The Spring Street Brief

The Government Accountability Office has released a comprehensive report on the Opportunity Zone tax incentive, responding to a congressional request for review in the aftermath of the One Big Beautiful Bill Act (OBBBA), enacted in 2025. The report examines how OBBBA provisions reshape future zone characteristics, what states and stakeholders experienced under the original program, how much is actually known about community impact, and whether the new law's reforms address the original program's documented shortcomings — a question with direct implications for LIHTC investors, developers, and policymakers who have used OZ equity to layer into affordable housing deals. Key Takeaways: The GAO report was commissioned by Congress specifically to evaluate the OBBBA's changes to the Opportunity Zone program, signaling active legislative scrutiny of the reformed incentive. The report's four-part scope includes zone characteristics under the new law, stakeholder experience with the original incentive, community impact awareness, and whether OBBBA reforms resolved prior program challenges. The original OZ program, created under the 2017 Tax Cuts and Jobs Act, drew persistent criticism for concentrating investment in already-transitioning neighborhoods rather than deeply distressed communities. A key GAO focus is the measurability of community benefit — a gap that has complicated both program defense and policy refinement since the program's inception. Deals layering OZ equity with LIHTC credits have been a notable market feature; shifts in investor behavior driven by the revised incentive structure will directly affect deal economics in those transactions. The report documents state-level administrative experience with zone designations, surfacing friction points that will inform how states approach designations under the new rules. Congressional appetite for further reform will be shaped by whether the OBBBA version of the program produces outcomes the GAO report framework can measure and validate. For practitioners structuring deals that layer Opportunity Zone equity with LIHTC credits, or state HFAs and agencies advising on zone designations under the revised program, this report is the most authoritative current assessment of what has actually changed and what remains unresolved. Monitor follow-on congressional activity closely — this GAO report is likely to serve as the evidentiary foundation for the next round of OZ legislation. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Florida's Live Local Act promised to unlock affordable and workforce housing development through tax exemptions and density bonuses — but three years in, nearly 50,000 of the 55,000 proposed units remain stalled. At the Leading Live Local 2026 event in Miami's Brickell neighborhood, developers and capital markets professionals identified the core bottleneck: Fannie Mae, Freddie Mac, and HUD are not yet underwriting Live Local deals at scale, and the path to GSE participation hinges on resolving a compliance and accountability debate with direct echoes of Texas's Public Facility Corporation debacle. Key Takeaways: Of 55,000 proposed Live Local Act units across 182 projects, only ~6,000 are under construction, per Florida Housing Coalition data. The Live Local Act (enacted 2023) offers a 75% tax abatement for units at 120% AMI and a 100% abatement for units at 80% AMI or below. GSE hesitation stems from Texas's 2015 Public Facility Corporation program, which granted 100% property and sales tax exemptions that were widely exploited due to weak accountability measures. A glitch bill has already locked in abatement upon receipt of a building permit, resolving the original vesting concern for construction lenders — but the GSEs remain cautious. The proposed fix: standardized Land Use Restriction Agreements (LURAs) that commit owners to rent levels and use terms, allowing GSEs to treat tax savings as cash flow rather than a liability. LURA terms as short as 5–10 years are under discussion, offering a middle ground between investor optionality and lender certainty. Despite a mandate requiring at least 50% of Fannie and Freddie's multifamily business to be mission-driven affordable housing, the enterprises are not yet routinely underwriting Live Local projects. The conversation at Leading Live Local 2026 has shifted from "will the GSEs participate" to "what does compliance look like" — a signal that the logjam may be breaking. Developers and lenders positioning for Live Local debt should begin structuring LURA terms proactively and engaging GSE counterparties early on abatement treatment in underwriting. The nearly 50,000 stalled units represent a significant opportunity if the compliance framework gets resolved, and the window to shape that framework is open right now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has published a Federal Register notice detailing the methodology for calculating FY 2027 Fair Market Rents (FMRs), which set payment ceilings for Housing Choice Vouchers and other federal rental assistance programs. Key changes include revisions to how HUD calculates the utility portion of gross rent inflation factors and updates to trend factor forecasts — both of which affect how closely final FMR figures track real market conditions. The notice also outlines the HOTMA-required procedures for PHAs to request FMR reevaluations. For LIHTC investors, developers, and lenders with voucher-assisted or FMR-constrained deals, the timeline is unusually compressed. Key Takeaways: HUD's FY 2027 FMR methodology notice is now published in the Federal Register and open for public comment. HUD is changing how it calculates the utility portion of gross rent inflation factors — a technical shift with real impact on final FMR levels. Trend factor forecasts are also being updated, affecting how FMRs are projected forward from ACS reference data. New FMRs take effect October 1, 2026 — the same day the public comment period closes. PHAs can request FMR reevaluations under HOTMA; procedures for doing so are detailed in this notice. Deals in FMR-constrained markets — particularly those dependent on competitive payment standards — face the most direct exposure to methodology changes. The comment window is effectively closed by the time final figures are published; stakeholders must act before October 1. With the comment deadline and effective date landing on the same day, developers, syndicators, and PHAs have a narrow window to influence the methodology before it locks in for the full fiscal year. Stakeholders with voucher-assisted portfolios or deals in tight FMR markets should review the utility inflation factor and trend forecast changes now and determine whether formal comments or a PHA reevaluation request are warranted. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

A $153 million tax-exempt affordable housing CMBS deal — eight times oversubscribed with $1.2 billion in orders — signals that private-label, tax-exempt commercial mortgage-backed securities are moving into the mainstream of affordable housing finance. For LIHTC developers, syndicators, and investors, a new federal PAB threshold reduction and growing institutional appetite are converging to make this structure an increasingly viable alternative to traditional agency and municipal bond executions. Key Takeaways: Systima Capital's July deal through the Public Finance Authority drew $1.2B+ in orders from 19 institutional investors on a $153M offering — more than 8x oversubscribed. The transaction was backed by a 1,272-unit, seven-property portfolio across Wisconsin, Illinois, Florida, Tennessee, and Texas, all LIE-tek-participating at or below 60% AMI. S&P assigned an A-minus to the senior tranche and BBB-plus to the subordinate; Systima retained the Class B certificates. Tax-exempt vs. taxable affordable housing securitizations currently show a 50–60 basis point spread savings, a meaningful advantage in a sustained high-rate environment. The new federal housing bill permanently lowered the PAB financing threshold for 4% LIHTC from 50% to 25%, reducing available municipal bond dollars and increasing demand for alternative capital sources like tax-exempt CMBS. State and local housing agency bond issuance grew from $9.6B in 2017 to $22.9B in 2025; $17.3B had already priced by August 24, 2026. Ratings currently cap in the low single-A range without a financial guarantee — reaching AA would materially expand the institutional investor base, per Municipal Market Analytics. As Wells Fargo, J.P. Morgan Chase, and Jefferies increase their underwriting activity in this space, competition will drive loan spreads lower and push more capital to the property level. Developers and syndicators sourcing permanent or construction financing should monitor which balance sheet lenders are pursuing private-label tax-exempt CMBS executions — and factor the PAB threshold change into their four percent LIHTC capital stacks going forward. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD Secretary Scott Turner rescinded Obama-era Fair Housing Act guidance that had effectively eliminated the statute of limitations for design and construction claims, replacing it with new guidance that enforces Congress's explicit two-year limitations period. HUD cites over $110 million in repair costs imposed on building owners over the past five years under the old framework — costs the agency argues are ultimately passed to renters and homebuyers. For LIHTC developers, syndicators, and lenders, this shift has direct implications for how legacy asset liability is underwritten and how acquisition-rehab due diligence is conducted. Key Takeaways: HUD rescinded guidance that had extended Fair Housing Act design and construction liability beyond the Act's statutory two-year limitations period. Over $110 million in repair costs were imposed on building owners over the past five years under the old guidance framework. The new guidance applies the two-year statute of limitations from the date of the alleged violation — not the date of complaint filing. Legacy LIHTC properties placed in service in the 1990s and early 2000s may see reduced tail liability exposure on design and construction claims. Acquisition-rehab due diligence processes should be reassessed in light of the changed liability horizon for older affordable housing assets. Fair housing advocacy groups are expected to challenge the new guidance in court — durability of the policy change is not guaranteed. HUD framed this action explicitly as a housing cost reduction measure, signaling continued regulatory rollback of liability-expanding guidance across the agency. This action is part of a broader pattern of HUD policy rollbacks under Secretary Turner aimed at reducing regulatory costs on builders and housing providers. For industry participants, the near-term priority is reassessing legal exposure on existing portfolios and watching for litigation that could unwind the new interpretation. Legal counsel should be engaged now — before pending administrative complaints move forward under assumptions that may no longer hold. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

NH&RA has launched a new project impact collection form to document real-world BABA (Build America, Buy America Act) compliance challenges affecting HUD-assisted affordable housing deals. The effort is part of active advocacy meetings with HUD and the Made In America Office (MIAO) within OMB, targeting faster waiver processing and broader compliance relief for the LIHTC and affordable housing development community. Key Takeaways: NH&RA is actively meeting with HUD and the Made In America Office (MIAO) within OMB to accelerate BABA waiver processing. BABA requirements apply to projects using federal assistance, directly impacting deals that layer LIHTC equity with FHA loans, HOME funds, or CDBG dollars. The new NH&RA form is designed to build a project-specific evidence database to support advocacy with both Congress and the Administration. Slow waiver processing has been cited as a primary source of deal friction — cost increases, procurement delays, and project restructurings are documented outcomes. Submissions from developers, syndicators, lenders, and HFAs are all being solicited — the database's strength depends on volume and specificity of responses. The advocacy window with the current Administration is active — timely submissions directly strengthen the negotiating position for systemic relief. BABA compliance has become one of the most operationally disruptive federal requirements for HUD-assisted affordable housing deals. NH&RA's database-building effort is a direct response — turning scattered project-level pain points into a structured policy argument. If your organization has navigated a BABA waiver, absorbed a material cost premium, or restructured a deal around compliance requirements, submitting that experience to NH&RA now is the highest-leverage action you can take. Visit NH&RA's website to access the form directly. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD released updated demolition and disposition guidance on August 28, 2026, expanding the tools available to public housing authorities to redevelop, sell, or reposition distressed properties. The guidance broadens the definition of obsolete buildings, reduces administrative burdens for small PHAs, and expands relief for mixed-finance and scattered-site properties — all with the explicit goal of moving more public housing stock onto the Section 8 platform where private capital can be leveraged. Key Takeaways: HUD estimates a $170 billion capital-needs backlog across the national public housing portfolio, the core problem this guidance addresses. The expanded definition of "obsolete" now includes buildings with outdated design features, widening the pool of properties eligible for demolition or disposition. PHAs with 75 or fewer units can now reposition their entire portfolio in a single action, exit the public housing program, and optionally consolidate with a larger nearby agency — with significantly reduced paperwork. Mixed-finance properties gain expanded access to demolition and disposition, removing a structural ambiguity that has complicated underwriting and deal execution. HUD broadened the definition of scattered sites, giving agencies and owners a cleaner path to disposition for those complex portfolios. The policy trajectory is explicit: HUD is steering distressed public housing toward the Section 8 platform to reduce federal operating subsidy reliance and increase private capital leverage. Families in distressed public housing are 3x more likely to live in higher-crime neighborhoods and 4x more likely to live in high-poverty concentrations, per HUD data cited in the announcement. For LIHTC developers, syndicators, and lenders with PHA relationships, the practical implication is an expanded pipeline of RAD and Section 18 conversion candidates. The small-agency provision in particular could surface consolidation and acquisition opportunities that were not viable under prior rules. Teams should revisit existing pipeline properties against the updated obsolescence and scattered-site definitions now, before the market reprices these opportunities. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Bipartisan Policy Center and the National Association of Affordable Housing Lenders (NAAHL) are hosting a joint policy forum on September 9, 2026, from 2–3 p.m. ET to examine implementation of the 21st Century ROAD to Housing Act. For LIHTC investors, developers, syndicators, and lenders, the forum comes at a critical moment — the regulatory and administrative details being resolved now will shape deal economics, housing supply outcomes, and state HFA activity for years ahead. Key Takeaways: The forum is scheduled for September 9, 2026, from 2:00–3:00 p.m. ET — a free, one-hour event hosted jointly by BPC and NAAHL. Speakers will address the full range of housing policy reforms included in the 21st Century ROAD to Housing Act, not just headline provisions. A key focus is implementation: where the rules still need to be written and where agency-level decisions will determine real-world outcomes. The legislation's potential impact on housing supply will be examined across states and communities — directly relevant to QAP strategy and state HFA engagement. Participants include experts from across the affordable housing industry, positioning this as a cross-sector intelligence opportunity for practitioners active in LIHTC, lending, and policy. The implementation phase is where broad reform legislation typically diverges from its stated intent — early engagement in forums like this can inform how organizations position their pipelines and advocacy. The 21st Century ROAD to Housing Act represents one of the more significant federal affordable housing reform efforts in recent years. With implementation underway, the September 9 forum is an early-stage opportunity to hear directly from practitioners and policymakers shaping the rules. Teams active in state HFA relationships, LIHTC structuring, or affordable housing lending should treat this as a must-attend or must-monitor event ahead of the next QAP and allocation cycle. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Fannie Mae abruptly cut roughly 12 senior executives last Friday, with eliminations concentrated in the multifamily lending unit, the low-income housing tax credit investment division, and finance, regulatory, and communications leadership. The Wall Street Journal first reported the shakeup, and Mortgage Point identified affected individuals by tracking removed employee profiles. For LIHTC investors, syndicators, and affordable housing lenders, the cuts raise immediate questions about deal continuity, underwriting appetite, and Fannie's institutional commitment to the affordable housing market. Key Takeaways: Approximately 12 senior executives were eliminated in a single action, reported Friday by the Wall Street Journal. Cuts specifically targeted Fannie's multifamily loans unit and its LIHTC investment operations — two divisions central to affordable housing finance. Finance, regulatory, and communications leadership were also among the eliminated roles, suggesting a broad, coordinated reduction. Affected executives were identified by Mortgage Point after their internal employee profiles were quietly removed from Fannie Mae's directories. The shakeup introduces near-term uncertainty around Fannie's LIHTC equity investment appetite and multifamily deal underwriting continuity. The timing overlaps with ongoing conservatorship exit discussions and potential FHFA-driven cost and mandate restructuring. Developers, syndicators, and lenders with active Fannie Mae relationships should immediately confirm the status of their deal contacts and relationship managers. Fannie Mae is one of the largest institutional LIHTC equity investors in the country and a cornerstone multifamily lender. Leadership disruption at this scale — particularly concentrated in affordable housing units — warrants close monitoring. Whether this is driven by conservatorship politics, FHFA directives, or internal restructuring, the downstream effect on deal flow and credit availability could be significant. Watch for further personnel disclosures and any formal statements from Fannie Mae or FHFA about the future direction of its multifamily and affordable housing operations. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

On August 25, 2026, HUD led a seven-agency joint rescission of the Biden-era Interagency Statement on Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act and Regulation B. The agencies — HUD, CFPB, DOJ, FDIC, NCUA, OCC, and FHFA — issued a unified directive telling creditors to stop relying on the 2022 guidance. For LIHTC lenders, syndicators, state HFAs, and GSE counterparties that built or expanded race-conscious credit programs under that framework, the compliance clock is now running. Key Takeaways: Seven federal agencies — HUD, CFPB, DOJ, FDIC, NCUA, OCC, and FHFA — jointly rescinded the February 2022 Interagency SPCP Statement on August 25, 2026. Creditors are explicitly directed not to rely on the 2022 statement, prior guidance, or related issuances going forward. The rescission is anchored in Executive Orders 14173 and 14151, which directed agencies to eliminate race-based preferences across federal programs and federally influenced credit markets. FHFA's participation signals direct implications for GSE seller-servicers — Fannie Mae and Freddie Mac counterparties should expect updated guidance on race-conscious credit products. DOJ Assistant AG Harmeet Dhillon explicitly identified enforcement of equal-treatment civil rights standards as a priority, elevating litigation risk for non-compliant programs. The underlying ECOA/Regulation B legal framework for SPCPs remains intact — programs built on economically relevant, non-protected criteria are not automatically disqualified. State HFAs and mission-driven lenders with demographic targeting in down-payment assistance or soft-second structures face the most immediate compliance exposure. The legal authority for SPCPs has not been eliminated — but the federal policy environment that made race-conscious credit programs administratively safe is gone. For the affordable housing industry, the priority action is an immediate legal review of any SPCP or targeted lending product that uses protected characteristics as a qualifying criterion. Watch for FHFA seller-servicer guidance as the next concrete signal of how GSE-connected lenders will be expected to respond. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Ohio Housing Finance Agency (OHFA) has released its first draft of program year 2026 guidelines for its 4% LIHTC with Bond Gap Financing (BGF) program, opening a short public comment window that closes August 27, 2026. For developers, syndicators, and lenders active in Ohio's four percent bond market, the draft guidelines — available in both clean and redline formats — directly govern deal feasibility for the coming program year. Key Takeaways: OHFA posted draft PY 2026 4% LIHTC with Bond Gap Financing guidelines for public comment on or before August 25, 2026. The public comment deadline is Thursday, August 27, 2026 — a narrow window of approximately two days from publication. Written comments must be submitted to [email protected]; no other comment channel is specified. Both a clean version and a redline of the draft guidelines have been published, enabling direct comparison to prior-year program terms. BGF is a subordinate debt program designed to close financing gaps in 4% LIHTC deals paired with private activity bonds — changes to loan terms, subsidy caps, or underwriting criteria affect senior debt sizing and syndicator pricing. Ohio four percent pipeline deals expected to close in PY 2026 should be stress-tested against draft BGF terms before the comment deadline. State HFAs routinely incorporate specific, deal-grounded written feedback into final guidelines — the comment process carries real influence. With the comment window closing in less than 48 hours from publication, Ohio market participants need to move quickly. Review the redline for material changes to eligible costs, maximum subsidy amounts, and underwriting standards. If draft provisions create structural problems for deals in your pipeline, submit written comments before Thursday. Final guidelines will govern program year 2026 transactions — there is no second opportunity to shape the terms once they are adopted. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has released the 2026 National Housing Trust Fund (HTF) allocations for all states and jurisdictions, with a total of $255 million available — up $32 million from the $223 million allocated in 2025. The HTF exclusively targets rental housing for extremely low-income households (at or below 30% of AMI), making it a critical gap-financing layer in complex LIHTC deal structures. Developers, syndicators, and lenders should expect state HFAs to begin updating their HTF allocation plans and opening application cycles imminently. Key Takeaways: Total 2026 HTF funding is $255 million, a ~14% increase over the 2025 total of $223 million. HTF is formula-distributed to states based on the shortage of affordable units and renter household incomes — states with larger affordability gaps receive larger absolute allocations. HTF exclusively funds units serving households at or below 30% of AMI, making it structurally distinct from LIHTC, which typically targets 50–60% AMI. HTF layered with 4% or 9% LIHTC equity can close the feasibility gap on the deepest affordability units in high-cost markets. State HFAs administer HTF through allocation plans — developers should engage their state agency now to confirm application timelines and available amounts. Deals with 30% AMI set-asides that currently have an unresolved gap should be reassessed in light of updated state HTF availability. QAP amendments and HTF plan updates from state HFAs are expected in the coming weeks — watch for competitive and over-the-counter application cycles opening soon. The 2026 HTF increase arrives at a moment when deep affordability is under intense pressure from rising construction costs and land prices. For developers structuring deals in high-cost markets, this is a timely opportunity to layer HTF into capital stacks before state application windows close. Teams that engage their HFAs early will be best positioned heading into year-end underwriting cycles. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has released its 2027 HOTMA inflationary adjustments and passbook rate, effective January 1, 2027, while simultaneously rescinding the waiver that allowed Emergency Housing Voucher (EHV) and Stability Voucher (SV) payment standards to reach up to 120% of Fair Market Rent. This episode walks through both actions and the cluster of additional HUD notices—on Title VI disparate-impact rules, VAWA lease addenda, and the renamed Foster Youth to Independence Initiative—that affordable housing operators and voucher administrators need to track now. Key Takeaways: HUD's 2027 HOTMA annual inflationary adjustments and passbook rate are effective January 1, 2027 — compliance teams should update income examination procedures before year-end. PIH has rescinded the EHV/SV payment standard waiver that allowed ranges of 90–120% of FMR; PHAs must now operate within the standard 90–110% FMR range. Existing exception payment standards already approved outside the 90–110% FMR range are not impacted by the rescission notice. HUD has proposed removing disparate-impact liability from its Title VI regulations, aligning with recent DOJ revisions — comments are due October 9, 2026. HUD is requesting comments on HUD Form 9834 (MOR) and HUD Form 91067 (VAWA Lease Addendum) — comments due September 3, 2026. PIH's updated FYI guidance removes the per-fiscal-year cap on vouchers PHAs can request under the Melania Trump Foster Youth to Independence Initiative, subject to funding availability. HUD launched a new Secure Systems landing page in July 2026 as part of its EICAM modernization initiative — no user action required, but the current URL remains available only through August during transition. The EHV payment standard rollback is the most operationally urgent item for housing authorities working in high-cost markets, where the 120% ceiling had been a critical placement tool for homeless and at-risk populations. Combined with the HOTMA adjustment cycle and the October 9 comment deadline on Title VI disparate-impact rules, this is a dense policy period — teams should prioritize review of all four items before Q4. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Senators Ruben Gallego (D-AZ) and Mike Rounds (R-SD) have introduced S. 5366, the Senate companion to the Affordable Housing Credit Carryback Act. The bill would create a five-year carryback for the Housing Credit, giving LIHTC investors the ability to apply unused credits against prior-year tax liability — a structural change that could meaningfully expand investor capacity and improve pricing on affordable housing deals. The measure has been referred to the Senate Committee on Finance. Key Takeaways: S. 5366 introduced by Senators Gallego (D-AZ) and Rounds (R-SD) — a companion to H.R. 9012, introduced in May by Reps. Carey (R-OH) and Panetta (D-CA). The bill creates a 5-year carryback for the Housing Credit, versus the current carry-forward-only structure. Carryback authority allows investors to recover credit value against prior-year tax liability, converting a deferred benefit into immediate cash — directly impacting investor pricing. Bipartisan co-sponsorship in both chambers is intentional, designed to strengthen the bill's chances of attachment to a broader tax package. The bill was introduced as a standalone measure specifically to better position it for inclusion in a viable tax vehicle moving through Congress. Expanded investor capacity through carryback could widen the buyer pool for LIHTC credits, particularly when corporate tax appetite is variable. Bill is now pending before the Senate Committee on Finance — committee calendar activity is the next signal to watch. With bipartisan support in both chambers and a strategic standalone posture, the Affordable Housing Credit Carryback Act is better positioned than most standalone tax measures. LIHTC developers, syndicators, and equity investors should track the Senate Finance Committee's legislative schedule and begin stress-testing deal structures against the possibility that carryback authority becomes law — because if a tax package moves, this provision has a credible path to inclusion. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has issued revised energy efficiency standards for HOME Investment Partnerships Program and Housing Trust Fund new construction, rolling the baseline back to the 2009 International Energy Conservation Code and ASHRAE 90.1-2007. The change follows a federal court ruling in March that found HUD and USDA's adoption of the 2021 IECC mandate violated the Cranston-Gonzalez National Affordable Housing Act — and it carries direct cost implications for affordable housing developers and participating jurisdictions nationwide. Key Takeaways: HUD's new baseline for HOME and HTF new construction is the 2009 IECC and ASHRAE 90.1-2007 — a significant rollback from the 2021 IECC and ASHRAE 90.1-2019 standards. A federal court sided with NAHB and 15 state attorneys general in March, ruling the 2021 IECC mandate violated the Cranston-Gonzalez National Affordable Housing Act. Unlike FHA programs, the stricter 2021 IECC standards actually took effect for HOME and HTF new construction in late 2024 — meaning projects completed or started under those standards face a different compliance calculus than pipeline deals. NAHB estimates the 2021 IECC and ASHRAE 90.1-2019 standards could add $9,600 to $21,400 to the cost of a new home. The buyer payback period for those added upfront costs could stretch up to 90 years, undermining the affordability case for mandatory adoption in subsidized programs. HUD has published updated FAQs formally clarifying the applicable standards for all HOME- and HTF-assisted new construction projects. Developers and participating jurisdictions should verify that project specifications and lender requirements align with the 2009 IECC baseline and seek field office guidance on any deals designed under the 2021 standards. This rollback closes a real cost exposure for affordable housing pipelines — but the fact that the 2021 standards were in effect for HOME and HTF new construction during late 2024 means practitioners cannot treat this as a clean slate. Any project that was scoped, bid, or completed under the stricter standards needs a careful compliance review before funds are drawn or deals are closed. Watch for additional HUD guidance as participating jurisdictions update their own program requirements in response. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Kentucky Housing Corporation (KHC) has announced the results of its 2026 tax-exempt bond funding round, selecting 15 applications and awarding more than $231 million in tax-exempt bonds paired with over $20 million in 4% Low-Income Housing Tax Credits. The funded projects will create or preserve 2,134 affordable rental units across Kentucky — a significant pipeline addition that signals KHC's continued commitment to bond-financed affordable housing production at scale. Key Takeaways: KHC awarded more than $231 million in tax-exempt bonds across 15 selected applications in its 2026 round. Projects are supported by over $20 million in 4% LIHTC, the automatic credit unlocked by private activity bond financing. The funded pipeline will create or preserve 2,134 affordable rental units throughout Kentucky. At an average of roughly 142 units per deal, the round suggests substantial project scale — not small scattered-site transactions. Preservation deals in this cohort are particularly significant, as bond-plus-4% structures can lock in long-term affordability restrictions for units otherwise at risk of market-rate conversion. For lenders, 15 bond transactions represent meaningful construction loan volume, credit enhancement decisions, and forward rate-lock exposure in the current rate environment. Developers not already engaged on these 15 projects should note that closing timelines typically follow award announcements by several months — the race to close has started. This round reinforces the role of the 4% LIHTC and private activity bond pairing as a primary production tool for state HFAs. Investors, syndicators, and lenders active in the Southeast should monitor KHC's QAP and future bond round announcements closely, as the agency's appetite for volume at this scale suggests a sustained strategic direction — not a one-cycle anomaly. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has issued a formal notice revising the Community Choice Demonstration (CCD), the renamed Housing Choice Voucher mobility demonstration. The updates restructure the evaluation design, shift the enrollment timeline, and sharpen the rules governing recapture and reallocation of Mobility Demonstration Vouchers — changes with direct operational implications for participating public housing authorities and broader policy significance for the affordable housing industry. Key Takeaways: HUD's notice formally removes the Selected Mobility-Related Services (SMRS) treatment arm from the CCD, narrowing the demonstration's evaluation scope. The CCD evaluation enrollment timeline has been revised, requiring PHAs to reassess staffing, outreach, and case management commitments accordingly. HUD has clarified the recapture and reallocation process for Mobility Demonstration Vouchers, defining what triggers a clawback and how funds are redistributed to other participants. The demonstration was formerly known as the Housing Choice Voucher mobility demonstration; the rebranding to Community Choice Demonstration reflects HUD's repositioning of the program's goals. CCD research outcomes are expected to influence future congressional and HUD policy on voucher mobility, including how mobility factors into competitive funding rounds. PHAs holding Mobility Demonstration Vouchers should review the updated notice immediately to avoid administrative disruption or unintended fund recapture. Removal of the SMRS arm reduces the evidence base the demonstration will generate, a concern for advocates and policymakers seeking rigorous data on mobility intervention effectiveness. The Community Choice Demonstration remains one of HUD's most closely watched active laboratories for voucher policy. Its findings will inform how mobility is weighted in future funding competitions and how Congress frames the next generation of housing mobility legislation. For developers and syndicators operating in opportunity areas, the direction of that policy conversation has real implications for deal viability and subsidy layering strategies. Stakeholders should engage with HUD's updated notice now and monitor the revised evaluation design as it takes shape. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The First-Time Homebuyer Affordability Act (H.R. 10075) was introduced by a bipartisan House quartet — Reps. LaHood, Panetta, Moore, and Suozzi — with a provision that carries major implications for multifamily affordable housing finance: exempting qualified mortgage bonds from the Private Activity Bond volume cap. If enacted, the bill would effectively end the competition between single-family mortgage bonds and multifamily 4% LIHTC bond deals for the same finite pool of state cap authority. Key Takeaways: H.R. 10075 would exempt qualified mortgage bonds from the PAB volume cap, directly reducing single-family demand on cap that multifamily deals also compete for. In 2023, $9,143.8 billion of total PABs issued went to single-family programs, versus $21,677.3 billion for multifamily — per the CDFA 2021–2023 Annual Volume Cap Report. 4% LIHTC deals are structurally dependent on Private Activity Bond financing; any expansion of effective cap availability translates to more viable multifamily pipelines. The bill is bipartisan — two Republican and two Democratic co-sponsors — improving its odds relative to single-party legislation. States with chronically oversubscribed volume cap would see the most direct benefit, as fewer competing claims on the pool means more allocable authority for multifamily deals. The policy mechanism is additive, not redistributive — it doesn't eliminate the single-family program, it removes it from the cap calculation. Developers and syndicators in high-demand cap states should monitor this bill's progress as the broader tax legislative calendar unfolds. This bill won't move in isolation — its fate is tied to the broader tax and housing finance legislative environment in Congress. But the mechanism is straightforward and the bipartisan framing is an asset. For affordable housing deal-makers in volume-cap-constrained markets, this is one of the more consequential single-family bills to watch precisely because of what it would do for multifamily. Stay close to your state HFA on cap availability regardless of outcome — but a favorable ruling here would materially change the calculus for 4% pipeline planning. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Governor Greg Abbott has announced more than $114 million in housing tax credits awarded by the Texas Department of Housing and Community Affairs (TDHCA), covering 70 rental properties and financing the construction or rehabilitation of over 4,400 affordable units statewide. For LIHTC investors, syndicators, developers, and lenders, this is one of the largest single-cycle award announcements in the Texas market and a significant signal about the state's affordable housing pipeline heading into the back half of 2026. Key Takeaways: TDHCA awarded over $114 million in housing tax credits in this cycle — one of the largest single announcements in recent Texas history. Awards span 70 rental properties, supporting construction or rehabilitation of more than 4,400 affordable units across the state. The award mix includes both new construction and rehabilitation deals, reflecting TDHCA's ongoing preservation strategy alongside new supply. 4% LIHTC deals paired with tax-exempt private activity bonds remain a key tool for rehab transactions, particularly as construction costs keep ground-up deals under pressure. Texas's QAP prioritizes proximity to amenities, income targeting, and geographic distribution — factors that will shape competitive positioning in future cycles. Developers who did not receive awards should analyze the geographic distribution of winning deals to inform future application strategy. TDHCA's full award list — including property-level credit amounts and credit types — is expected to be published on TDHCA's website and is essential reading for anyone active in the Texas market. Texas consistently operates one of the most competitive LIHTC allocation programs in the country. With this cycle closing at over $114 million across 70 deals, the state's pipeline remains robust — but so does the competition. Investors, syndicators, and lenders should monitor TDHCA's website for the full award list and begin positioning now for the next application cycle. For those tracking affordable housing capital deployment at scale, Texas remains one of the most consequential state markets to watch. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The IRS has released transitional guidance for current Opportunity Zone investors ahead of new OZ designations taking effect January 1, 2027, while a June 2026 Treasury Department analysis reveals a stark investment gap between rural and non-rural zones. Through 2024, the average rural OZ attracted just $7.3 million in investment compared to $23.3 million for non-rural OZs — a disparity with direct implications for developers and investors considering the upcoming designation round. Key Takeaways: Current OZ designations remain in effect through December 31, 2028; new designations take effect January 1, 2027. The IRS's transitional guidance signals that forthcoming proposed regulations will closely mirror its provisions — a key underwriting reference for deals spanning both designation periods. Through 2024, 77% of both rural and non-rural OZs received investment, but the average rural OZ received only $7.3 million vs. $23.3 million for non-rural OZs — a 3-to-1 gap. Rural-urban investment disparities vary significantly by state, meaning national averages obscure major regional differences. Rural tracts eligible for new designations show higher homeownership rates, higher housing vacancy rates, and lower home values than eligible non-rural tracts. Rural eligible tracts have older populations with lower educational attainment and weaker labor market attachment — factors affecting both demand underwriting and exit assumptions. Layered subsidy structures — combining OZ equity with LIHTC, USDA financing, or state rural set-asides — will likely be necessary for rural OZ deals to achieve financial feasibility. With the new designation round approaching and IRS regulations on the horizon, investors and developers should evaluate rural OZ pipeline opportunities now. The Treasury data provides a data-driven baseline for market demand assumptions, and the IRS transitional guidance offers regulatory clarity that reduces near-term structuring risk. Teams building rural OZ strategies should also monitor state-level variation closely — aggregate national figures mask the states where rural OZ capital is already flowing competitively. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The District of Columbia has filed a lawsuit seeking to block the relocation of HUD and Ginnie Mae headquarters from Washington, D.C., to Alexandria, Virginia. The complaint invokes the Residence Act of 1790 and each agency's governing statutes, arguing no congressional authorization exists for the move. With more than 80% of HUD headquarters staff already relocated, the case has immediate implications for agency operations, program delivery, and the broader affordable housing finance ecosystem. Key Takeaways: D.C. filed suit to block relocation of both HUD and Ginnie Mae headquarters to Alexandria, Virginia, citing the Residence Act of 1790 and agency-specific governing statutes. More than 80% of HUD headquarters staff and most Ginnie Mae employees have already been moved — the relocation is not proposed, it is substantially complete. The lawsuit alleges required environmental and historic preservation reviews were skipped, undermining the procedural basis for the move. The District disputes the agencies' cost estimates for renovating HUD's Robert C. Weaver Federal Building, a landmark that has housed the agency since 1968. D.C. claims the relocation will reduce local tax revenue by nearly $2 million annually, establishing concrete economic harm for standing purposes. No ruling has been issued; the court has not yet tested any of the allegations. Ginnie Mae's role in backing mortgage-backed securities for FHA-financed affordable deals makes its operational stability a direct concern for LIHTC and bond-financed transactions. This case is one to watch. A court order requiring both agencies to return to Washington would trigger significant operational disruption — and set a ceiling on unilateral executive action over agency placement. Conversely, if the relocation is allowed to stand, it establishes that headquarters can be moved without explicit congressional approval, a precedent with reach far beyond affordable housing. Developers, syndicators, and lenders with active HUD or Ginnie Mae pipelines should monitor the docket and assess contingency scenarios now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

121 House Democrats, led by Financial Services Committee Ranking Member Maxine Waters (D-CA), have formally urged HUD to withdraw its proposed "Equal Access to Housing in HUD Programs Revisions" rule — a proposal that would roll back LGBTQ+ protections across HUD-funded housing programs and shelters. The move follows a June letter from 28 senators led by Elizabeth Warren and Jeff Merkley, and comes after the rule's comment period closed with over 23,000 submissions. For LIHTC developers, operators, lenders, and syndicators with HUD-connected assets, this is a live regulatory conflict risk that demands attention now. Key Takeaways: 121 House members signed the letter urging HUD to withdraw the proposed rule — the largest congressional action on this issue to date. A separate June letter from 28 U.S. Senators, led by Warren (D-MA) and Merkley (D-OR), was sent prior to the close of the comment period. Over 23,000 public comments were submitted during the rulemaking period — creating a substantial administrative record for any future legal challenge. If finalized, the rule would require HUD-funded shelters to determine access based on HUD's definition of sex, removing the gender identity accommodation requirement currently in place. The rule is tied to the Executive Order "Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government," signaling administration commitment to finalization. LIHTC properties in states with strong LGBTQ+ protections face potential direct conflict between federal program requirements and state law if the rule is finalized. HUD is not legally required to withdraw the rule in response to congressional pressure — operators and lenders should not wait for political resolution before consulting counsel. Congressional opposition is significant, but it does not stop rulemaking. If HUD finalizes this rule, operators of HUD-funded and HUD-insured properties — including LIHTC developments — will need immediate legal guidance on how to navigate conflicts between the new federal requirements and applicable state and local fair housing law. Investors and lenders should be stress-testing this as a compliance and reputational risk factor in existing and prospective deals. The time to engage counsel is before the final rule publishes, not after. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The OCC and FDIC have proposed sweeping changes to Community Reinvestment Act bank size thresholds that could remove 416 banks — a 61% reduction — from the large bank category subject to the CRA investment test. Since the CRA incentivized roughly 80% of Housing Credit equity investment in 2024 (just over $23 billion), the proposal carries major implications for LIHTC equity supply, syndication volume, and affordable housing production broadly. Key Takeaways: The proposed small bank threshold rises from $412 million to under $1 billion (lending test only); small banks are not subject to the investment test. A new "intermediate bank" tier ($1B–$10B) replaces intermediate small banks, subject to lending and community development tests only — not the investment test. The large bank threshold rises from $1.649 billion to $10 billion, removing approximately 416 banks (61%) from the investment test requirement. The CRA incentivized ~80% of Housing Credit equity investment in 2024, totaling just over $23 billion, according to a new NAAHL report. From 2015–2022, the Housing Credit comprised 79% of OCC-regulated bank public welfare investments — $95 billion total. Regulators are also soliciting comment on alternative thresholds: an intermediate bank floor of $3.252 billion, an intermediate ceiling of $30 billion, and a small bank ceiling of $10 billion. The Federal Reserve is not party to this proposal, creating the possibility of divergent CRA frameworks across different bank regulators. The comment period opens 60 days after Federal Register publication; NH&RA is coordinating an industry response. This proposal arrives at a moment of significant housing affordability stress and represents one of the most consequential potential changes to the CRA investment framework in decades. LIHTC syndicators, equity investors, and affordable housing lenders with bank partners in the $1.649 billion to $10 billion asset range should assess their exposure and engage the comment process. The Federal Reserve's absence from the rulemaking also raises the prospect of regulatory fragmentation that could complicate multi-bank capital stacks going forward. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Senate Banking, Housing, and Urban Affairs Committee convened on July 23 for a combined vote and hearing on several Trump administration nominees — but left Jeffrey Ledbetter, the president's nominee for HUD Inspector General, without a confirmation vote after the panel moved into closed session to review FBI background investigations. It's the second time the administration has attempted to fill the post, following the withdrawn nomination of Jeremy Ellis on September 30, 2025. For LIHTC investors, developers, and lenders, the continued vacancy at the HUD IG office raises real questions about program oversight, audit direction, and enforcement consistency across HUD's affordable housing portfolio. Key Takeaways: Jeffrey Ledbetter's confirmation vote was skipped entirely on July 23 — the committee will vote at a later, unspecified date. Ledbetter is the administration's second HUD IG nominee; Jeremy Ellis's nomination was withdrawn September 30, 2025. Ledbetter has 30+ years with the Army's Criminal Investigation Division, including service in the Defense Department's Office of Inspector General. Ranking Member Elizabeth Warren cited troubling responses to pre-hearing Questions for the Record, potentially signaling a contested confirmation path. Irving Dennis, nominated as HUD CFO, spent 37 years at Ernst & Young and served as Secretary Ben Carson's principal financial management advisor during the first Trump administration. Dennis authored Transforming a Federal Agency: Management Lessons from HUD's Financial Reconstruction — a signal of the financial management priorities he may bring to the role. A sustained HUD IG vacancy affects oversight posture across LIHTC, Section 8, and CDBG programs — audit priorities and enforcement consistency remain uncertain until the post is filled. The committee's decision to table Ledbetter's vote — rather than vote it down outright — keeps the nomination alive but in a holding pattern. If the QFR responses Ranking Member Warren flagged become public before the next scheduled vote, they could shape both the confirmation outcome and the broader political environment around HUD oversight heading into fall budget negotiations. Stakeholders across the affordable housing spectrum should monitor whether the next vote date is set before or after the September appropriations deadline. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

JP Morgan has announced plans to deploy more than $750 billion through 2035 under its American Dream Initiative to expand housing supply, preserve affordable units, and support homeownership across the U.S. The commitment — from the nation's largest multifamily lender — spans debt, equity, grants, policy advocacy, and public-private partnerships, with an explicit target of preserving 1 million affordable units. For LIHTC investors, developers, syndicators, and state HFAs, this represents one of the most significant single-institution capital commitments to the affordable housing ecosystem in recent memory. Key Takeaways: JP Morgan will deploy more than $750 billion through 2035 via the American Dream Initiative, covering debt, equity, and grants to create and preserve housing supply. The initiative targets preservation of 1 million affordable units, directly relevant to LIHTC preservation pipelines and recapitalization deals. JP Morgan explicitly supports the 21st Century ROAD to Housing Act, which became federal law on July 11, 2026, aimed at boosting supply and curbing large investor home purchases. The rollout begins in five markets — Alabama, San Francisco, Philadelphia, Atlanta, and Los Angeles — with New York and Chicago to follow, signaling geographic deployment priorities for the near term. In San Francisco's Dogpatch neighborhood, JP Morgan used a recycled bond structure to deliver 105 affordable middle-income apartments at reduced per-unit cost, then committed $200 million for an adjacent multifamily community in the same redevelopment. Karen Purcell, who joined as head of community development banking in December 2025 after 16 years at Bank of America, is leading the community development deployment and is actively mobilizing multiple internal JP Morgan business lines. The firm is hiring additional professionals to support loan origination and client outreach, and is equipping bankers with policy, program, and subsidy toolkits — expanding its capacity as a financing counterparty. For LIHTC developers, syndicators, and state housing finance agencies operating in JP Morgan's initial target markets, early engagement is strategically important. The firm is explicitly seeking public-private partnerships and intends to shape housing policy at the local, state, and federal levels. The recycled bond solution deployed in San Francisco points toward a willingness to absorb structuring complexity that could unlock stalled feasibility-challenged pipelines. Firms that position themselves as partners in these markets now will have the greatest influence over how this capital is ultimately allocated. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Goldman Sachs's Urban Investment Group has closed a $116 million construction loan anchoring a $269 million financing package for the redevelopment of Parkside Commons, a Section 8-backed affordable housing complex in Syracuse, New York. The deal, structured by BFC Partners and SAA Canopy Group, combines federal and state LIHTC equity, tax-exempt bond proceeds, and a major institutional construction loan to deliver 393 affordable apartments through a phased renovation and new-construction strategy — with every existing resident remaining in the community throughout the transition. Key Takeaways: Goldman Sachs's Urban Investment Group provided a $116 million construction loan — the anchor piece of a $269 million total financing package. Federal LIHTC equity is projected to raise $88 million; New York State LIHTC equity adds another $13.6 million to the capital stack. The remaining funds derive from interest earnings on tax-exempt bond proceeds and interim project income, indicating a 4% PAB-driven deal structure. The project delivers 393 affordable apartments: 200 renovated units in six existing buildings and 193 new units across two new four- and five-story buildings. Renovations to the six western buildings begin in September 2026, with completion targeted for early 2028; new construction is projected ready for occupancy by late 2028. Four of the oldest buildings will be demolished after residents are relocated on-site — protecting HAP contract continuity for the Section 8 component. New York Homes and Community Renewal is the state agency partner; the demolished building footprints are designated for a future additional housing phase. Parkside Commons is a case study in institutional-scale affordable housing finance: a Section 8 preservation deal layered with dual-track LIHTC equity, tax-exempt bonds, and a nine-figure Goldman construction loan in an upstate New York market. For syndicators, lenders, and developers tracking where institutional capital is flowing in 2026, this transaction — and the phased pipeline it sets up — deserves close attention. The future development phase on the demolished building footprints represents an already-entitled land position inside an active affordable community, a rare asset in today's environment. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Maryland's Department of Housing and Community Development wrapped fiscal year 2026 with more than $1 billion in combined awards — low-income housing tax credits, state rental housing funds, Multifamily Bond Program financing, and energy efficiency program dollars — targeting the creation and preservation of 3,025 affordable rental units. For LIHTC investors, developers, syndicators, and lenders active in the mid-Atlantic, this round signals a robust near-term pipeline and a state agency operating at full deployment capacity. Key Takeaways: Maryland DHCD awarded more than $1 billion in total financing commitments in FY 2026. The round funds the creation or preservation of 3,025 affordable rental units statewide. Awards span LIHTC (4% and 9%), state rental housing funds, the Multifamily Bond Program, and energy efficiency programs — a full capital stack approach. Implied public subsidy commitment averages approximately $330,000 per unit, reflecting current construction cost realities. The Multifamily Bond Program component reinforces Maryland's commitment to bond-financed 4% deals as a volume driver. Energy efficiency program layering signals a dual focus on development feasibility and long-term resident operating cost reduction. Deal closings from this award round are expected to flow over the next 12–24 months, creating active transaction opportunities for syndicators and lenders. Maryland's FY 2026 round is one of the larger state HFA commitments on record for the state, and it sets a pricing and absorption benchmark for investors already holding Maryland LIHTC paper or evaluating new placements. Developers with active relationships in the state should move quickly to understand specific award recipients and capital stack structures. The subsidy is committed — execution is the next hurdle. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD's Office of Public and Indian Housing (PIH) has issued a formal notice extending the NSPIRE compliance deadline to February 1, 2027, for public housing authorities administering Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) programs, including Moving to Work agencies. The notice formalizes a September email announcement and establishes revised administrative procedures for transitioning from legacy Housing Quality Standards (HQS) to the National Standards for the Physical Inspection of Real Estate — with significant implications for LIHTC developers, syndicators, and lenders with PBV-dependent deals in their portfolios. Key Takeaways: The new NSPIRE compliance deadline for HCV and PBV programs is February 1, 2027 — extended from the previously anticipated timeline. The PIH notice formalizes a September email announcement, giving PHAs a defensible administrative record and regulatory clarity. Moving to Work PHAs are included in this notice — no separate compliance timeline or carve-out applies. NSPIRE standards differ materially from HQS in how life-threatening deficiencies, violation categories, and scoring are handled — affecting operational assumptions in existing and pipeline deals. PBV-layered LIHTC transactions are particularly exposed: rent structures and underwriting assumptions built around HQS inspection outcomes may require reassessment under NSPIRE. Owners and operators should use the remaining window to conduct gap analyses between current HQS performance and NSPIRE requirements and build remediation into asset management plans. The extended deadline is a planning opportunity — deals closing now with PBV components should model NSPIRE compliance costs before February 2027. With a firm deadline now on record, the window for passive monitoring is closed. LIHTC investors and developers with PBV exposure should be running NSPIRE gap assessments now, not in late 2026. The transition from HQS to NSPIRE represents one of the most significant shifts in voucher-program physical inspection standards in decades — and the February 2027 deadline will not move again. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Kansas Housing Resources Corporation has released its 2027 draft Qualified Allocation Plan, including a proposed-changes overview and a redlined version comparing the draft to the current plan. A virtual public hearing is scheduled for August 19, 2026 at 10:30 a.m., with registration required. For LIHTC developers, syndicators, and investors active in Kansas, the public comment period now underway is the critical window to influence scoring criteria, threshold requirements, set-asides, and tie-breakers that will govern the entire 2027 allocation cycle. Key Takeaways: KHRC published the 2027 draft QAP with a full redline against the current plan — review it to identify any changes to scoring, set-asides, basis boost eligibility, or developer fee caps. Virtual public hearing is set for Wednesday, August 19, 2026 at 10:30 a.m. — registration is required in advance. The public comment period is open now; written comments submitted alongside hearing testimony carry the most influence. Scoring and threshold changes in the QAP directly determine which deals are competitive in Kansas for the full 2027 LIHTC cycle. Developers with active Kansas pipeline should map proposed changes against site selection criteria, income targeting requirements, and amenity scoring before pre-development spending deepens. State HFAs track stakeholder participation — repeat applicants and lenders with existing relationships have particular standing to shape final QAP language. Once the QAP is finalized, comment-period leverage disappears; organizations with positions on any provision should act now. Kansas is one of several states finalizing QAPs for the 2027 allocation cycle this summer. Tracking redlined changes across state HFAs is increasingly important as developers balance multi-state pipelines against shifting scoring environments. If your team operates in Kansas or is evaluating entry, the KHRC draft QAP and public hearing represent direct access to the decision-makers setting next year's rules. Engage early and on the record. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Merchants Capital has closed on its Tax Credit Equity Fund 31, a $160 million multi-investor LIHTC equity fund backed by 10 institutional investors. The fund will inject equity into nine affordable housing properties, creating or preserving more than 1,400 affordable homes. For syndicators, developers, and LP investors, the closing is a concrete data point on the current state of institutional appetite for tax credit equity. Key Takeaways: Fund 31 closed at $160 million, making it a significant multi-investor vehicle in the current market. 10 institutional limited partners participated, signaling broad LP interest despite a challenging development environment. Equity will flow to nine affordable housing properties — implying an average of roughly $17–$18 million per asset. The fund is structured to create or preserve more than 1,400 affordable homes. The multi-investor fund format diversifies risk across a portfolio of deals, a structure increasingly favored by institutional LPs seeking LIHTC exposure without single-deal underwriting. Freshly closed funds carry deployment timelines — developers with near-term, shovel-ready deals are well-positioned to engage Merchants Capital now. The close reinforces that institutional LIHTC equity demand remains intact heading into the second half of 2026. The Merchants Capital Fund 31 close comes at a moment when the affordable housing industry is closely watching LP sentiment. Higher construction costs and prolonged interest rate pressure have complicated deal underwriting, yet this closing demonstrates that well-capitalized syndicators are still assembling large, diversified equity pools. Developers, co-syndicators, and lenders should treat this as a signal to engage active equity platforms early — capital with a deployment mandate moves fastest to sponsors who are ready to close. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

With federal government funding set to expire on September 30, 2026, Congress is on track to pass a continuing resolution rather than full FY2027 appropriations. The House passed its version of a CR before heading to recess — with no Trump Administration anomalies included — while the Senate is expected to introduce its own stopgap before breaking on August 7. For LIHTC investors, developers, and housing finance professionals, the key question is whether HUD-critical anomalies make it into the final deal. Key Takeaways: Federal funding expires September 30, 2026 — a CR is the base case, not a full-year spending bill. The House passed 3 of its 12 FY2027 funding bills; the Senate has released no CR text and no FY2027 bill language. The House CR includes zero anomalies requested by the Trump Administration — a significant omission for HUD program continuity. Senate Majority Leader Thune (R-SD) plans to bring a stopgap to the floor before August 7; the Senate version is expected to include some anomalies. Senate Appropriations Ranking Member Patty Murray (D-WA) called the House CR flawed and said it is unlikely to pass the Senate as written. HUD programs — including tenant-based rental assistance, project-based Section 8 renewals, and HOME — are funded through annual appropriations and are directly exposed to CR terms. Absence of HUD-specific anomalies could create operational disruptions to voucher renewals and rental assistance payment timing. A bicameral negotiation between the House's clean CR and the Senate's anomaly-inclusive version will play out over the coming weeks. For affordable housing stakeholders, the Senate CR text — when released — is the document to watch. Whether HUD programs receive anomaly protection will determine the operational risk heading into the fourth quarter. Monitor Senate Appropriations closely for any program-specific language affecting Section 8, HOME, or housing finance agency allocations. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

On July 17, 2026, HUD's Office of General Counsel (OGC) issued a notice rescinding 13 guidance documents effective September 25, 2025, covering Fair Housing compliance, the Violence Against Women Act (VAWA), the Mrs. Murphy exemption, and tenant admittance and eviction standards in federally assisted housing. The action follows a similar withdrawal of FHEO guidance documents in April, signaling a department-wide rollback of interpretive guidance that owners, PHAs, and compliance professionals have relied on for years. Key Takeaways: OGC rescinded 13 guidance documents in a single notice issued July 17, with a September 25, 2025 effective withdrawal date. Rescinded documents cover four major compliance areas: Fair Housing, VAWA, the Mrs. Murphy exemption, and tenant admittance and eviction in federally assisted housing. OGC's stated grounds include: guidance not prescribed by statute, guidance inconsistent with statute or regulation, and guidance imposing compliance burdens beyond the regulatory baseline — that third category has the broadest implications for owners. HUD's Office of Fair Housing and Equal Opportunity (FHEO) had already withdrawn a separate set of guidance documents in April, with an earlier effective date of September 17, 2025 — this OGC action is a continuation of the same rollback strategy. Underlying statutes and regulations remain in force; what's disappearing is the interpretive layer that shaped day-to-day compliance expectations. VAWA implementation guidance and tenant screening standards are among the highest-risk areas where the removal of agency direction creates immediate operational ambiguity. State HFAs and larger PHAs are likely to issue their own interim guidance to fill the void — watch for that activity in the coming months. This rollback removes compliance scaffolding that owners and management agents have built procedures around for years. Until replacement guidance — from HUD, state HFAs, or PHAs — arrives, operators of federally assisted housing should treat their VAWA policies, tenant screening criteria, and eviction procedures as requiring immediate legal review. The gap between statutory text and prior agency interpretation is now exposed, and the direction of risk exposure has shifted. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

USDA has published a proposed rule to amend its Section 515 Direct Multifamily Housing regulations, expanding the permissible uses of subsequent loans to include property acquisition. For developers, syndicators, and lenders working on rural affordable housing preservation, the change would open a new financing tool in one of the hardest-to-capitalize corners of the affordable housing market. Comments are due August 31, 2026. Key Takeaways: USDA proposes allowing Section 515 Direct Multifamily Housing subsequent loans to be used for acquisition — a use currently not permitted under existing regulations. The change is specifically targeted at preservation transactions involving properties originally financed by USDA's Section 515 program. Section 515 properties are among the most at-risk affordable units in the U.S. — typically small, rural, aging, and serving extremely low-income residents with few market alternatives. Adding acquisition as an eligible use could reduce equity or gap financing requirements in rural preservation deals, improving deal feasibility. 4% LIHTC transactions involving Section 515 property transfers will need to model the new debt layer against USDA loan assumption and subordination requirements. The comment deadline is August 31, 2026 — a tight window given the technical complexity of the proposal. Final regulatory language will determine real-world usability; industry comment on structuring mechanics and rural market realities is essential before the window closes. Rural multifamily preservation has long been constrained by small deal sizes, scattered geographies, and limited capital tools. If finalized in a workable form, this rule change could meaningfully expand USDA's role as a preservation lender — but the devil is in the drafting. Developers, state HFAs, syndicators, and lenders active in rural markets should review the proposed rule and submit comments before August 31. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Three federal policy developments are colliding this week with direct consequences for LIHTC investors, developers, lenders, and compliance teams. The House is moving toward a continuing resolution instead of full FY appropriations, HUD has withdrawn Federal Housing Administration guidance documents affecting FHA-insured multifamily transactions, and the Department of Homeland Security has finalized a rule rescinding the 2022 public charge ground of inadmissibility — reintroducing chilling effects for immigrant households relying on housing assistance programs. Key Takeaways: A House continuing resolution — rather than full appropriations — risks carrying forward flat or reduced funding baselines for HOME, Housing Choice Vouchers, and HUD administrative operations. HUD's withdrawal of FHA guidance documents creates underwriting uncertainty for lenders closing FHA-insured multifamily deals paired with 4% LIHTC and private activity bonds. Without current written guidance, lenders and counsel will need direct HUD program staff engagement to confirm policy positions, adding timeline and closing risk to active pipelines. DHS finalized a rule rescinding the 2022 public charge clarification that explicitly excluded housing assistance from inadmissibility determinations. The rollback reintroduces documented chilling effects among eligible immigrant households, directly threatening voucher utilization rates and occupancy stability at affordable properties. Compliance teams should brief on-site staff on the public charge change now — income certification integrity and occupancy projections used in underwriting can be affected by resident behavior changes. All three developments converge on the same pipeline simultaneously: financing-layer friction (FHA guidance), program-layer funding uncertainty (CR), and resident-layer chilling effects (public charge). The combination of a continuing resolution, withdrawn FHA guidance, and a reversed public charge rule represents compounding regulatory headwinds arriving at the same time. Developers and syndicators should stress-test deal timelines against HUD processing delays, lenders should escalate FHA guidance questions to program staff rather than relying on withdrawn documents, and property managers should prepare residents and compliance teams before confusion reaches the lease level. Forward-looking teams will map their exposure across all three vectors now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Oregon Housing and Community Services (OHCS) is advancing its Qualified Allocation Plan (QAP) update process ahead of the 2027 and 2028 LIHTC award cycles. A public engagement session scheduled for July 27, 2026 will review results from an April 2026 partner survey and open discussion on proposed QAP changes — giving developers, syndicators, lenders, and investors an early look at where Oregon's allocation priorities may shift before draft language is finalized. Key Takeaways: OHCS is updating the QAP for the 2027 and 2028 LIHTC award cycles — changes will affect scoring, set-asides, and underwriting parameters for both 9% and 4% allocations. An engagement session is set for Monday, July 27, 2026, 11 a.m.–noon Pacific, held via Microsoft Teams webinar — registration required. The April 2026 QAP survey focused on three areas: current QAP performance, financial challenges developers face, and specific policy questions — signaling OHCS is open to feasibility-driven changes. A formal public hearing and open comment period is anticipated for fall 2026, providing a second structured opportunity for industry input. QAP draft documents and comment opportunities will be distributed through OHCS Technical Advisories — teams not on that list risk missing critical windows. Direct questions to OHCS can be submitted to the QAP team via email ahead of or following the July 27 session. Oregon's QAP revision comes as developers across the state are navigating persistent cost and feasibility pressures. OHCS's explicit focus on financial challenges in its survey suggests the agency may be considering meaningful adjustments to how it underwrites or scores projects under current market conditions. Stakeholders with Oregon LIHTC exposure — whether active in competitive 9% deals or bond-financed 4% transactions — should participate in the July 27 session and position their organizations to comment during the fall public process before the QAP is finalized. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Greystone Real Estate Capital has closed its second affordable housing fund, raising $137 million in LIHTC equity from eight institutional investors to support nearly 2,000 affordable housing units across 20 properties in nine states. Combined with the $105 million Fund I close in August 2025, Greystone has now raised $240 million in under 12 months — a signal of accelerating institutional appetite for affordable housing as an asset class. Key Takeaways: Fund II closed at $137 million; combined with Fund I, Greystone has raised $240 million total in less than 12 months. Eight institutional LIHTC investors participated in Fund II; three are repeat investors from Fund I, indicating strong platform execution. Portfolio is 60% new construction / 40% rehabilitation, with 80% of properties carrying project-based rental subsidies. Average affordability level across the portfolio is 56% of Area Median Income. Individual equity investments range from $3 million to $29 million, averaging $11 million per deal; total development costs including debt approach $500 million. Portfolio spans nine states: North Carolina, Louisiana, Illinois, Pennsylvania, Connecticut, Arkansas, Tennessee, New Jersey, and Ohio. Projected economic impact includes ~2,700 jobs, ~$300 million in business revenue, and at least $111 million in local tax revenue. The Greystone story is worth tracking for what it signals about institutional demand. CRA-motivated investors are increasingly drawn to LIHTC funds as a vehicle for stable, long-term, impact-linked returns — and the repeat investor participation in Fund II suggests that demand is translating into real performance confidence. Developers active in the nine portfolio states should take note of Greystone's deal parameters as a benchmark for where institutional fund capital is pricing and sizing today. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has published its FY 2026 Renewal Funding Inflation Factors (RFIFs) for the Housing Choice Voucher (HCV) program, setting a national per unit cost growth projection of 2.337% and proposing a significant methodology change for FY 2027 that would incorporate local regulatory housing policy as a driver of rent inflation. The notice is effective July 6, with comments due August 5, 2026 — a narrow window for PHAs, syndicators, lenders, and LIHTC stakeholders with PBV exposure to engage. Key Takeaways: HUD projects national per unit cost growth at 2.337% between FY 2025 and FY 2026. The RFIF notice is effective July 6, 2026; public comments are due August 5, 2026. HUD is updating its PUC prediction methodology — not just setting an inflation number. For FY 2027, HUD proposes adding a factor for local land use, permitting, and regulatory housing policies that may be influencing local rent inflation above national trends. The proposed localized regulatory factor could increase HAP contract revenue predictability in supply-constrained markets with restrictive zoning environments. Syndicators and lenders underwriting deals with project-based voucher components should monitor how the FY 2027 methodology change interacts with local market conditions in their portfolios. PHAs relying on RFIF projections for renewal budget planning should review the methodology changes before the August 5 comment deadline. The FY 2027 methodology proposal is the more consequential development here. HUD explicitly linking local regulatory housing policy to funding inflation factors is a notable shift — one that could affect underwriting assumptions in high-cost, supply-constrained markets and reshape how PHAs and project-based voucher deals are modeled. Stakeholders with active PBV pipelines or PHA advisory relationships should engage the comment process before the August 5 deadline. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has proposed a rule to rescind the Federal Flood Risk Management Standard (FFRMS) final rule and its associated regulations, originally published in April 2024. The proposed rule would restore HUD's Part 55 floodplain management regulations to their pre-April 2024 state — removing the elevated site elevation and freeboard requirements that affected HUD-assisted and HUD-insured projects in or near floodplains. For LIHTC developers relying on FHA-insured debt or other HUD program dollars, the proposal would reduce site selection friction and eliminate costly engineering requirements triggered by the 2024 rule. Comments are due September 8, 2026. Key Takeaways: HUD's proposed rule targets the FFRMS final rule published in April 2024 — a full rescission of its elevated flood hazard standards. HUD's Part 55 floodplain management regulations would generally revert to their pre-April 2024 state. Flexibilities related to floodways, categorical exclusions, exemptions from Part 55 applicability, and the decision-making process would be preserved — not rescinded. Deals using FHA 221(d)(4) or 223(f) financing on sites near Special Flood Hazard Areas are directly affected — reduced elevation and freeboard requirements lower development cost and complexity. Developers and syndicators with deals in the pipeline structured around FFRMS requirements should revisit site engineering assumptions with environmental counsel. The public comment period closes September 8, 2026 — state HFAs, syndicators, and developers have a direct opportunity to shape the final rule. The proposed rule represents a broader rollback of Biden-era climate risk standards embedded in HUD program requirements. This proposal is a significant policy reversal with real deal-level implications. For teams active in HUD-insured lending or layering HUD grants into LIHTC transactions, now is the time to assess how the FFRMS has affected your underwriting and site selection — and whether the retained flexibilities adequately address floodplain risk management going forward. Engaging in the comment process before September 8 is the clearest way to influence the final outcome. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Ohio Housing Finance Agency (OHFA) has opened a public comment period on the first draft of its 2026–2027 9% LIHTC Qualified Allocation Plan (QAP) Technical Amendment, alongside updated opportunity area data and maps from the Urban Institute. For developers, syndicators, and investors with active Ohio pipeline, this mid-cycle amendment has direct implications for site scoring, geographic eligibility, and additional credit allocation strategies heading into the next competitive round. Key Takeaways: OHFA has posted the first draft of its 2026–2027 9% LIHTC QAP Technical Amendment for public comment — a mid-cycle revision with potential scoring implications across the state. Updated Urban Institute data and maps have been published alongside the draft, directly affecting how OHFA defines opportunity areas and eligible geographies for competitive scoring. The comment period also covers OHFA's additional credits policy, which governs how allocations beyond standard awards are handled — a key lever for deals with above-average credit need. The comment deadline is 5 p.m. on the date published on OHFA's website; written submissions must be received by that time. Developers should cross-reference active Ohio sites against revised Urban Institute maps immediately — a change in opportunity area designation can materially alter a deal's competitive scoring position. Ohio operates one of the most active 9% LIHTC programs in the Midwest, making QAP amendments consequential for a large share of regional affordable housing pipeline. Substantive public comment during this window is the last point of real leverage to influence final QAP language before the amendment is locked for the cycle. Mid-cycle QAP technical amendments don't happen in a vacuum — when an agency like OHFA updates its underlying opportunity mapping through a partner like the Urban Institute, the ripple effects on deal competitiveness can be significant. Teams with Ohio pipeline should treat this comment period as an active workstream, not a passive notification. Review the maps, assess your sites, and engage with the additional credits policy language if it touches your capital stack. The window is open now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The 21st Century Road to Housing Act — the ROAD Act — became law on July 11, 2026, without a presidential signature, after Congress passed it on June 23. Described as the most significant federal housing reform in a generation, the nearly 400-page bill includes dozens of provisions touching manufactured housing, zoning, Community Development Block Grants, the Rental Assistance Demonstration program, and bank investment capacity. For LIHTC investors, developers, syndicators, and lenders, several provisions have direct and near-term implications for deal structure, financing capacity, and preservation pipelines. Key Takeaways: Section 203 raises the Public Welfare Investment Cap from 15% to 20% of overall bank capital, expanding balance-sheet room for CRA-driven affordable housing equity investment. Section 204 reforms CDBG to permit new housing construction for the first time, allowing cities to allocate up to 20% of their CDBG funds toward new development. Section 212 expands the Rental Assistance Demonstration (RAD) program, giving PHAs broader authority to take on debt for unit preservation and rehabilitation. Section 301 eliminates HUD's permanent steel chassis requirement for manufactured homes; Section 303 updates FHA lending rules to allow home improvement loans for manufactured homes used as ADUs — opening a new federally backed financing lane. Section 208 authorizes a $200 million innovation fund for communities that increase housing supply, subject to congressional appropriation. HUD is directed under Section 107 to develop zoning and land use best practices for localities — guidance that could influence future state QAP incentive structures. The bill does not appropriate new demand-side dollars, does not address HUD staffing cuts, and leaves the mixed-status rule and housing-first policy questions unresolved. The ROAD Act's passage required genuine cross-aisle cooperation — Senate Banking Chair Tim Scott and Ranking Member Elizabeth Warren, House Financial Services Chair French Hill and Ranking Member Maxine Waters all had to find common ground. That political signal matters as much as the technical provisions: housing affordability is now a durable bipartisan priority, which sets the table for future, potentially larger reforms. For practitioners, the immediate focus should be on HUD implementation guidance for the CDBG construction flexibility and the Public Welfare Investment Cap increase, and on how state HFAs begin to incorporate the new manufactured housing financing pathways into upcoming QAP cycles. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Trump administration's effort to eliminate HUD's Restore-Rebuild initiative is now a national story, following a Politico report that highlights the program's cancellation and its cascading effects on public housing authorities and affordable housing developers. The San Diego Housing Commission is walking back plans for 700 units; the Council of Large Public Housing Authorities says the move contradicts HUD's stated mission. For LIHTC investors, developers, and lenders with Restore-Rebuild exposure in their pipelines, the implications are immediate and concrete. Key Takeaways: The Trump administration is moving to shut down HUD's Restore-Rebuild initiative, drawing national coverage from Politico. The San Diego Housing Commission is walking back plans to build 700 new affordable units that were structured around Restore-Rebuild funding. CLPHA CEO La Shelle Dozier called the move a direct contradiction of HUD's stated goal to expand affordable housing supply. Restore-Rebuild was one of the few remaining federal tools capable of delivering deep affordability layering in markets where 9% credits alone cannot close the financing gap. NH&RA led a letter-signing effort to HUD as recently as June 24 urging reconsideration — a sign that organized industry advocacy is underway but has not reversed course. Deals with Restore-Rebuild assumptions in their financing stacks face repricing, restructuring, or collapse without a replacement mechanism. State HFAs may face pressure to respond through QAP incentives or state-funded bridge programs as the federal gap widens. With the fiscal year-end approaching and congressional appropriators still engaged on housing funding, there is a narrow window for legislative intervention. Developers and PHAs with active Restore-Rebuild pipelines should begin stress-testing their financing structures now and engaging state HFAs about potential gap-filling strategies. The program's elimination is not yet finalized in statute, but the administrative intent is clear — waiting is not a strategy. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD's newly released LIHTC Tenant Tables for 2023 reveal that 57.2% of LIHTC residents earn 30% or less of area median gross income — the highest share of extremely low-income tenants ever recorded in the dataset. With a national median tenant income of just $18,600 and nearly half of all residents receiving rental assistance, the data paints a clear picture of who the program is actually serving and raises urgent questions for investors, developers, and policymakers about income targeting, layered subsidy, and underwriting assumptions. Key Takeaways: 57.2% of LIHTC residents are classified as extremely low-income (≤30% AMI) — the highest share ever recorded in this dataset. Only 6.2% of residents earn more than 60% AMI, meaning the program is heavily concentrated well below its statutory eligibility ceiling. 48.3% of LIHTC residents received monthly rental assistance in 2023 — the highest share since HUD began tracking this figure in 2015. The national median LIHTC tenant income was $18,600; nearly 20% of households reported annual income of $10,000 or less. The growing share of assisted tenants signals deepening interdependence between the LIHTC program and the Housing Choice Voucher system. This data strengthens the policy case for extremely low-income set-asides and deeper income targeting in state QAPs. Developers and underwriters should reassess rent collection risk assumptions given the declining income profile of the LIHTC tenant population. The 2023 Tenant Tables arrive at a moment when state housing finance agencies are refining their qualified allocation plans and Congress is debating the future of both the LIHTC program and the voucher system. The convergence of these policy tracks matters: if nearly half of LIHTC tenants depend on rental assistance to afford a tax credit unit, program design decisions made in Washington and in state capitals are more tightly coupled than ever. Stakeholders across the capital stack should be using this data now — in QAP comment periods, in advocacy, and in deal structuring. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Housing Assistance Council's latest research brief confirms what many rural housing advocates have feared: USDA's Section 515 Multifamily Housing portfolio is shrinking faster than scheduled maturities alone would explain. With 504 properties already gone ahead of their loan maturity dates and seven Midwestern states each losing more than 10% of their Section 515 stock since 2021, the affordable rural housing supply is eroding now — and USDA's own projections show the worst is still ahead, with exits peaking around 2040 and the program potentially depleted by 2056. Key Takeaways: 504 Section 515 properties have exited the portfolio before their mortgage maturity date — signaling early opt-outs and deterioration, not just scheduled wind-down. Seven states — Nebraska, North Dakota, Michigan, South Dakota, Wisconsin, Indiana, and Iowa — each lost more than 10% of their Section 515 housing stock between 2021 and 2026. Michigan recorded the largest unit loss: 2,072 affordable rural housing units departed the program in just five years. Losses are concentrated in the Midwest and Upper Great Plains, where early Section 515 loans are now reaching maturity — making this a regional crisis first, but a national one soon. USDA projects annual exits will accelerate sharply, peaking around 2040, with complete program depletion possible by 2056. Section 515 markets largely fall outside the LIHTC financing stack, meaning lost units are rarely replaced by conventional affordable housing mechanisms. Preservation opportunities exist now in the seven hardest-hit states — before the exit curve steepens further. For LIHTC investors, syndicators, and rural lenders, this brief is a signal to watch for preservation vehicles targeting Section 515 — including potential loan restructuring programs, new USDA appropriations, and rural housing tax credit proposals that have been circulating in Congress. The states losing the most units today are also the states most likely to assemble preservation pipelines first. That's where the near-term deal flow will be. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

A coalition of local governments and nonprofits has filed a supplemental complaint challenging HUD's FY 2026 Continuum of Care Notice of Funding Opportunity, arguing it mirrors the version a federal court already found likely unlawful in December 2025. With applications still due August 26, developers and syndicators structuring supportive housing deals with CoC operating subsidies face real underwriting uncertainty as the litigation advances. Key Takeaways: Plaintiffs filed a supplemental complaint in the existing CoC lawsuit, extending the legal challenge from the FY 2025 NOFO to the newly released FY 2026 NOFO. A preliminary injunction issued in December 2025 already blocked HUD's altered FY 2025 CoC NOFO, reverting to the prior FY 2024–25 version. Plaintiffs argue the FY 2026 NOFO "bears many similarities to the version the court already determined likely to be unlawful" — strong language signaling a high-confidence legal posture. FY 2026 CoC applications are still due August 26, despite the active litigation — applicants must decide whether to proceed under a potentially enjoined NOFO. CoC operating subsidies are frequently paired with LIHTC equity in permanent supportive housing deals; litigation-driven disruption creates bankability risk for deals in predevelopment. Any emergency motion for a temporary restraining order before August 26 could force HUD to extend the deadline or revert to prior NOFO terms. Developers and syndicators with CoC-dependent deals should build contingency language into timelines and monitor court dockets closely. This case is a live test of HUD's authority to reshape the CoC program's criteria and emphasis through the NOFO process alone. If the court extends injunctive relief to the FY 2026 cycle, it would mark the second consecutive year HUD's CoC funding notice has been blocked — a significant constraint on the agency's ability to redirect the program without statutory or regulatory change. Stakeholders across the supportive housing spectrum should treat August 26 as a fluid target and maintain close contact with their legal counsel and CoC intermediaries as the case develops. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Connecticut Housing Finance Authority (CHFA) has released its draft Qualified Allocation Plan (QAP) for 2027 and 2028, opening a brief public comment window that closes July 10, 2026. For LIHTC developers, syndicators, investors, and lenders active in Connecticut, this two-year plan will govern how CHFA scores and ranks tax credit applications through the end of 2028 — making early engagement critical for anyone with a Connecticut pipeline. Key Takeaways: CHFA's draft QAP covers two full allocation cycles — 2027 and 2028 — giving it an unusually long governance horizon for Connecticut LIHTC deals. A virtual public hearing is scheduled for July 7, 2026 at 10:00 AM ET via Zoom; all stakeholders are invited to participate. Written comments are accepted through close of business July 10, 2026 — just three days after the hearing. Submissions can be sent by email or by mail to Terry Nash Giovannucci, CHFA, 999 West Street, Rocky Hill, CT 06067. QAP provisions that merit close review include scoring criteria, set-aside allocations, geographic targeting, income targeting requirements, and developer fee caps — all of which directly affect deal feasibility. Syndicators and investors should use the draft to anticipate deal flow composition (project type, location, tenant population) from Connecticut over the next two years. Any party with active or planned Connecticut LIHTC applications should prioritize submitting formal comments before the July 10 deadline. With a two-year QAP, CHFA is setting the rules of the road for Connecticut affordable housing finance through the end of 2028. Changes embedded in this draft — whether to basis limits, scoring weights, or set-aside priorities — will compound across two full funding rounds. Stakeholders who engage now, during the comment period, have the best opportunity to shape outcomes before the plan is finalized. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has announced that all Preservation Rent Increase (PRI) funding available under the RAD for PRAC program has been exhausted for calendar year 2026. Any new RAD for Section 202/Project Rental Assistance Contract conversion plan submissions that include PRI funding and were submitted after May 29, 2026, will be waitlisted on a first-come, first-served basis. For sponsors, syndicators, lenders, and investors active in elderly affordable housing preservation, this announcement has immediate deal-structuring consequences. Key Takeaways: All PRI funding available under RAD for PRAC has been fully exhausted for calendar year 2026. New RAD for PRAC conversion plan submissions with PRI submitted after May 29, 2026, will be waitlisted and evaluated first-come, first-served. HUD's immediate priority is to assess funding availability and obligations tied to submissions already in the pipeline as of June 25, 2026. Deals submitted before May 29 are likely queue-protected; post-cutoff submissions face an indeterminate hold. PRI is often the critical bridge between existing PRAC contract rents and the rents required to support debt service in a conversion — making its absence a potential deal-stopper for many transactions. No timeline has been published for when HUD will resolve the backlog or when new PRI capacity may become available. Sponsors with post-cutoff submissions should confirm their waitlist position and engage their HUD field office directly to understand deal status relative to the June 25 assessment date. The exhaustion of PRI capacity this far into the calendar year signals that demand for RAD for PRAC conversions is outpacing available resources — a reflection of both the scale of need in the aging Section 202 housing stock and a rapidly building pipeline. Stakeholders should monitor HUD's funding assessment closely and evaluate whether alternative deal structures are viable while awaiting PRI availability. Proactive communication with HUD field offices and early queue positioning will be essential for deals dependent on this funding source. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

The Federal Housing Finance Agency has proposed a sweeping overhaul of the Duty to Serve regulations governing Fannie Mae and Freddie Mac. The proposed rule replaces the existing prescriptive Activities framework with a flexible, principles-based approach — and expands LIHTC credit eligibility across all three Duty to Serve underserved markets. For LIHTC investors, affordable housing developers, and structured finance practitioners, the comment deadline of July 24 and a target effective date of January 1, 2028, make this a near-term priority. Key Takeaways: FHFA proposes to eliminate the current Activities framework entirely, including Statutory and Regulatory Activity lists, Additional Activities, extra credit provisions, and minimum activity requirements from three-year plans. Enterprises would instead be permitted to pursue any action consistent with Duty to Serve, unless FHFA has specifically deemed it ineligible by regulation or case-by-case review. LIHTC investments would earn Duty to Serve credit across all three underserved markets — rural housing, manufactured housing, and affordable housing preservation — up from rural only under the current framework. The restriction on subordinate multifamily liens (previously limited to energy and water improvement financing) would be removed, opening the door to broader layered financing structures for multifamily affordable deals. The income calculation methodology would be revised to more accurately reflect families in areas of concentrated low-income populations, and affordability determinations for manufactured housing communities would be updated. Comments on the proposed rule are due July 24, 2026; regulatory changes are targeted to take effect January 1, 2028. A correction affecting refinancing mortgages that are not arms-length or borrower-driven transactions was posted June 26, 2026. The shift from a prescriptive activity checklist to a principles-based framework with a published ineligible-actions list will fundamentally reshape how Fannie Mae and Freddie Mac structure their Duty to Serve plans — and, by extension, how they engage with LIHTC deals, manufactured housing finance, and preservation transactions. The July 24 comment deadline gives the industry a narrow window to influence what ends up on the ineligible list. Practitioners with active pipeline in any of the three underserved markets should engage now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

HUD has issued a Request for Information (RFI) targeting a shift from project-specific waivers to general applicability (product-category) waivers under the Build America, Buy America Act (BABA). For LIHTC developers and their construction teams, this is the most actionable near-term opportunity for relief from one of the most disruptive compliance requirements introduced into federally assisted housing. Comments are due July 20, 2026. Key Takeaways: HUD's RFI targets product-category BABA waivers — meaning relief, once granted, would apply broadly across all projects using those products, not just on a deal-by-deal basis. The 30-day comment period closes July 20, 2026 — a tight window requiring immediate action from developers and their procurement teams. Covered product categories include HVAC systems (VRF, heat pumps, PTACs), plumbing fixtures, door hardware, elevators, fire alarm/suppression systems, solar panels, wood trusses, and a broad range of electrical components. Heat pump subcategories specifically called out include cold climate air-source, ducted split, ductless mini-split, geothermal/ground source, and water source — all common in energy-efficient affordable housing. Electrical components targeted include LED lighting fixtures, panelboards, distribution panels, GFCI receptacles, surge protection devices, and security cameras. NH&RA has announced it will submit a comment and has offered to assist others in drafting submissions. Project-specific BABA waivers are slow and resource-intensive; general applicability waivers would remove deal friction across the entire affordable housing pipeline for affected product types. The Build America, Buy America Act has added significant procurement complexity to federally assisted housing deals since its implementation. This RFI is HUD's clearest signal yet that it recognizes the operational burden and is looking for an evidence-based path to systemic relief. The public record built from this comment period will directly influence the scope and speed of any waivers granted — making the quality and specificity of developer and contractor submissions critically important. If your pipeline includes deals subject to BABA, this filing deserves attention at the leadership level today. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

President Trump canceled a planned signing of the 21st Century Road to Housing Act, leaving enrolled housing legislation in a holding pattern with no rescheduled signing date confirmed. NAHB Chairman Bill Owens expressed confidence the bill will eventually become law, but the delay introduces meaningful uncertainty for LIHTC investors, developers, syndicators, and state HFAs watching for any federal policy changes tied to the legislation. Key Takeaways: The 21st Century Road to Housing Act has cleared Congress — the only remaining step is a presidential signature. President Trump canceled the signing with no rescheduled date announced as of today. NAHB Chairman Bill Owens characterized the situation as a timing issue, not a policy breakdown — language that typically signals active negotiation. Developers and syndicators with deal structures or financing assumptions tied to any new federal housing authority in this bill should carry a contingency flag on effective dates. If the delay moves toward a veto or pocket veto, state HFA QAP planning that anticipated federal policy changes would need to be reassessed. Housing supply and affordability remain explicit political pressure points — Congressional passage of a bill of this scope is not routine and is unlikely to be abandoned quietly. Watch for a White House statement clarifying the basis for the delay; that statement will determine whether this is a weeks-long pause or a more significant obstacle. The legislative work is done — this is now an executive timing question. For LIHTC market participants, the practical implication is straightforward: do not underwrite to any policy change in this bill until a signing is confirmed. State HFAs drafting or finalizing QAPs should build flexibility for federal provisions that remain contingent on enactment. The market signal here is a holding pattern, not a collapse — but the distinction only matters if you're positioned accordingly. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

Senator Ron Wyden (D-OR) and Rep. Val Hoyle (D-OR) have reintroduced the Decent, Affordable, Safe Housing for All (DASH) Act for the third consecutive Congress. The bill expands LIHTC, introduces a new Middle-Income Housing Tax Credit (MIHTC), restructures the first-time homebuyer tax credit to be advanceable at closing, and adds a new home-sale loss deduction of up to $100,000 for low- and middle-income sellers. For LIHTC investors, developers, and syndicators, the MIHTC provision and the LIE-tek strengthening language are the provisions with the most direct market implications. Key Takeaways: The DASH Act has now been introduced in three consecutive Congresses (2023, 2024, and 2026); it has failed to advance out of committee both prior times. The bill proposes a new Middle-Income Housing Tax Credit (MIHTC) — a separate credit structure targeting the gap between LIHTC-eligible households and market-rate renters, which would require new equity market infrastructure to deploy. LIHTC is explicitly named as a strengthening target, alongside investment in deeply affordable housing for extremely-low-income households. The first-time homebuyer tax credit is restructured to be advanceable at closing, eliminating the liquidity gap that previously delayed access until tax filing season. A new home-sale loss deduction — new to this version of the bill — allows low- and middle-income sellers to deduct up to $100,000 when they sell for less than their original purchase price. Housing Choice Vouchers are central to the bill's homelessness strategy, with a five-year mandate to house all people experiencing homelessness, prioritizing children and families. The bill's fate depends on markup activity in the Senate Finance and House Ways and Means committees — neither of which has advanced prior versions. The DASH Act's repeated reintroduction reflects durable Democratic consensus on housing supply, voucher expansion, and tax credit tools — but legislative momentum remains the open question. For the LIHTC community, MIHTC is the provision worth building institutional familiarity with now. If it ever advances, syndicators and equity investors will need frameworks ready. Track Senate Finance and House Ways and Means for any sign of markup activity. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.