The COVID-19 pandemic and economic downturn is threatening the housing stability of millions of low-income Americans. While the ACTION Campaign remains committed to advancing the Affordable Housing Credit Improvement Act, we also have to be rapidly adaptive and responsive to the new challenges we face. The ACTION Campaign is advocating for critical Low-Income Housing Tax Credit (Housing Credit) statutory and regulatory measures in response to the COVID-19 crisis.
Questions or Comments? Please email Krista D’Alessandro at kdalessandro@enterprisecommunity.org.
Legislative Advocacy
The ACTION Campaign urges Congress to include provisions that support the Housing Credit in the next COVID-19 response package.
For emergency relief:
Enact a minimum 4 percent Housing Credit rate for buildings placed in service after January 20, 2020 (per the COVID-19 “incident period” for states per FEMA).
Allow developments to access 4 percent Housing Credits by lowering the “50 percent test” to 25 percent (for buildings placed in service after January 20, 2020).
For economic recovery:
Increase the annual Housing Credit allocation by 50 percent, phased in over two years at 25 percent per year, and adjusted for inflation, beginning in 2021.
Provide additional basis boosts for vulnerable properties impacted by COVID-19, including Housing Bond-financed properties that have felt the financing crisis most acutely, developments serving extremely low-income tenants, and properties in rural area and Native American communities.
For regulatory relief:
Extend key Housing Credit deadlines to continue progress on affordable housing development, including: rehabilitation expenditure deadlines, 10 percent test deadlines, and placed in service deadlines.
Advocacy Resources:
To view the detailed list of ACTION’s proposals, click here.
To read a December 10 ACTION Campaign Steering Committee letter to Congress with recommendations related to the Housing Credit for COVID-19 relief in any year-end tax legislation, click here.
To read a July 31 bipartisan, sign-on letter led by Affordable Housing Credit Improvement Act (AHCIA), H.R. 3077, co-leads Representatives Suzan DelBene (D-WA-01) and Jackie Walorski (R-IN-02) and signed by 103 Representatives urging House leadership to include Housing Credit priorities in the next COVID-19 response package, click here.
To view the June 1 sign-on letter with 69 mayors urging Congress to include ACTION’s Housing Credit proposals in the next COVID-19 response package, click here.
To view the May 6 ACTION sign-on letter with 2,354 organizations urging Congress to include our Housing Credit proposals in the next COVID-19 response package, click here.
To read an April 16 letter from AHCIA lead sponsors Representatives Suzan DelBene (D-WA), Kenny Marchant (R-TX), Don Beyer (D-VA), and Jackie Walorski (R-IN) to House Speaker Nancy Pelosi (D-CA) and Leader Kevin McCarthy (R-CA) calling for key Housing Credit priorities for COVID-19 relief legislation, click here
To view an AHTCC fact sheet on how a 4 percent Housing Credit rate would provide Emergency Relief for Affordable Housing, click here.
To view ACTION’s new 4 percent Housing Credit fact sheets updated May 26, click here.
Legislative Updates:
The Economic Justice Act. On July 16, Senate Democrats released The Economic Justice Act, a proposal to invest $350 billion in communities of color as a part of the next Covid-19 relief package. The proposal is intended to further buttress House Democrats’ HEROES Act. The proposal includes the expansion of the Housing Credit by $5 billion for setting a minimum 4 percent rate for bond-financed Housing Credit properties, which would expand Housing Credit production by an estimated 126,000 units over ten years. To read a summary of the proposal, click here.
The Moving Forward Act. On July 1, the House passed its infrastructure package, The Moving Forward Act, H.R. 2, which includes an expansive section to strengthen and expand the Housing Credit. To read more about The Moving Forward Act, click here.
The Emergency Affordable Housing Act of 2020. On June 25, Senate Finance Committee Ranking Member Ron Wyden (D-OR) and Senator Maria Cantwell (D-WA) introduced standalone Senate companion legislation to the Housing Credit provisions included in The Moving Forward Act called The Emergency Affordable Housing Act of 2020, S.4078. Like The Moving Forward Act, the legislation includes all of ACTION’s legislative priorities for Covid-19 relief. To read more about The Emergency Affordable Housing Act of 2020, click here.
The HEROES Act. On May 13, House Democrats released the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act), which would provide additional funding and other response measures to the COVID-19 pandemic. To read more about the HEROES Act, click here.
The CARES Act. On March 27, the Coronavirus Aid, Relief, and Economic Securities (CARES) Act was signed in to law. The bill did not include Housing Credit provisions; however, it did include language with direct or indirect impact on the Housing Credit. To read more about the CARES Act, click here.
Regulatory Advocacy
The ACTION Campaign urges the IRS and the Treasury to take immediate regulatory action to provide deadline extensions and other necessary accommodations for the Housing Credit program in light of the severe disruptions the COVID-19 pandemic is having on development and construction activities and the ongoing operations of existing Housing Credit properties.
Advocacy Resources:
To view a March 23 letter from NCSHA with Housing Credit regulatory requests to the IRS and Treasury, click here.
To view an April 8 letter with 233 organizations echoing support for those accommodation requests, click here.
To read an April 10 letter from House Ways and Means Chairman Richard Neal (D-MA-01) and Representative Suzan DelBene (D-WA-01) sent to Treasury Secretary Steven Mnuchin requesting deadline extensions, click here.
To view a November 16 letter from NCSHA with updated Housing Credit regulatory requests to the IRS and Treasury, click here.
To view a November 23 letter with 140 organizations echoing support for those accommodation requests, click here.
Regulatory Updates:
On July 1, the IRS published Notice 2020-53 providing temporary relief to owners and residents of Housing Credit and tax-exempt bond financed developments in response to the COVID-19 pandemic. The IRS guidance addresses nearly all of the issues raised in the letter that ACTION co-chair NCSHA sent to the IRS in March, and that many ACTION partners echoed in a sign-on letter. To read more, click here.
On April 9, the IRS provided short-term extensions to certain Housing Credit and Housing Bond deadlines due to COVID-19 through Notice 2020-23. To read ACTION’s blog for more information on the recent IRS notice as well as previous IRS guidance related to Housing Credit deadlines, click here.
To view an NCSHA’s matrix comparing the requested accommodations to those allowed under existing IRS Revenue Procedures 2014-49 and 2014-50, which provide relief in instances of Presidentially-declared Major Disasters, and to recent IRS Notice 2020-23, which extends certain program deadlines until July 15, 2020, click here.
Additional Resources
- The Affordable Housing Tax Credit Coalition (AHTCC) COVID-19 resource page
House Committee on Financial Services COVID-19 Resource Center
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