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NAHMA HUD Update: PIH Updates on Guidance for Shared Waiting Lists; Initial Guidance for Small PHAs on Prop. Inspections & Environmental Reviews; Guidelines for Subsidy Layering Review for PBVs

Recently issued guidance from HUD's Office of Public and Indian Housing (PIH).

Please find below, recently issued guidance from HUD's Office of Public and Indian Housing (PIH):
 
1. Shared Waiting Lists: In late February, PIH published guidance regarding how to facilitate the voluntary use of shared waiting lists among public housing agencies (PHAs) and owners of multifamily properties that receive assistance from HUD. As provided in the notice, this notice was issued to ensure HUD complies with Section 209(e) of the Economic Growth, Regulatory Relief and Consumer Protection Act of 2018, Pub. L. No. 115-174, by providing guidance regarding how to facilitate the voluntary use of shared waiting lists among public housing agencies (PHAs) and owners of multifamily properties that receive assistance from HUD. This notice also describes and responds to public comments received in response to the Federal Register notice entitled “Section 209 of the Economic Growth, Regulatory Relief, and Consumer Protection Act: Initial Guidance” (84 FR 4097). Because of differences in the way that PHAs and owners of HUD-assisted multifamily properties operate, this notice focuses on shared waiting list software and common application for PHAs.
 
The guidance can be found HERE.
 
2. Small PHAs Physical Inspections and Environmental Reviews: This notices was issued in late February.  As provided in the summary of the notice,  Section 209 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the ‘‘Economic Growth Act'') added section 38 to the United States Housing Act of 1937 and makes several amendments pertaining to small public housing agencies (PHAs). This notice explains how HUD designates small PHAs and implements section 209 provisions that reduce regulatory burden on small PHAs by reducing the number of inspections required for units with section 8(o) voucher assistance, and providing an exemption from environmental review requirements for development and modernization projects that have a total cost of not more than $100,000. This notice also identifies the small PHAs that are eligible for this section 209 regulatory relief.

The guidance can be found HERE.
 
3. SLR for PBVs: HUD has issued guidelines and requirements for Project-Based Voucher (PBV) Subsidy Layering Reviews (SLRs). This includes new PBV Housing Assistance Payments (HAP) contract terms provisions, as amended by the Housing Opportunity Through Modernization Act of 2016 (HOTMA) and SLR requirements for Mixed-Finance projects that may or may not include PBV assistance.
 
The guidelines can be found HERE.
 

Michal Machnowski
Manager, Government Affairs
National Affordable Housing Management Association
400 N. Columbus St., Suite 203
Alexandria, VA 22314
703-683-8630 (ext 116)
703-683-8634 (fax)
mmachnowski@nahma.org
NAHMA is the leading voice for affordable housing management, advocating on behalf of multifamily property managers and owners whose mission is to provide quality affordable housing.

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