CLPHA Priorities for 2025

Opportunities and Challenges

Our nation is facing an unprecedented housing crisis, but there is strong bipartisan support for addressing housing supply and preservation challenges. The role of PHAs as affordable housing developers is growing, and PHAs will be crucial to increasing housing supply and preserving affordable units across the country.

Affordable housing development is a significant driver of economic growth. Congress and the second Trump Administration should expand opportunities for PHAs to boost affordable housing supply through regulatory streamlining, expanded tax credits for public-private partnerships, and new preservation tools. Opportunity Zones can also play an important role in expanding affordable housing development.

PHAs also operate and manage the majority of federal rental assistance programs in their communities and provide rent subsidies to private owners on behalf of low-income households. Funding disruptions not only put millions of households at risk for housing instability, but also cause local businesses and economies to experience significant negative impacts. Therefore, it is critical that congressionally authorized funding be available to PHAs in a timely manner so that their operations are not interrupted.

Because PHAs are key stakeholders in their local communities, it is critical that they receive the funds, flexibility, and federal support for their operations so that residents, landlords, private owners, and local economies can thrive.

*Note: these priorities have been updated since CLPHA's 2025 Spring Meeting to incorporate member feedback.

CLPHA's 2025 Priorities:

Fully Fund Rental Assistance Programs

When funding for federal rental assistance programs is interrupted or curtailed, residents and private owners experience negative impacts. The Public Housing Operating and Capital Funds, in combination with tenant rents, are the primary source of operating and capital revenue, and disruptions in funding can undermine public/private investment and the ability of PHAs to leverage public funds with private investment. Furthermore, private owners of every size depend on regular and consistent payments called for in the contracts with PHAs. Therefore, it is essential that Congress and the Trump Administration ensure continuity of funding for programs administered by PHAs.

Increase Program and Funding Flexibility

PHAs are burdened by onerous and inflexible regulations that impact their abilities to provide rental assistance programs that benefit low-income residents and private sector owners alike. Increasing program and funding flexibility and reducing regulatory burdens for PHAs will increase the efficiency and efficacy of their affordable housing programs. Congress and the second Trump Administration should: 

Eliminate Inefficiencies in PHA Funding and Programs

Streamline regulatory requirements in the Housing Choice Voucher program (HCV) for landlords, voucher holders, and applicants to allow more funding flexibility.
Allow HAP to be used for short-term financial assistance.
Streamline retrospective income determination so PHAs can use any 12-month period before an income determination is conducted.
Streamline income recertification to allow PHAs to consider self-certification or third-party income determinations as the highest form of income verification.
Provide all PHAs the full fungibility between the public housing operating and capital funds that small PHAs now have. 
Guarantee Annual Appropriations for vouchers for people who are homeless, at risk of homelessness or fleeing domestic violence.
Allow Restore Rebuild “operating assistance” only units to be attached to developments post-construction/rehab without additional development activity making it easier for PHAs to acquire properties and quickly designate vacant units as deeply affordable.
Extend funding and leasing permissions for EHV allocated to PHAs beyond 2025.
Allow PHAs to establish appropriate reserve levels based on their future projected need, including capital projects, pension obligations, and replacement reserves.  
Eliminate mandates for Small Area Fair Market Rents (FMR) for PHAs.   
Make permanent and expand the number of PHAs in the Moving to Work (MTW) program. 
Remove barriers to full flexibility and fungibility for MTW expansion agencies. 
Improve Project-Based Rental Assistance through greater flexibility with HOTMA forms and not requiring retroactive corrections to leasing or occupancy documents.

Provide Regulatory Relief for PHAs

HOTMA and HIP 

Develop a Housing Information Portal (HIP) migration plan in collaboration with software vendors and PHAs through CLPHA industry-wide IT Working Group.
Delay the July 1, 2025 compliance date for Sections 102 and 104 of HOTMA provisions by rescinding section IV.B of Notice PIH 2024-38.
Prioritize first rolling out the HIP software system using the current (2020) versions of Form 50058 that do not include HOTMA income and asset changes.
Provide software vendors with the Technical Reference Guide (TRG) that includes information on new HOTMA-compliant forms as soon as possible so they can program their software.
Postpone the required compliance date of HOTMA Sections 102 and 104 until at least one year after the HIP is launched, and allow for the option for further delay if needed.

Build America, Buy America (BABA) Regulations

Exempt federally assisted housing from BABA requirements to increase the pace and cost-efficiency for agencies modernizing public housing properties and developing other housing.
Waive tariffs for any iron, steel, construction materials, or manufactured products being imported in connection with any federally assisted housing.
Waive the applicability of BABA for small grants of up to $1 million for housing and community development programs (up from $250,000).
Increase the de minimis threshold for which housing and community development programs are exempt from BABA to 15% of the total cost of a project’s iron, steel, manufactured products, and construction materials (up from 5%).
Allow federal agencies to approve project-specific waivers or require strict timelines for central review.

Inspections and Assessments

Delay mandatory implementation of NSPIRE-V until October 1, 2026.
Do not require NSPIRE inspections of properties built within the last five years.
Provide clear and readily available guidance documents, FAQs, and training materials on NSPIRE for both PHAs and inspectors.
Allocate dedicated funding to PHAs for NSPIRE implementation costs, including hiring additional inspectors, purchasing equipment, and training staff.
Explore options to help PHAs manage rising costs, such as grant programs or risk-sharing mechanisms.
Reduce the number of inspection items that require 24-hour correction.
Waive voucher inspections in key instances.
Exclude MTW Expansion Agencies from PHAS, to allow them to implement innovative programs that are not constricted by current program assessments, as is the case with original MTW cohort.
Provide broad regulatory relief through proven MTW Waivers.

Admissions and Eligibility

Streamline off-site PBV waiting list administration to reduce PHA administrative burden and liability.
Allow PHAs to develop and adopt local preferences and other policies and procedures consistent with applicable Fair Housing and non-discrimination laws, for admission into programs so long as the families assisted qualify as low-income.
Allow PHAs to develop a local process for determining whether units meet certain eligibility requirements, provided such requirements are part of the 1937 Act.
Rescind the 30-Day Notification Requirement Prior to Termination of Lease for Nonpayment of Rent final rule.

Expand Housing Supply

Expanding housing supply is a crucial component of solving our nation’s affordable housing crisis. PHAs, in their capacity as housing developers, are integral to increasing the supply of both affordable and market-rate housing units. Congress and the Trump Administration can support efforts to preserve and expand affordable housing by expanding tax credits that allow public-private partnerships to leverage equity, increasing land use opportunities, and deregulating environmental reviews to promote housing supply.

Preserve Existing Affordable Housing

Expand opportunities for preservation, particularly through RAD. 
Support the development of additional affordable and market-rate units. 
Enact recommendations from the 10 Year Roadmap for preserving existing federally assisted housing. 
Eliminate the authorized RAD unit cap and sunset date for the program to provide certainty to PHAs and their private partners/investors. 
Increase rents at properties that converted through RAD early in the program. 
Simplify rent-setting calculations for RAD-PBV transactions.
Fund RAD rent adjustments to make high-cost, high-needs properties feasible for conversion.  
Provide that Restore-Rebuild (Faircloth to RAD) units receive an allocation of capital funding.  
Streamline the application and approval processes for Restore-Rebuild conversions.  
Ensure that subsidies for RAD project-based rental assistance (PBRA) contracts are sufficient to address capital needs and inflation.  
Ensure that operating cost adjustment factors (OCAFs) keep pace with inflation and fluctuating economic and market conditions.

Expand Tax Credits

Enact the bipartisan Affordable Housing Credit Improvement Act (AHCIA) to expand and strengthen the Low-Income Housing Tax Credit (LIHTC), our nation’s most successful tool for encouraging private investment in the development and preservation of affordable housing. If enacted, benefits could include:  
- Up to 1.94 million additional affordable homes financed  
- Nearly 3 million jobs created  
- $115 billion in additional tax revenue generated 
- $333 billion in wages and business incomes generated 
Expand the LIHTC allocation authority by 50% and give states greater ability to direct credits to preserve and increase deeply affordable housing supply.  
Lower the “50% test” to 25% regarding project costs that must be “financed-by” bonds to qualify for 4% LIHTC. 
Establish a basis boost for serving extremely low-income households. 
Eliminate the LIHTC Qualified Contract loophole.   
Enact the Supporting Allowing Volume Exception for Federally Assisted Housing (SAVE) Act that exempts federally assisted housing from tax-exempt bond volume cap restrictions, thereby allowing greater access to 4% LIHTC. 
Enact the HOPE Act to provide tax incentives that would expand investment in affordable housing preservation.
Strengthening the ability of PHAs and nonprofits to retain long-term control over LIHTC projects, including enactment of a statutory purchase option.

Support Public-Private Partnerships

Expand opportunities for affordable housing investment in Opportunity Zones. 
Fund additional renewable housing vouchers.   
Raise the cap on the number of vouchers PHAs may project-base (the PBV cap).  
Incentivize HFAs to prioritize allocating volume cap to preserve federally assisted housing in their Qualified Allocation Plans.  
Ensure housing tax credits are targeted to families with the greatest rent burdens.

Increase Land Use Opportunities and Streamline Review Processes

Open federal lands to affordable housing developers and offer PHAs priority access to build on these lands.  
Modernize environmental and permitting approval processes for affordable housing developers, including for those developments on federal lands.  
Waive National Environmental Policy Act permitting for public housing redevelopment and Restore-Rebuild projects that have already received local entitlements and undergone local or state-required environmental review. This will expedite project approvals and construction start times.
Waive Advisory Council on Historic Preservation regulations (Sec. 106) in affected historic preservation areas for all public housing redevelopment projects, whether rehabilitation or new construction to allow faster more streamlined permitting. Replacing or rehabilitating older, poorly constructed housing stock that may have public safety implications should not be held up just because the buildings are 50-years old or older.
Waive design reviews for Restore Rebuild and Choice Neighborhood Initiative transactions.
Waive upfront FHEO review for site and neighborhood standards and accessibility requirements for RAD transactions, Choice Neighborhood, and Restore-Rebuild transactions.
- Lift the standards completely in cases where PHA’s are just replacing housing in its existing location.

Leverage Housing as a Platform for Economic Independence

Reducing the number of individuals who need housing assistance requires investments in stable housing and services that foster workforce development, post-secondary education opportunities, and financial literacy. HUD and the Trump Administration can bolster these efforts by maintaining initiatives in these areas and fostering new opportunities to create economic mobility.  

Fund services and coordinators for programs that enable PHAs to assist residents with workforce development and post-secondary opportunities so that more residents can participate in these programs. 
Fund initiatives that give access to apprenticeships and college as pathways to employment and future economic success. 
Use and encourage data sharing to implement evidence-based programs. 
Streamline government regulations through cross-sector coordination. 
Support for workforce development and education efforts.

Ensure HUD Programmatic Capacity

HUD funding and staffing cuts could impact PHAs’ abilities to provide federal rental assistance and develop affordable housing. We recommend that Congress and the Trump Administration provide HUD with the capacity to deliver on the promise of these programs: 

Ensure HUD has adequate staff capacity with the expertise to oversee programs, provide necessary approvals, and ensure funding is delivered in a timely manner. 
Improve the accuracy and timeliness of FMR calculations.    
Provide notice and comment on forthcoming FMR and renewal funding inflation factors.  
Conduct a longitudinal study to observe the efficacy of FMR calculation methodology.

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CLPHA Priorities for 2025

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