Although SAHF and its members share HUD’s sense that the inspection model could be improved to better reflect the true operating condition of properties, we believe that improvements will better achieved by aligning inspection criteria with HUD’s expectations for housing quality and using existing enforcement tools to address bad actors than by broadly implement rigid inspection timelines on the full portfolio.
The Department of Homeland Security's proposed changes to the "public charge" assessment would penalize noncitizens who utilize housing assistance programs and would undermine the effectiveness of the critical investments SAHF members make in their residents.
SAHF comments state that efforts to modernize CRA should seek to provide clarity and predictability in the evaluation process, but in doing so must also prioritize meeting the needs of LMI people and communities.
As part of its efforts to develop an implement a comprehensive government-wide Federal Data Strategy, Commerce, SBA, and OMB released a draft set of practices for new expectations agencies will have for data governance, management, protection, use, and partnerships.
Over the past four years, SAHF, LISC, NHT, Enterprise, and HPN have strongly supported HUD's efforts in implementing the AFFH rule and its goals. Rather than rework the entire rule, we encourage HUD to solicit feedback from jurisdictions that have completed the process and use that feedback to update the Assessment Tool.