Housing Partnership Network appreciates the opportunity to comment on HUD’s review of existing regulations to assess their compliance costs and reduce regulatory burden pursuant to Executive Order 13771 “Reducing Regulation and Controlling Regulatory Costs.”
Housing Partnership Network is a business alliance of high-performing nonprofit affordable housing developers and lenders. The members’ businesses include affordable housing development, lending, property management and housing counseling. HPN has 97 members in 50 states that collectively have developed and preserved 373,600 homes, and have served 9.8 million low-income people through housing, community facilities and services. Through HPN, the members’ senior leadership comes together with their peers to exchange information, solve problems, and share best practices. Their collaborations have spawned member-owned businesses like a property insurance company and a Real Estate Investment Trust that advance innovations in the practice of affordable housing and community development.
HPN members develop both single family housing and multifamily housing and thus work with a broad array of HUD programs in combination with state and local funding. We understand the need for regulations to ensure that affordable housing is maintained in decent, safe condition and occupied by income-eligible tenants, but as layers of regulations, notices, and subregulatory guidance accumulate over time, they should be reevaluated to ensure that they are still needed. HPN’s members have some specific Notices and regulations to suggest, beginning with two bigger picture suggestions.