The Spring Street Brief

Episode 90: HUD Overhauls CoC Funding With $4.04B Recovery-First NOFO

3 min · 2. juni 2026
episode Episode 90: HUD Overhauls CoC Funding With $4.04B Recovery-First NOFO cover

Beskrivelse

HUD has released its Fiscal Year 2026 Continuum of Care Notice of Funding Opportunity — $4.04 billion in federal homelessness assistance structured around a fundamental policy shift away from housing-first and toward recovery, self-sufficiency, and competitive performance accountability. For developers, syndicators, and lenders with exposure to supportive housing, the implications for operating subsidy assumptions are immediate. Key Takeaways: * HUD's FY2026 CoC NOFO releases $4.04 billion — described by HUD as a record funding level for the program. * $1.3 billion is specifically reserved for new projects, with explicit priority given to Transitional Housing and Supportive Services over permanent supportive housing. * Automatic renewal of CoC grants is eliminated; CoC recipients must now competitively scrutinize and prioritize projects based on performance outcomes. * HUD is conditioning funding on prohibiting facilitation of illicit drug use, directly targeting harm-reduction models that have operated within CoC-funded programs. * HUD is actively encouraging new applicants, signaling that incumbent grantees no longer hold a structural funding advantage. * Deals carrying CoC-dependent operating revenue — particularly those built on housing-first frameworks — face genuine renewal risk under the new NOFO structure. * State QAP scoring of supportive housing and lender underwriting of CoC grant revenue may need to be reassessed as the federal program's priorities realign. This NOFO represents the most significant structural overhaul of the CoC program in its history. For the affordable housing finance community, the shift isn't just ideological — it changes the risk profile of supportive housing deals that depend on CoC operating subsidies. Developers, syndicators, and lenders should review existing and pipeline deals for CoC revenue exposure, and state HFAs should expect pressure to realign supportive housing priorities in upcoming QAP cycles. The $1.3 billion in new project funding is a real opportunity, but only for organizations positioned to compete under the new performance and programmatic framework. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

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Alle episoder

104 Episoder

episode Episode 105: Trump Pulls Back on 21st Century Road to Housing Act cover

Episode 105: Trump Pulls Back on 21st Century Road to Housing Act

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.

25. juni 20262 min
episode Episode 104: DASH Act Reintroduced With LIHTC and MIHTC Provisions cover

Episode 104: DASH Act Reintroduced With LIHTC and MIHTC Provisions

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.

I går3 min
episode Episode 103: Missouri MHDC Opens Public Comment on 2028 QAP cover

Episode 103: Missouri MHDC Opens Public Comment on 2028 QAP

The Missouri Housing Development Commission (MHDC) has opened a public comment period to gather input on topics under consideration for its 2028 Qualified Allocation Plan (QAP). With this window opening nearly two years ahead of the plan's effective year, developers, syndicators, lenders, and investors active in Missouri have an early and meaningful opportunity to influence how LIHTC and MHDC resources will be allocated — before internal drafts are even in circulation. Key Takeaways: * MHDC governs allocation of both 9% and 4% LIHTC through its annual QAP and associated Notice of Funding Availability (NOFA). * The comment period targets the 2028 QAP — opening approximately two years ahead of the plan's effective year, which is earlier than many peer state HFAs. * Written comments can be submitted directly to MHDC and are formally incorporated into the QAP development process. * Key policy levers subject to change include scoring criteria, basis limits, income targeting requirements, set-aside categories, and developer fee structures. * Early input — submitted before internal drafts are circulated — typically carries more influence than comments on a published draft. * Missouri is one of the more active Midwest HFAs; QAP changes have direct implications for project feasibility and investor returns across the state's deal pipeline. * Stakeholders with views on rural vs. urban prioritization, income averaging, deeper affordability scoring, or basis boost policy should act now. Missouri's decision to solicit feedback this early signals that MHDC intends a deliberate, stakeholder-informed process for the 2028 cycle. For organizations with Missouri projects in development or under evaluation, this is the moment to engage — not after a draft is released. Monitor MHDC communications for draft publication timelines and plan your comment strategy accordingly. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

19. juni 20262 min
episode Episode 102: Build Housing Affordably Act Targets BABA Reform cover

Episode 102: Build Housing Affordably Act Targets BABA Reform

A bipartisan House bill — H.R. 9311, the Build Housing Affordably Act — has been introduced by Rep. Mike Flood (R-NE), Chairman of the House Housing and Insurance Subcommittee, and Rep. Maggie Goodlander (D-NH). The legislation targets Build America Buy America Act (BABA) requirements that have created cost and timeline friction for affordable housing developers relying on federal funding streams, including LIHTC deals with federal program exposure. Key Takeaways: * H.R. 9311, the Build Housing Affordably Act, was introduced as bipartisan legislation in the U.S. House of Representatives. * Lead sponsors are Rep. Mike Flood (R-NE), Housing and Insurance Subcommittee Chairman, and Rep. Maggie Goodlander (D-NH) — a pairing designed to attract votes from both sides of the aisle. * The bill directly addresses BABA domestic content procurement requirements that have added cost drag and schedule risk to affordable housing deals with federal funding exposure. * The stated goal is to "strike a better balance" between promoting domestic production and sustaining the affordable housing development pipeline — framed as a housing production argument, not a deregulatory one. * BABA compliance friction has hit deals involving HUD programs and certain bond-financed structures particularly hard, where domestic supplier availability and pricing have not kept pace with project needs. * Flood's subcommittee chairmanship gives the bill a credible path to markup — making this more than a messaging exercise. * Developers with projects in predevelopment that rely on federal funding should model both current BABA compliance costs and potential relief scenarios as the bill advances. BABA has been a quiet deal-killer and cost inflator across the affordable housing pipeline since its requirements expanded under the infrastructure law. This bill represents the first serious, bipartisan legislative vehicle aimed at resolving that tension. Developers, syndicators, and lenders should monitor committee activity closely and engage their federal advocacy channels now — the window for industry input on bill language is typically widest before markup. A Senate companion bill, if introduced, would signal genuine momentum toward enactment. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

18. juni 20262 min
episode Episode 101: May Housing Starts Drop 15% as Multifamily Craters cover

Episode 101: May Housing Starts Drop 15% as Multifamily Craters

May housing starts fell 15.4% to a seasonally adjusted annual rate of 1.18 million units, but the headline understates the real shock: multifamily construction cratered 40.2% in a single month to an annualized pace of just 295,000 units — down 14.2% year-over-year. For LIHTC developers, syndicators, and lenders, the data lands at a critical moment, signaling that the construction pipeline is under serious stress from elevated interest rates, rising costs, and persistent labor shortages. Key Takeaways: * Overall May housing starts fell 15.4% to a 1.18 million seasonally adjusted annual rate (HUD/Census Bureau). * Multifamily starts dropped 40.2% in May to a 295,000 annualized pace — the sector is down 14.2% vs. May 2025. * Single-family starts declined 1.9% to an 882,000 annualized rate, down 6.7% year-over-year; homes under construction at 587,000, off 5.9% from a year ago. * Multifamily permits fell 2.8% to a 527,000 annualized pace in May, though they remain up 2.5% vs. May 2025 — a modest forward-pipeline signal worth watching. * The Northeast is the only region running positive on both starts (+17.5% YTD) and permits (+10% YTD); the South is down 6.7% on permits YTD. * NAHB's June builder sentiment survey weakened further, with elevated mortgage rates and affordability challenges cited as primary headwinds. * New LIHTC transactions underwriting today face elevated feasibility risk — the starts-to-permits gap indicates financing and cost execution, not demand, is where deals are stalling. The divergence between permits (relatively stable) and starts (sharply lower) is the key signal for affordable housing finance professionals. It suggests developers intend to build but cannot make the numbers work at current cost and rate levels — a dynamic that directly pressures LIHTC equity pricing, increases gap financing needs, and may drive further requests for basis boosts or state subsidy layering. Teams actively underwriting new transactions in the South and West should stress-test construction budgets more aggressively and revisit financing structures before locking commitments. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

17. juni 20263 min