- The Government Accountability Office (GAO) has released a report, Affordable Rental Housing, which points out that there are initiatives on the state, local and federal level which address this issue, however they are not always well coordinated, often overlap, and there is “incomplete information to assess performance.” Without sufficient information, the GAO argues it is impossible for Congress or other agencies to set appropriate spending priorities and assess performance. GOA’s recommendation is for the U.S. Department of Housing and Urban Development to work with state and local entities to develop a coordinated assessment and reporting structure.
- Also from the GAO, Pay for Success: Collaboration Among Federal Agencies Would be Helpful as Governments Explore New Financing Mechanisms is a report which describes Social Impact Bonds (SIBs). SIBs are a mechanism by which investors pay for social outcomes and receive an agreed upon return based on the success of the program or as GAO put it, “contracting for social outcomes.” According to the GAO SIBs can be useful in reducing the cost of providing social services while improving success. While the use of SIBs has been limited so far the Office of Management and Budget has been encouraging Federal Agencies to test their potential effectiveness. This GAO report analyzes SIBs that have already been piloted, for example the Department of Labor awarded $24 Million in grants in 2013 to reduce recidivism in New York and Massachusetts. One fear is that SIBs could create perverse incentives. SIBs could eventually be used to finance affordable housing development.
Tag Archives: affordable housing development
Tuesday’s Regulatory & Legislative Round-Up
- The U.S. Department of Housing and Urban Development (HUD) held a policy conference to commemorate the 50 year anniversary of the Fair Housing Act. Among the conference materials is a report from the Government Accountability Office (GAO) which states the the Internal Revenue Service’s (IRS) oversight over compliance with the Low Income Housing Tax Credit Program (LIHTC) has been lax and proposes joint IRS/HUD oversight. The NMTC has been used to create affordable housing through Housing finance Agencies (HFAs). According to the GAO report the IRS has only conducted seven audits of the 56 HFA since 1986. The GAO report states, “Joint administration with HUD could better align program responsibilities with each agency’s mission and more efficiently address existing oversight challenges.”
- The U.S. Treasury has awarded awarded $202 million dollars to 195 Community Development Financial Institutions (CDFIs) through the Community Development Financial Institutions Fund (CDFI Fund). The CDFI Fund was established in 1994 to provide capital and access to credit in underserved communities through CDFIs. CDFIs are mission driven financial institutions which work on the local level to revitalize neighborhoods and create economic change. The CDFI Program invests in and builds the capacity of community credit unions, banks, loan funds, and other financial institutions serving rural and urban communities.
- The Seattle Mayor has proposed new legislation to build 6,000 new affordable housing units. The proposal has been dubbed a “grand bargain” between affordable housing advocates and real estate developers. This grand bargain will require all new development in Seattle pay for affordable housing creation.
- Not to be outdone, the Mayor of Denver has also been mulling over a policy (mentioned in his inaugural address) which would tax new development and also raise the property taxes. Both Seattle and Denver are reacting to a situation in which lower paid professionals including teachers, restaurant and healthcare workers are increasingly difficult to attract and recruit because they are unable to find housing they can afford.
Tuesday’s Regulatory & Legislative Round-Up
- The Consumer Financial Protection Bureau recently released a compliance bulletin regarding Amendment to the Interstate Land Sales Full Disclosure Act. The bulletin provides information to interested parties, primarily developers, regarding the extension of exemption from registration and disclosure requirements of the sale of a condiminium, which is not exempt under other provisions.
- The Federal Transportation Administration (FTA) has released Final Interim Guidance regarding its Capital Investment Grant Program. This guidance provides a greater level of detail with respect to the methods of evaluation used in funding decisions. According to Enterprise Community Partners, “…the incorporation of affordable housing criteria in the evaluation framework has been effective in promoting such coordination. The revised guidance reaffirms those elements and makes two minor adjustments to the affordable housing portion of the land use rating criteria: project sponsors will now have more flexibility in certifying affordable housing data, and transit projects reaching counties with more affordable housing will receive a scoring bonus.”
Tuesday’s Regulatory & Legislative Update
- The Federal Housing Administration (FHA) released a final notice, The Small Buildings Risk Sharing Initiative invites private sector lenders to partner with the FHA to provide long term fixed rate capital to small building owners with mortgages of $3 – 5 million. Lending under this initiative will be limited to properties which are willing to meet affordability requirements. The FHA will guarantee 50% of the mortgages. The FHA is also pursing a change to Section 542(b) of the Housing and Community Development Act of 1992 to allow SBRSI lenders to access capital through Ginnie Mae and to authorize securitization of the loans. In the mean time lenders can access low interest long term capital through the U.S. Treasury’s Federal Financing Bank.
- The Mayor of Seattle has released an Action Plan to address the affordability crisis in that city, where 15-20% of the population is severely rent burdened and minorities are disproportionately impacted. The Mayor’s goal is to create 50,000 units over the next 10 years.
- The U.S. Department of the Treasury has proposed a rule which, “provides for the enforcement of Title VI of the Civil Rights Act of 1964…to that end no person in the United States shall on the grounds of race, color, or national origin be denied participation in, be denied benefits of, or be otherwise subjected to discrimination under any program or activity that receives Federal financial assistance from the Department of the Treasury.” The rule, open for comment until September 11, provides guidance to recipients and provisions for “consistent and appropriate enforcement.” The proposed ruled covers 12 programs including the Community Developments Financial Institutions Fund (CDFI).
