The U.S. Department of the Treasury released on March 16 a revised Frequently Asked Questions (FAQ) document regarding its $25 billion emergency rental assistance (ERA) program approved by Congress at the end of 2020. These changes align with recommendations made by NLIHC and the NLIHC-led Disaster Housing Recovery Coalition (DHRC) to ensure critical rent relief resources reach households with the greatest needs (see Memo, 3/8). NLIHC expects Treasury to release further guidance in the coming weeks.
Rental Security Deposits
FAQ 7 has been revised to include rental security deposits as a permissible relocation expense and to clarify that application or screening fees are permissible rental fees, as recommended by NLIHC.
Hotel and Motel Stays
Treasury added FAQ 26 to clarify that rental assistance may be provided to temporarily displaced households living in hotels or motels, as recommended by NLIHC.
According to the revised document, these expenses fall within the category of “other expenses related to housing incurred due, directly or indirectly, to the COVID-19 outbreak,” provided that: the household has been temporarily or permanently displaced from its primary resident or does not have a permanent residence elsewhere; the total months of assistance provided to the household do not exceed 12 months (plus an additional three months if necessary to ensure housing stability); and documentation of the hotel or motel stay is provided and the other applicable requirements provided in the statute and FAQs are met.
The guidance states that the cost of the hotel stay does not include expenses incidental to the charge for the room. Grantees covering the costs of hotel and motel stays must develop policies and procedures outlining under what circumstances they would provide such assistance. The FAQ also states that if a household is eligible for an existing program with narrower eligibility criteria that provides similar assistance for hotel or motel stays, such as HUD’s Emergency Solutions Grant program or FEMA Public Assistance, grantees should use those programs before providing aid under the ERA program.
FAQ 27 states that grantees may provide ERA to households renting their residence under a “rent-to-own” agreement, under which the renter has the option or obligation to purchase the property at the end of the lease time, as long as a member of their household is not a signor or co-signor to the mortgage on the property, does not hold the deed or title to the property, and has not exercised the option to purchase.
FAQ 28 states that rental payments for either a manufactured home and/or the parcel of land a manufactured home occupies are eligible for assistance under the ERA program, as recommended by NLIHC. Households renting manufactured homes and/or the parcel of land may also receive assistance for utilities and other expenses related to housing.
Treasury says it will continue to work with stakeholders to provide additional guidance and technical assistance, and NLIHC will continue to advocate for improvements to ensure ERA reaches the lowest-income and most marginalized renters.
Read Treasury’s new ERA guidance at: https://bit.ly/3ttue0l
Read NLIHC’s letter to Treasury at: https://bit.ly/30RNfgS