Major Action Items Since 2004
I. Contact congressional representatives and urge their support for adequate funding for the Section 8 Voucher Program in the FY 05 VA-HUD appropriations bill, and urge them NOT to approve the proposed Flexible Voucher Program.
NAHMA signed onto an industry letter supporting provisions in the FY 05 VA-HUD appropriations bill that will ensure adequate funding for the Section 8 voucher program. Click here for a copy of the industry letter. Also, for your convenience, we have modified the letter for members to use as well. NAHMA recommends that members send this letter (via fax or e-mail) to their members of Congress, as well as a copy to Mr. Joshua Bolten, Director of the Office of Management and Budget. Click here for the draft text in support of Section 8 funds.
Contact information for Mr. Bolten is: The Honorable Joshua Bolten, Director, The Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503; 202-395-3888 (fax).
Information on how to contact your senators and representatives is explained above in the introduction to the Grassroots Action Center.
II. Contact HUD and urge the agency not to implement the FY 2005 Fair Market Rents (FMRs) until comments are considered and data is complete.
HUD is accepting comments on its FY 2005 FMRs until November 8. NAHMA encourages members to submit comments urging the Department to postpone implementation of the FMRs in order to allow full consideration of comments and additional rent data. Specifically, we recommend that members submit comments (before October 1 if possible) requesting that HUD continue to use the current FMRs in your area until comments can be fully considered.
The National Low Income Housing Coalition has prepared a summary of deadlines and procedures for submitting comments on the FMRs at http://www.nlihc.org/2005fmrs/comment.htm.
Consensus industry comments, which NAHMA signed onto, can be viewed at http://www.nlihc.org/2005fmrs/comments.pdf.
Additional resources provided by the Center on Budget and Policy Priorities (CBPP) and the NLIHC include:
To find out how the proposed FMRs could affect your area, see http://www.nlihc.org/2005fmrs/data.htm and http://www.cbpp.org/fmr.htm.
For a list of the 70 regions where HUD has contracted for rent surveys, see http://www.cbpp.org/fmr2a.pdf. Results from these surveys will probably not be available until too late to be used for Oct. 1 FMR changes. If you are in one of these areas, point this out to HUD and to your Congressional delegation as a reason why delay is necessary to set the FMRs accurately.
In some areas, public housing agencies will have to redetermine the “rent reasonableness” of each unit starting December 1. Some 860 of these counties are not scheduled for a HUD-funded rent survey. A list of these counties is at http://www.cbpp.org/fmr1c.pdf. Comments from these areas may include updated rent data that would make FMRs more accurate. To allow such comments to be considered, HUD needs to delay implementation of the FMRs until later in the year.
A list of the 682 counties where the proposed decrease in the FMR is so large that PHAs are likely to have to reduce the current maximum voucher payment is at http://www.cbpp.org/fmra.pdf. Some 587 of these counties are not scheduled for a HUD-funded rent survey. A list of these counties is at http://www.cbpp.org/fmr1b.pdf. Comments from these areas may include updated rent data that would make FMRs more accurate. To allow such comments to be considered, HUD needs to delay implementation of the FMRs until later in the year.
Click here to view and download a copy of the letter.
III. Contact the Federal Deposit Insurance Corporation (FDIC) and urge the agency to not implement its proposed rule to greatly increase the asset threshold for the Community Reinvestment Act (CRA).
The Community Reinvestment Act is a very important source for community development loans, investments and services that benefit low- and moderate-income persons. Recently, two of the four federal agencies that regulate financial institutions covered by the CRA, the Office of Thrift Supervision (OTS) and the FDIC, have issued or proposed rules that would relieve an estimated 2,000 insured depository institutions of half their current CRA responsibilities.
On Aug. 18, the OTS published a final rule that increased its CRA threshold for thrift institutions from $250 million in assets to $1 billion in assets. On Aug. 20, the FDIC issued a proposed rule to offer “streamlined” testing under the CRA to institutions up to $1 billion in assets.
As noted by the National Association of Affordable Housing Lenders, which represents the nation's leaders in lending and investing private capital in low- and moderate-income (LMI) communities, the FDIC's proposed rule will harm affordable housing and community and economic development in LMI communities, particularly in rural areas. "With government subsidies drying up, now is not the time to eliminate regulatory incentives for private capital to leverage scarce subsidy dollars," NAAHL said.
NAHMA has signed onto industry letters to the FDIC in opposition to its proposed rule, and will also be contacting the FDIC directly. In addition NAHMA urges members to sign onto the industry letter (on behalf of your company), or send a letter directly to the FDIC urging the agency not to implement its proposed rule. Additional background information is provided below. Please feel free to use the material provided here as a model for your letter. Please note that the FDIC comment period deadline is Oct. 20, 2004.
Click here to view an industry letter and other background information provided by NAAHL.
Click here to view a white paper distributed by Recapitalization Advisors, Inc.
IV. Contact Congressional Representatives about HUD’s interpretation of the
FY 04 Section 8 Housing Choice Voucher Renewal Formula, which puts families at risk. Urge your representatives to support legislation introduced by Rep. Barney Frank (D-MA).
HUD's interpretation of the Section 8 voucher renewal formula established in the 2004 appropriations bill threatens to short-change the program and cause families to lose their assistance. HUD's interpretation limits per unit adjustments to the number of vouchers under lease at August 1, 2003, adjusted for inflation. NAHMA and other industry partners believe the appropriations language provides for a renewal formula which bases per unit costs on the most recently available Public Housing Authority (PHA) data.
NAHMA urges members to contact their senators and congressmen about this important issue. Ask your congressional delegation to urge HUD to reconsider its overly-restrictive interpretation of the voucher renewal formula. Also, please urge your representatives to co-sponsor or otherwise support legislation to address this issue which was introduced by Rep. Barney Frank (D-MA). Please feel free to use the letters below as a model and/or attachments for your correspondence.
Click here to view and download a Word file of the letter concerning the voucher renewal formula.
Click here to view legislation introduced by Rep. Barney Frank (D-MA).
Click here to view the "Dear Colleague" letter circulated by Rep. Barney Frank urging co-sponsors to his proposed legislation.
Click here to view the Industry Coalition Letter to members of the House of Representatives urging cosponsorship of Rep. Frank’s bill, HR 4263.
V. Contact congressional representatives on the FY 05 HUD budget:
1) NAHMA Member Letter to Congressional Leaders
Click here to view and download a Word file of the letter.
2) Industry Letter to Key Appropriators opposing Section 8 cuts and the proposed “Flexible Voucher Program”
Click here to view and download a Word file of the letter.
NAHMA spearheaded an effort to unite affordable housing owners, management agents, tenant groups,
and public housing agency officials in speaking out against Section 8 budget cuts and questionable programmatic changes. NAHMA drafted and sent identical letters to VA-HUD Appropriations Subcommittee Chairman and Ranking Members--namely Senator Kit Bond (R-MO), Barabara Mikulski
(D-MD), Rep. James Walsh (R-NY) and Rep. Alan Mollohan (D-WV).
VI. Items Regarding LEP
Click here to download the executive summary
Click here to download talking points
Click here to download the draft letter to HUD
Click here to download the NAHMAnalysis on the proposed draft Guidance
VII. LIHTC Full-Time Student Occupancy Correction: Ask Your Senators to Cosponsor S 3941
Senator Rick Santorum (R-PA) has introduced legislation (S 3941) which makes common-sense corrections to the Low Income Housing Tax Credit (LIHTC) occupancy rules for full-time student households. NAHMA led an industry coalition in requesting the three specific changes authorized in this bill. First, S 3941 specifies that minor children in grades K-12 should not count toward the determination of who is a full time student household. Likewise, it strikes the requirement that a single parent and their children must not have been claimed as dependents of another individual to qualify for the single parent with children exemption. Finally, it adds a new exemption for working adults who are full-time students pursing a high school diploma or GED. NAHMA strongly supports this legislation, and we highly encourage members to discuss the need for these important changes with their elected officials.
Click here to read S 3941 as introduced on September 26, 2006
Click here to read Senator Santorum’s statement on the bill (from the Congressional Record, Sept. 26, 2006, pages S 10189 to S 10190)
Click here to read the letter signed by industry trade groups requesting these changes
Click here to see LIHTC related links
Arranging a Congressional Visit
With NAHMA's March Membership Meeting just around the corner, members can take advantage of being in D.C. by scheduling an appointment with their Representative or Senators.
NAHMA has provided a model letter to help in this process. NAHMA is more than willing to help you in deciding what times are best to visit Capitol Hill, who you would like to meet with, and how to best present your message. If you would like NAHMA to schedule the appointment on your behalf, simply fill out this letter and return it to Frank Scardena. Alternatively, if you would like to meet with a member of Congress and it is more convenient to schedule a visit in your Representative's District, please contact us so that we may provide any additional assistance.
NAHMA has also provided our members with talking points for these Congressional visits. You may also use our Bill Summary for the 110th Congress to discuss specific pieces of legislation with Capitol Hill staff.
ADVOCACY UPDATES:
1) Funding for Seniors' Housing Programs
NAHMA signed on to an Elderly Housing Coalition letter in support of adequate funding for various seniors' housing programs in Fiscal Year 2004. Select the link below to read the letter.
Elderly Housing Coalition Letter
2) Section 8 Voucher Funding
NAHMA spearheaded an industry effort to advocate for Section 8 voucher funding. Letters sent by NAHMA, signed by seven other industry associations can be viewed below.
Letter to HUD
Letter to Appropriators
