States Prepare Housing Trust Fund Allocation Plans

Most national Housing Trust Fund (HTF) state administering agencies have made significant progress in preparing their HTF Allocation Plans. The plans are required to receive their first disbursements from HUD later this year.  As of Friday, June 9, three states have finalized their HTF Allocation Plans, 11 states have submitted draft HTF Allocation Plans for public review and comment, and 19 states and the District of Columbia have sought public input about how their HTF funds should be used prior to drafting their HTF Allocation Plans.

The three states that have finalized their Allocation Plans are Arizona, Hawaii and South Dakota. Arizona submitted a final HTF Allocation Plan to HUD on May 15, after a 30-day review and comment period. Hawaii and South Dakota have produced final Allocation Plans, but it is unclear whether the plans have yet been submitted to HUD.

The 11 states that have submitted draft HTF Allocation Plans for public review and comment are Alabama, Connecticut, Florida, Illinois, Michigan, Minnesota, Missouri, New Mexico, North Dakota, Vermont, and West Virginia. These drafts have been or will be available for public review and comment for at least 30 days.

The 19 states in addition to the District of Columbia that have sought public input about how their HTF funds should be used prior to drafting their Allocation Plans are Alaska, Arizona, Delaware, Connecticut, Florida, Georgia, Iowa, Kentucky, Louisiana, Maine, Maryland, New Hampshire, North Dakota, Oregon, South Carolina, Texas, Utah, Virginia, and Wisconsin.

It is important to have public input prior to drafting an HTF Allocation Plan, particularly during this inaugural year, so that state HTF agencies can inform stakeholders about this new, unique program and its targeting of scarce resources to renters who have extremely low incomes, those with income less than 30% of the area median income. The methods of securing public input include round tables, solicitation of written input, and traditional public hearings. A number of NLIHC state coalition partners were informally contacted by the state. In Vermont, the Vermont Affordable Housing Coalition and other advocates were on the committee that drafted the state’s HTF Allocation Plan. Missouri and Tennessee sent surveys to known stakeholders to obtain input prior to drafting the Allocation Plan.

The HTF statute requires states to follow the Consolidated Plan (ConPlan) public participation regulations when conducting public input for the HTF Allocation Plan. The ConPlan regulations require states to submit their Annual Action Plan updates to their ConPlans by August 16 of each year. Because HTF Allocation Plans are required by the interim HTF regulation to be integrated into the Annual Action Plan of a state’s ConPlan, HTF Allocation Plans are also due to HUD by August 16. As with Annual Action Plans, HUD has 45 days to review a state’s HTF Allocation Plan. HUD has indicated that for this initial year, HUD headquarters staff will be reviewing HTF Allocation Plans in addition to HUD field office staff.  

The statute requires the HTF Allocation Plan to describe how a state intends to distribute its HTF funds based on the priority housing needs identified in its ConPlan and to describe the criteria that potential recipients of HTF funds must meet. The statute also requires the HTF Allocation Plan to give priority in awarding HTF funds to potential recipients based on six factors, the most important of which are: the extent to which rent will be affordable, especially for extremely low income households; the length of time HTF-assisted units will remain affordable (a minimum of 30 years as required by the interim HTF rule); and the merit of a project in addressing a state’s priority housing needs.

Much more HTF information is at: