NHT Leads PWG in Advocating for Strong Housing Credit Administration
In August 2023, NHT coordinated the efforts of the Preservation Working Group – a national coalition of housing owners, developers, advocates and others dedicated to the preservation of affordable multifamily housing – to weigh in on NCSHA’s proposed updates to the Recommended Practices in Housing Credit Administration. These recommendations, issued by the National Council of State Housing Agencies, serve as critical benchmarks for the 50-plus housing finance agencies across the US that administer the Low-Income Housing Tax Credits (Housing Credits). The 2023 set, expected to be released in their final form later this month, will mark the first update to the recommended practices since 2017, and represent a critical moment for housing finance agencies to establish baseline standards to drive more equitable and resilient affordable housing financed with Housing Credits.
PWG members coalesced around a shared set of recommendations to NCSHA that both supports and seeks further action by agencies to preserve properties, bolster tenant protections, strengthen the nonprofit right of first refusal, and address climate risks. In particular, the seven PWG signatory organizations encouraged NCSHA to consider the following as they finalize their recommended practices for Housing Credit administration:
- Encourage greater funding for third-party Capital Needs Assessment for properties approaching Year 30 in order to more accurately assess the physical and financial condition of existing properties and foster more sound asset management.
- Extend tenant protection policies to both new and existing properties and enforce them through sanctions for noncompliance.
- Retain the strong proposed language related to Qualified Contracts, which encourages Agencies to “consider developing strategies and identifying financial tools to actively assist developers in the acquisition and preservation of projects that have submitted qualified contract requests.”
- Clarify and strengthen proposed language to support the nonprofit Right of First Refusal, in particular to address efforts by aggregators (those who seek to challenge the transfer of property with the explicit intent of maximizing profit).
- Consider energy performance investments and their ability to respond to environmental or climate hazards as an important pathway for owners to bolster operating and replacement reserves for Housing Credit properties.
The full PWG comments, endorsed by NHT and six peer organizations – Leaders and Organizers for Tenant Empowerment, LeadingAge, National Housing Law Project, National Low Income Housing Coalition, Network for Oregon Affordable Housing, and Preservation of Affordable Housing – can be seen here.
NHT serves as the secretariat for the Preservation Working Group, convening regularly to discuss matters prevalent to or emerging within the affordable housing industry which threaten the preservation of existing units. PWG members act collectively on issues of importance to the industry and align efforts to speak with a singular voice to key decision makers. Learn more about the Preservation Working Group here.
NHT and the Preservation Working Group applaud NCSHA’s work supporting HFAs with the strongest possible set of Recommended Practices to inform the administration of Housing Credits. As the primary source of funding for increasing and preserving the nation’s supply of affordable rental homes, it is critical that Housing Credits are administered to most effectively combat the greatest threats to affordable housing. We look forward to seeing the final Recommended Practices when they are released later this month and will continue to support allocating agencies as they administer and allocate Housing Credits to create, preserve, and improve affordable housing.
Senior Director of Housing Policy