March ACTION Newsletter: Legislative and Advocacy Updates

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The ACTION Campaign monthly call will be held on Friday, March 5 at 2:00 PM EST.

ACTION Updates

Legislative and Advocacy Update

ACTION is preparing for the reintroduction of the Affordable Housing Credit Improvement Act (AHCIA), working with our champions on the Hill to finalize the bill text. As soon as the legislation is reintroduced, we will alert our members and mobilize advocacy efforts to rebuild and expand our strong cosponsorship from last Congress. We will also continue to monitor for any potential legislative vehicles that could carry our Housing Credit priorities, including through the budget reconciliation process or an infrastructure package.

IRS to Hold Hearing on Average Income Test

On March 24, the IRS will hold a hearing on its proposed rule to implement the Average Income Test (AIT). The AIT was included as a new minimum set-aside option in the Consolidated Appropriations Act of 2018, and though states have since developed their own policies, the IRS final rule will provide the official regulatory guidance on the AIT’s implementation. The AIT allows owners of Housing Credit projects for which the owner chooses AIT as the project’s minimum set-aside to serve households earning as much as 80 percent of the area median income (AMI), so long as on average qualified low-income units have income designations that are 60 percent or less of the AMI. The IRS’ March 24 hearing will allow stakeholders an opportunity to provide feedback on the proposed rule. Those interested in testifying at the virtual hearing must submit their contact information and an outline of their expected oral comments to by March 5.

ACTION Submits Comments to Federal Reserve on ANPR to Modernize the CRA

On February 16, ACTION co-chairs Enterprise Community Partners and the National Council of State Housing Agencies submitted a comment letter on behalf of the ACTION Campaign to the Federal Reserve Board (Fed) on its advance notice of proposed rulemaking to modernize the Community Reinvestment Act (CRA). The letter highlights the critical role the CRA plays in Housing Credit investment and encourages the Fed to issue a final CRA regulation that facilitates investment in affordable housing through the Housing Credit program. The next step in the process is for the Fed to issue a proposed rule for further comment. ACTION encourages the Fed to work with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation to together issue a joint final CRA rule.

ACTION Membership

The ACTION Campaign is pleased to welcome the following new members, who joined our coalition in February:

  • Norstar Development USA, LP – National

  • Banks & Robertson Consulting Group LLC – Virginia

ACTION is the largest coalition of Housing Credit advocates in the country. Help our coalition continue to grow by inviting your state and local partners to join ACTION.

Housing Credit Research

  • A report by the National Housing Trust and LeadingAge, “Affordable Senior Housing: A Scan of State Housing Credit Allocation Plans” assesses how senior housing development is being prioritized in state Qualified Allocation Plans (QAPs), which is especially critical given the rapid grown in the older adult population in recent years.

  • The Corporation for Supportive Housing (CSH) released a report called, “Leveraging Low-Income Housing Tax Credits to Support Thriving Communities,” which emphasizes how supportive housing – safe, stable affordable housing with quality integrated services – is critical to support thriving communities, especially given the consequences of Covid-19. It underscores the importance of QAPs to support thriving communities through the Housing Credit program.

Housing Credit In the News

Krista D'Alessandro is the senior tax policy analyst at Enterprise Community Partners. The ACTION Campaign is co-chaired by Enterprise and the National Council of State Housing Agencies.

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