AMI or 30% of the poverty guideline to minimize tenants paying more than 30% or even 50% of their incomes for rent (see comment letter for a detailed explanation
  • Maintain the income-targeting rule requiring 100% of HTF funds be used for households whose incomes are equal to or less than 30% of the area median income or at or less than the federal poverty line (whichever is greater) when there is less than $1 billion for the HTF
  • Increase the affordability period to 50 years from 30 years
  • Maintain the limitation on the use of HTF funds for operating cost assistance (including reserves) to one-third of a state’s annual grant 
  • Modify the definition of operating cost assistance to include other operating costs that match industry standards  
  • Modify HTF guidance to indicate that 90% of a state’s annual HTF allocation must be used for rental housing activities
  • Modify the final HTF rule to establish as threshold requirements, rather than factors subject to a point system when states set priorities for awarding HTF to projects: an applicant’s ability to obligate HTF funds and undertake eligible activities in a timely manner, and the extent to which an application makes use of other funding sources
  • Adopt many of the technical changes suggested by the Technical Assistance Collaborative to better serve people with disabilities

NLIHC’s comment letter is at:

The Federal Register notice is at:

More information about the national Housing Trust Fund is on page 3-1 of NLIHC’s 2021 Advocates’ Guide