SAHF Submits Comments on HOTMA Sections 102-104
11/18/2019
SAHF submitted comments on the implementation of Sections 102-104 of the Housing Opportunity through Modernization Act of 2016 (HOTMA) affecting income calculation and reviews.
Letters & Comments
SAHF Submits Comments on HUD's NSPIRE Demonstration
10/29/2019
SAHF submitted comments on HUD's NSPIRE Demonstratiion
SAHF Submits Comments on HUD's Proposed Rule on Disparate Impact
10/29/2019
SAHF submitted comments on HUH's proposed changes to the disparate impact rule in a letter with Enterprise, Housing Partnership Network (HPN), Local Initiatives Support Corporation (LISC), and National Housing Trust (NHT).
SAHF Submits Comments on HUD's Proposed Rule on Verification of Eligible Status (Non-Citizen Rule)
7/12/2019
SAHF submitted comments on HUD's proposed Non-Citizen Rule which would cause harmful disruption to individuals and communities and imposing unnecessary administrative burdens on owners and operators of HUD-assisted affordable rental housing.
SAHF Submits Comments on HUD Policy in Opportunity Zones
6/25/2019
While supporting the development of Opportunity Zone communities is certainly consistent with HUD’s mission, it is critical that HUD’s efforts to incentivize investment in Opportunity Zones compliment and improve the efficiency and impact of HUD’s work in all communities rather than diverting disproportionate resources to focus on Opportunity Zone communities.
SAHF Submits Comments on Alternative Inflationary Indices Used to Calculate the Official Poverty Measure
6/25/2019
SAHF submitted comments on the Office of Management and Budget’s (OMB) notice regarding the differences among the various consumer price indexes produced by the Bureau of Labor Statistics (BLS) and the Bureau of Economic Analysis (BEA) and how those differences might influence the estimation of the Official Poverty Measure and other income measures produced by the Census Bureau.
SAHF Comments on Information Collection as part of "NSPIRE" Demonstration
6/10/2019
In general, SAHF and its members believe that the annual self-inspection and reporting of code and other compliance are components of sound operations that are appropriately included in a proposed inspection protocol.
SAHF Comments on Recent Changes to REAC Physical Inspections
4/15/2019
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.
SAHF Comments on HUD's Draft Notice Implementing "RAD for PRAC"
3/25/2019
The new regulations will extend HUD's Rental Assistance Demonstration (RAD) to Section 202 Project Rental Assistance Contracts (PRAC) properties, which provide affordable homes to seniors.
SAHF Comments on Proposed Amendments to "Public Charge" Assessment
12/10/2018
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.