New York Housing Conference submitted comments in strong opposition to the U.S. Department of Housing and Urban Development’s (HUD) Notice of Proposed Rulemaking, “Establishing Flexibility for Implementation of Work Requirements and Term Limits” which would allow public housing authorities (PHAs) and owners to implement work requirements and term limits on tenants living in public housing or receiving Housing Choice Vouchers (HCV), Project Based Vouchers (PBV), or Project Based Rental Assistance (PBRA) for non-elderly, non-disabled families.
Arbitrary restrictions on assistance would only create more barriers to housing stability for individuals and families that can’t keep up with the housing market. Those that are work eligible but have no wage income only make up about one-fifth of households in the impacted programs but this still means 950,000 households are at risk of losing assistance – almost 70 percent of them have children. Term limits in particular are effectively an eviction sentence. There is no state, metropolitan area, or county where a full-time minimum-wage worker can afford a modest two-bedroom rental home at HUD’s determined Fair Market Rent (FMR). HUD’s own impact analysis showed 44 percent to 52 percent of families where they expect five-year term limits to be adopted would lose assistance.
The rapid turnover of rental assistance would also increase costs for PHAs and owners and threaten the financial viability of buildings that rely on the stable rental income. HUD anticipates that it will cost PHAs and landlords anywhere from $15 million to $255 million to throw half of families off of rental assistance. There would be impact to lenders and investors who underwrite their loans and/or investments against rental assistance income. For example, at least 57 percent of Low-Income Housing Tax Credit units received either PBRA, HCV, or PBVs in 2023. The investments of Government-Sponsored Enterprises (Fannie Mae and Freddie Mac) could also be undermined by renter instability brought by term limits A NYHC analysis found that from 2018-2023, the GSEs supported more than $49,563,000,000 in financing—through loan purchases and guarantees —for 238,634 multi-family units in properties across the U.S. participating in HUD’s Section 8 and RAD programs.
Read NYHC’s full comment here.