National Housing Trust Fund Implementation Update
The National Housing Trust Fund (NHTF) Allocation Plan guidance from HUD was posted as Notice CPD-16-07 on April 28. It is available at: http://bit.ly/1TgNxjU
Several states are advancing their process for developing the required Allocation Plan to receive National Housing Trust Fund allocations. The National Low Income Housing Coalition is encouraging all state affordable housing and homeless coalitions to engage in this process. The seven-page Notice primarily restates the interim regulations, with a few exceptions as outlined by the National Low Income Housing Coalition in its May 2 Memo to Members and is available on its website: http://www.nlihc.org/library/memos/20160502 Prior to releasing Notice CPD-16-07, HUD conducted a webinar for state NHTF grantees. A recording of the webinar and accompanying slides are at http://bit.ly/24pK4qZ
State Designated Administrative Entities: The statute creating the NHTF requires that each state, the District of Columbia, and Puerto Rico select a state entity, such as a housing finance agency or housing department, to receive NHTF money and administer the state’s NHTF program. All states have done so and they are listed on HUD’s list of state designated NHTF entities at: http://bit.ly/1Govcho
Allocation Plans: The statute also requires that these designated entities draft a NHTF Allocation Plan, notify the public about it and provide for public comment – all following Consolidated Plan (ConPlan) public participation regulations. The statute requires states to give priority in awarding NHTF money to applicant organizations based on six factors. For states that have already submitted their ConPlan Annual Action Plan, Notice CPD-16-07 indicates that those states must submit their NHTF Allocation Plan as an amendment to the state’s ConPlan Annual Action plan no later than August 16. Advocates need to monitor their state’s compliance with this long-standing ConPlan regulation as it affects not only the NHTF but other federal, state, and local resources. States must follow the public participation process detailed in the Consolidated Plan regulations, which include a minimum 30-day review and comment period. HUD has 45 days to review Allocation Plans. Summer is when HUD Secretary Castro has projected the NHTF money will begin to be distributed.
Expected NHTF Allocation Amounts: The allocation amounts going to each state is expected to be published in the Federal Register by HUD soon. Estimates, based on the projected revenue, are available on the NLIHC website: http://www.nlihc.org/issues/nhtf.
Resources: There are several resources available from NLIHC which advocates are encouraged to take advantage of. These include:
- A NLIHC webinar is available on the implementation of the National Housing Trust Fund. Please contact: Ed Gramlich at NLIHC ed@nlihc.org
- A model allocation plan, available here: http://www.nlihc.org/sites/default/files/NHTF_Model-Allocation-Plan.pdf
States taking advantage of the webinar have commented that it provides a unique opportunity to engage other stakeholders that can partner in the effective implementation of the funds.
- Developer Advisory Group. NLIHC has formed a Developer Advisory Group of non-profit developers from around the county with experience and expertise in developing and operating rental housing that extremely low income households can afford. The members of this group will serve as a resource to potential NHTF grant recipients, as well as state housing coalition advocates, and state officials involved in NHTF planning and implementation. More information is available here: http://www.nlihc.org/sites/default/files/NHTF_Developer-Resources.pdf
