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.
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 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.
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.
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.