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CLPHA and Reno & Cavanaugh recently submitted comments on HUD’s proposed revised forms of the Public Housing Authority Annual Contributions Contract (“ACC”) and Mixed Finance Amendment to the ACC (“MFACC Amendment”). Our comments, which were drafted with feedback from CLPHA members, are...

Yesterday, CLPHA submitted comments on the recent HOTMA notice, in which HUD sought comments on implementations of Sections 102, 103, and 104 of HOTMA. These provisions address income definitions and reexaminations, over-income households, and asset restrictions for public housing, the Housing...

Yesterday, CLPHA submitted comments in response to HUD’s notice outlining the first details of the NSPIRE demonstration. NSPIRE is a voluntary demonstration, expected to last at least two years, that would replace UPCS inspections for participating properties. NSPIRE is intended to simplify the...

Today, CLPHA and its counsel Reno & Cavanaugh submitted comments on HUD’s recent notice of proposed rulemaking on changes to the disparate impact standard.
As described in our August 19 member update, HUD is proposing substantial changes to the current “burden-shifting” framework used to...

On Friday, October 4, CLPHA and the RAD Collaborative submitted comments to HUD on the latest revision to the RAD Notice, which were prepared with our counsel, Reno & Cavanaugh, PLLC. The comments applaud HUD’s efforts to simplify RAD, address critical implementation issues, and...

On July 9, 2019, CLPHA and Reno & Cavanaugh PLLC submitted comments opposing HUD’s proposed rule titled “Housing and Community Development Act of 1980: Verification of Eligible Status.”
View CLPHA and Reno & Cavanaugh's Comments

On July 5, 2019, CLPHA submitted comments on HUD's proposed changes to the methodology used for estimating fair market rents (FMRs).
View CLPHA's Comments

On June 17, 2019, CLPHA submitted comments on HUD's notice seeking information on a review of HUD policy in opportunity zones.
View CLPHA's Comments

CLPHA’s comments for the proposed rule on changes to Section 3, as well as a summary of the rule’s major changes to Section 3 that was reviewed on CLPHA’s member call, are available below. Please contact Senior Research & Policy Analyst Emily Warren with questions at ewarren@clpha.org...

Draft comments for the proposed rule on changes to Section 3 are now available. CLPHA received valuable feedback on the changes during our recent member call and those concerns are reflected in our draft comments. Please contact Senior Research & Policy Analyst Emily Warren at ewarren@...