Comment Letters and Testimony
America’s Affordable Housing Crisis: Challenges and Solutions
Member Statements
Orrin G. Hatch (R - UT)
Witnesses
Daniel Garcia-Diaz
Director, Financial Markets And Community Investment
United States Government Accountability Office
Washington
Grant S. Whitaker
President
National Council of State Housing Agencies
Washington , DC
The Honorable Katherine M. O’Regan, PhD
Professor Of Public Policy And Planning; Faculty Director, Furman Center For Real Estate And Urban Policy, Robert F. Wagner Graduate School Of Public Service
New York University
New York , NY
Kirk McClure, PhD
Professor, Urban Planning Program, School Of Public Policy And Administration, College Of Liberal Arts And Sciences
University of Kansas
Lawrence , KS
Granger MacDonald
Chairman Of The Board Of Directors
National Association of Home Builders
Washington , DC
Affordable Housing Trust Fund
NCSHA's Comments on Housing Trust Fund Proposed Rule
December 28, 2010
LIHTC Working Group Letter Regarding Proposed Regulations for the National Housing Trust Fund
December 28, 2010
H.R. 2895 National Affordable Housing Trust Fund Act of 2007
June 28, 2007
American Recovery and Reinvestment Act of 2009
LIHTC Working Group Letter: Recapture Issues Related to Section 1602 of the Recovery Act
July 30, 2009
Letter from Reps. Rangel and Frank to Treasury Secretary Geithner Urging Action on LIHTC Exchange Guidance
March 25, 2009
National Association of Home Builders Letter to Sen. Maria Cantwell in Support of her Amendment to Accelerate the LIHTC
January 26, 2009
Coalition of Affordable Housing Industry Participants' Letter Urging Support for the LIHTC be Included in Economic Recovery Bill
January 15, 2009
Community Reinvestment Act
LIHTC Working Group Comment Letter on the Proposed Changes to the Interagency Q&A Regarding Community Reinvestment
November 10, 2014
LIHTC Working Group Letter to the GAO on the Effect of CRA on LIHTC Investments
January 16, 2013
NCSHA Letter to Federal Regulators Asking Them to Improve CRA Regulations
August 31, 2010
Community Reinvestment Act: Towards a sustainable national CRA policy for Low Income Housing Tax Credit (LIHTC) investments
August 31, 2010
Dividend Exclusion Proposal
Letter from NCSHA Executive Director Barbara J. Thompson regarding a Correction to the MBAA Report
March 20, 2003
MBAA Multifamily Alert: Notice of Clarification
March 20, 2003
Statement of Secretary Shaun Donovan
February 25, 2003
Industry Joint Letter "The Impact of the Administrations Dividend Tax-Exemption Proposal on the Low Income Housing Tax Credit"
January 27, 2003
Treasury Department's Detailed Description of President Bush’s Dividend Exclusion Proposal from the Jobs and Growth Package
January 21, 2003
What a Dividend Tax-Exemption Rule Could Mean for Affordable Housing and Community Development Investments
January 20, 2003
Economic Substance
LIHTC Working Group Letter Seeking Guidance Related to Codification of Economic Substance and Low-Income Housing Tax Credits
October 27, 2010
Encourage LIHTC Investment
ACTION Campaign Letter to Congress about Housing Credit Authority and Private Activity Bonds
Nov. 21, 2022
Sen. Feinstein and Sen. Padilla Support Affordable Housing Provisions in BBB Revisions
April 6, 2022
H.R. 3661 Support Letter from Reps. Tiberi and Neal
February 28, 2012
Industry Consensus Letter: Proposals to Broaden LIHTC Investor Market, Produce Housing
August 3, 2009
National Association of Home Builders Letter to Sen. Maria Cantwell in Support of her Amendment to Accelerate the LIHTC
January 26, 2009
AHTCC Proposals to Stimulate Investment in Housing Credit Development
November 10, 2008
Enterprise Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
Enterprise Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007
Global Bond Ratings
AHTCC Letter to Moody’s Investors Service Regarding Assignment of Global Ratings to Tax-Exempt Municipal Obligations
June 30, 2008
Guidance Priority List
NCSHA Letter to IRS about Recommendations for 2022-2023 Priority Guidance Plan
June 3, 2022
Letter from Housing Groups to IRS about Notice 2022-21 Recommendations for 2022-2023 Priority Guidance Plan
June 3, 2022
ACTION Campaign Letter to IRS about Recommendations for 2022-2023 Priority Guidance Plan
June 3, 2022
LIHTC Working Group Letter to IRS on 2021-2022 Priority Guidance Plan
June 3, 2022
LIHTC Working Group Letter to IRS on 2021-2022 Priority Guidance Plan
May 28, 2021
LIHTC Working Group 2014-2015 Guidance Priority Letter Draft
May 13, 2014
LIHTC Working Group Letter Proposing an Issue for Addition to the 2012-2013 Guidance Priority List
April 30, 2012
LIHTC Working Group Letter to the Internal Revenue Service Regarding Notice 2011-39: Priority Guidance Plan
May 31, 2011
NABL Comment Letter Regarding 2009-2010 Guidance Priority List
May 28, 2009
Hold Harmless Rule
LIHTC Working Group Letter on Rural Designation Uncertainty
January 30, 2013
LIHTC Working Group Letter: Response to HUD Docket No. FR-5323-N-01: Request for Comments on Ending "Hold Harmless" Policy
November 2, 2009
LIHTC Working Group Letter to IRS Regarding HUD Hold Harmless Provisions in the Housing and Economic Recovery Act of 2008
April 15, 2009
HOPE VI/H.R. 1614
Housing Assistance for Hurricane Victims
NYSAFAH Letter Urging Introduction of Senate Hurricane Sandy Tax Relief Bill
September 27, 2013
Section 42(i)(2)(D) and CDBG Funds for Areas Impacted by Hurricanes Katrina, Rita and Wilma
January 8, 2007
NCSHA Letter Urging Extension of Provisions in IRS Notices 2005-69 and 2006-11
August 28, 2006
HUD 2530 Filing Requirements
Industry Sign-on Letter in Support of H.R. 1675, Preservation Approval Process Improvement Act of 2007
March 27, 2007
HUD Secretary Nomination
Statement of Chairman Christopher J. Dodd: Nomination Hearing for Shaun Donovan, HUD Secretary-Designate
January 13, 2009
Statement of Shaun Donovan, Nominee for Secretary of the U.S. Department of Housing and Urban Development
January 13, 2009
Improve the LIHTC Program
Congressional Letter to the Federal Housing Finance Agency in Support of Affordable Rental Housing and Reforming the Mortgage Finance System
January 23, 2014
AHTCC Letter to Rep. Rangel in Support of H.R. 1491
March 15, 2007
AHTCC Letter to Reps. Davis and Ramstad in Support of H.R. 1491
March 14, 2007
Dear Colleague Letter in support of H.R. 4873
June 27, 2006
Affordable Housing Tax Credit Coalition's Comments in response to NCSHA Working Group Proposals
September 10, 2004
Income Averaging
Congressional Leaders Letter on Average Income Test
May 26, 2022
Treasury Response to Senator Bennet
June 6, 2022
NCSHA Letter to IRS and Treasury on Income Averaging Implementation
National Council of State Housing Agencies, June 13, 2018
Income Limits
Comments on the Effects of 2020 American Community Survey Data Issues
Income Limits Working Group, March 25, 2022
Interpretation of Section 42(h)(4) of the Internal Revenue Code
Oregon State Treasurer letter to Donald Lee Korb, IRS Chief Counsel, and Eric Solomon, Treasury Deputy Assistant Secretary, Regulatory Affairs
January 28, 2005
LIHTC Consensus Proposals
Sens. Kerry, Cantwell Letter to Senate Finance Committee Leadership in Support of the LIHTC Consensus Proposals
December 17, 2009
Industry Consensus Letter: Proposals to Broaden LIHTC Investor Market, Produce Housing
October 26, 2009
Low-Income Housing Tax Credit Investment Survey
October 8, 2009
AHTCC Announces Legislative Priorities for 2009
May 19, 2009
Miscellaneous LIHTC
Moody's Investors Services: Outlook Update: US State Housing Finance Agencies Outlook Revised to Stable
October 8, 2013
Remarks Prepared for Jack Kemp, HUD Secretary, at the Heritage Foundation Lecture
June 6, 1990
A Vision of Hope: America's New War on Poverty - Remarks Prepared for Delivery by Secretary Jack Kemp to the National League of Cities
November 28, 1989
Remarks to National Press Club Luncheon by Jack Kemp, Sec. of Housing & Urban Development
November 15, 1989
Abolish HUD or Abolish Poverty?" Remarks by Hon. Jack Kemp to the Mortgage Bankers Association
October 23, 1989
NCSHA Recommended Practices
Novogradac & Company LLP Comments Regarding Potential Changes to NCSHAs Housing Credit Recommended Practices
September 27, 2010
Non-Discrimination Against Limited English Proficient (LEP) Persons
National Housing Provider Trade Associations' Joint Commentary Regarding HUD's Proposed Guidance
January 20, 2004
Notice 2009-44 (Treatment of Utility Costs Paid by Rent-Restricted Unit Tenant Based on Submetering)
Michael Uccellini, Institute of Real Estate Management, Comments on IRS Notice 2009-44
July 27, 2009
Michael Kotin, Kay-Kay Realty Corp., Comments on IRS Notice 2009-44
May 11, 2009
South Carolina State Housing Finance and Development Authority Comments on IRS Notice 2009-44
April 2009
Florida Tenant Monica Barronton Comments on IRS Notice 2009-44
April 2009
Preserve the Community Development Block Grant (CDBG) Program
Dear Colleague Letter to the Senate Budget Committee on preserving the Community Development Block Grants and related programs
February 16, 2005
Prevailing Wage Requirements
Department of Industrial Relations Ruling: Section 42 federal tax credits and tax-exempt bonds do not trigger prevailing wage
February 25, 2005
California S.B. 360 Public works: Prevailing Wages: Exclusions
September 2003
CA S.B. 972 Amending Prevailing Wage Law for Affordable Housing
September 28, 2002
Calif. S.B. 975, Prevailing Wage Law for Affordable Housing
August 30, 2001
Proposal to Double the LIHTC Cap in 2006
Sen. Charles Schumer Keynote Address to the Annual Awards Luncheon of the New York Housing Conference and National Housing Conference
December 7, 2004
Proposed Regulation and Guidance
LIHTC Working Group Letter to IRS about Public Comment for Notice 2022-48
November 4, 2022
NSCHA Comments on IRA Compliance Monitoring Regulations
May 6, 2019
American Bar Association Section of Taxation Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 28, 2007
National Housing Law Project
September 18, 2007
National Council of State Housing Agencies Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007
Affordable Housing Tax Credit Coalition Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007
Novogradac & Company LLP Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007
New York State Division of Housing and Community Renewal Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007
City of New York Department of Housing Preservation and Development Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 15, 2007
Georgia State Trade Association of Nonprofit Developers Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 14, 2007
Arizona Department of Housing Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 7, 2007
Washington State Housing Finance Commission Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 7, 2007
Public Comment Letters and Testimony
GAAP Accounting for Tax Credits Working Group Letter to FASB about Emerging Issues Task Force 21-A
March 23, 2022
Sen. Feinstein and Sen. Padilla Support Affordable Housing Provisions in BBB Revisions
April 6, 2022
NCSHA Sign-On Letter to Congressional Leaders on Using Fiscal Recovery Funds with the Housing Credit
March 2, 2022
Housing Industry Letter Urging Treasury to Align Fiscal Recovery Fund Rules with the Housing Credit
Dec. 10, 2021
Representatives Urge Congressional Leaders to Include Affordable Housing in Build Back Better
Oct. 18, 2021
Senators Urge President and Congressional Leaders to Include Affordable Housing in Build Back Better
Oct. 14, 2021
Letter to Pelosi, Feinstein and Padilla: Prioritizing Affordable Housing in the Build Back Better Package
Sept. 30, 2021
Letter to Senate Leadership from DelBene and Beyer
Aug. 25, 2021
National Association of Home Builders Urges Extension of Deadlines
Aug. 16, 2021
National Council of State Housing Agencies Urges IRS and Treasury to Extend Housing Credit COVID-19 Relief
Aug. 13, 2021
Poverty and Race Research Action Council Comment Letter on IRS Notice 2017-77
February 10, 2017
National Council of State Housing Agencies Comment Letter on IRS Notice 2016-77
February 10, 2017
Local Initiatives Support Corporation Comment Letter on IRS Notice 2016-77
February 10, 2017
National Housing Trust Comment Letter on IRS Notice 2016-77
February 10, 2017
Inclusive Communities Project, Inc. Comment Letter on IRS Notice 2016-77
February 10, 2017
Minnesota Housing Finance Agency Comment Letter on IRS Notice 2016-77
February 10, 2017
National Housing Law Project Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 18, 2007
Utah Housing Corporation Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007
National Association of Home Builders Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007
National Affordable Housing Management Association Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007
NCSHA Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007
NMHC Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 13, 2007
Arizona Department of Housing Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 7, 2007
Nationwide Housing Preservation Companies Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 6, 2007
Washington State Housing Finance Commission Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
August 27, 2007
Industry Letter Urging IRS to Consider Changing Regulations Governing Utility Allowances
April 12, 2005
Qualified Contract Price
Oregon Housing and Community Services letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 20, 2006
South Dakota Housing Development Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 9, 2006
Washington State Housing Finance Commission letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 9, 2006
Alabama Housing Finance Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 8, 2006
SEC Interpretation of LIHTC Public Fund Investments
Rep. Barney Frank Letter to SEC Chairman Christopher Cox Regarding SEC Audit Process for LIHTC Partnerships
September 18, 2007
AHTCC, NAHB, Housing Advisory Group Letter to Rep. Barney Frank Regarding SEC Audit Process for LIHTC Partnerships
September 6, 2007
Section 4965 (Exempt Organizations Prohibited Tax Shelter Transactions)
Novogradac & Company LLP Comment Letter Regarding Notice 2006-65
August 16, 2006
Affordable Housing Tax Credit Coalition Comments Regarding regulations pertaining Section 4965
August 11, 2006
State Tax Credits
Office of the Comptroller of the Currency (OCC) Interpretive Letter #948
December 2002
Statements, Letters, Testimony
140 Organizations Sign On to Letter to IRS and Treasury Urging Deadline Extensions for LIHTC Program
Nov. 24, 2020
Pennsylvania Delegation Letter to Congressional Leadership on LIHTC
April 20, 2020
Pennsylvania Delegation Letter to Treasury and IRS on LIHTC
April 20, 2020
Chairman Neal-Representative Delbene Letter to Treasury on LIHTC Deadlines
April 10, 2020
NCSHA Letter to HUD on CPD Program Accommodations
March 30, 2020
NCSHA letter to IRS on COVID-19 and the Housing Credit Program
March 23, 2020
Enterprise COVID-19 Response Policy Recommendations Letter to Congressional Leadership
March 21, 2020
NLHA and Other Real Estate Organizations Letter to Congressional Leaders Proposing Relief for Renters and Owners
March 19, 2020
NAHB’s COVID-19 Response Letter to President Trump
March 17, 2020
NAHB’s Letter to President Trump - Policy Proposals to Help Stabilize the Housing Sector in the Near Term
March 17, 2020
Tax Reform
Adrianne Todman, District of Columbia Housing Authority
April 16, 2015
Brad Fennell, WC Smith
April 16, 2015
James M. Evans, Quadel Consulting
April 16, 2015
Sheila Crowley, National Low-Income Housing Coalition
April 16, 2015
Letter to the Senate Discussing the Status of Tax Exempt Municipal Bonds
March 26, 2015
ACTION Campaign Letter Urging Inclusion of Minimum Low-Income Housing Tax Credit Rates in Tax Extenders Legislation
June 17, 2014
Hilary Shelton, NAACP
November 7, 2013
Rick Judson, National Association of Home Builders
November 7, 2013
Sheila Crowley, National Low Income Housing Coalition
November 7, 2013
Douglas Holtz-Eakin, American Action Forum
November 7, 2013
Ethan Handelman, National Housing Conference
November 7, 2013
Pres. Barack Obama's "A Better Bargain for the Middle Class: Housing" Plan
August 6, 2013
Tax Reform Joint Real Estate Industry Letter
July 23, 2013
LIHTC Working Group Letter to the Ways and Means Committee on Tax Reform and Residential Real Estate
May 8, 2013
LISC Tax Reform Working Group on Financial Services Letter to the Ways and Means Committee on Tax Reform
April 15, 2013
National Housing Trust Real Estate Tax Reform Working Group Letter to the Ways and Means Committee on Real Estate Tax Reform
April 15, 2013
Enterprise Letter to the Committee on Ways and Means Regarding Real Estate Tax Reform
April 15, 2013
LIHTC Working Group Letter to the Committee on Ways and Means on Real Estate Tax Reform
April 15, 2013
Letter to the Committee on Ways and Means Regarding Multifamily Housing and Tax Reform
April 4, 2013
Letter to the Senate Discussing the Status of Tax Exempt Municipal Bonds
March 8, 2013
Tax-Exempt Organizations
TEFRA Requirements for Bonds Under Section 147
NABL Guidance Recommendations on TEFRA Public Approval Requirements for Bonds
January 24, 2007
Treatment of LIHTCs Under the Troubled Asset Relief Program (TARP)
AHTCC Letter to Members of Congress Regarding the Emergency Economic Stabilization Act of 2008
October 10, 2008
AHTCC Letter to the Treasury Department Regarding the Emergency Economic Stabilization Act of 2008
October 10, 2008
Treatment of the GSEs LIHTC Portfolios
Statement of FHFA Acting Director Edward J. DeMarco Concerning the Possible Transfer of Fannie Mae Low-Income Housing Tax Credits to Investors
November 5, 2009
Press Release: Fannie Mae Reports Third-Quarter 2009 Results
November 5, 2009
Letter from Ways and Means Chairman Rangel to Secretary Paulson discouraging sale of GSEs LIHTC Portfolios
November 18, 2008
Unit Protection Rule
AHTCC Memo to IRS Regarding Its Position on the Unit Protection Rule
April 9, 2007
Utility Allowances
LIHTC Working Group Letter on Carryover Allocation and Utility Allowance Regulations
November 6, 2013
Statement by Sen. John Kerry (D-Mass.) on the Introduction of S 875, the Community Development Homeownership Tax Credit Act
April 10, 2003
Volcker Rule
LIHTC Working Group Letter on the Proposed Rule Implementing the Volcker Rule
February 13, 2012
Other
NLIHC Research Note: The Need for Emergency Rental Assistance During the COVID-19 and Economic Crisis
April 7, 2020
LIIF Policy Update: LIIF Shares Federal Policy Recommendations to Address Immediate COVID-19 Challenges
March 24, 2020
Joint Enterprise, HPN, LISC, OFN, National NeighborWorks Association, and SAHF recommendations on COVID-19 response
March 22, 2020
SAHF Housing Stability Proposals for the Lowest Income People on COVID-19 response
March 22, 2020
ACTION Campaign Recommendations to Congress for COVID-19 Relief Package Related to the Low-Income Housing Tax Credit
March 18, 2020
Bipartisan Mayors Letter to Congressional Leadership in Support of the Affordable Housing Credit Improvement Act of 2019
December 9, 2019
Senator Letter to IRS: Allow Veteran Housing Projects to Receive Tax-Exempt Bonds
March 15, 2019
Follow-Up Letter: LIHTC Regulatory Reform and the President’s Budget Proposal
March 20, 2016
Novogradac & Company LLP Comment Letter Regarding IRC Section 42: Conflicting Affordable Housing Program Requirements
February 27, 2013
Novogradac & Company LLP Comment Letter Regarding Form 8823: Low-Income Housing Credit Agencies Report of Noncompliance
August 29, 2011
Notice 2009-44: Utilities Paid by Tenant of Submetered Rent-restricted Unit
May 26, 2009
Industry Coalition Letter Seeking Guidance on Exchange Program
April 2, 2009
LIHTC Working Group Letter: Immediate Issues from the American Recovery and Reinvestment Act of 2009
March 16, 2009
LIHTC Industry Sign-On Letter Encouraging Inclusion of Housing Credit Provisions in Senate Stimulus Bill
February 3, 2009
Letter Regarding the Burdens Imposed by the Current Federal Income Tax System and the Need for Reform
February 2, 2011
Letter from Sen. Edward Kennedy to the Secretary of the Treasury
October 20, 2000
Senator George Mitchell Letter to Michael Novogradac Regarding the Future of the Low-Income Housing Tax Credit
November 4, 1993