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The National Housing Trust Fund: Making Sure it Meets the Greatest Needs

By Andrew Aurand, NLIHC Vice President for Research and Dan Emmanuel, NLIHC Research Analyst

nhtf_logo_webThe National Low Income Housing Coalition’s most recent Gap report indicates a national shortage of more than seven million affordable homes available to extremely low income (ELI) renter households, those with income of no more than 30% of their area median income (AMI). Unable to find affordable housing, ELI renters account for 7.8 million or 68% of the nation’s 11.4 million renter households who spend more than half of their income on housing. Meanwhile, fewer than half of new rental homes supported by federal housing subsidies on which developers most often rely – including the Low Income Housing Tax Credit (LIHTC), HOME Investment Partnerships Program (HOME), and the Federal Home Loan Bank’s Affordable Housing Program (AHP) – reach these households.

This year marks the first distribution of money from the national Housing Trust Fund (HTF), a program created to focus specifically on the housing needs of the lowest income renters. Funded by mandated contributions from Fannie Mae and Freddie Mac, at least 90% of HTF funds must be used for rental housing and at least 75% of funds for rental housing must benefit ELI households. All HTF money must benefit ELI households while the HTF is capitalized under $1 billion a year. The first year’s distribution of $174 million is small in comparison to the need, but is an important step forward in helping the nation’s lowest income renters find affordable housing. Successful implementation of the program in its first year will ensure in the future that the HTF truly serves the population it was intended to serve to the greatest extent possible.

A potential challenge that state advocates and other stakeholders are working to address is the possibility that renters whose income is at 30% of AMI may be cost burdened, spending more than 30% of their income on housing, even if they live in an HTF supported rental home. The Housing and Economic Recovery Act of 2008 modified the definition of ELI for the national HTF to include households whose income is no greater than the federal poverty guideline or 30% of AMI, whichever is higher.[1] The change broadened eligibility for the HTF to households who live in poverty, but whose income is greater than 30% of AMI. HUD’s HTF interim rule went a step further and applied the same criteria to set maximum rents at 30% of either the federal poverty guideline or 30% of AMI, whichever is higher. Wherever the federal poverty guideline is higher, renters with household income at 30% of AMI will be cost burdened by the maximum rent.

Table 1 shows the HTF maximum rent standard by apartment size across metropolitan and non-metropolitan counties.[2] Maximum rents are set at 30% of the federal poverty guideline in 61% and 92% of counties for one-bedroom and two-bedroom apartments, respectively. The vast majority of metropolitan and non-metropolitan counties alike have maximum rents based on the federal poverty guideline for apartments larger than one bedroom.

Table 1: Distribution of HTF Maximum Rent Standards by County and Size

All U.S. Countiesa(3,147)>

Metropolitan Counties (1,198)

Non-Metropolitan Counties (1,976)


% of Counties with Max. Rents Set at 30% of Area Median Incomeb

% of Counties with Max. Rents Set at 30% of the Federal Poverty Guideline

% of Counties with Max. Rents Set at 30% of Area Median Income*

% of Counties with Max. Rents Set at 30% of the Federal Poverty Guideline

% of Counties with Max. Rents Set at 30% of Area Median Income*

% of Counties with Max. Rents Set at 30% of the Federal Poverty Guideline

0 Bedroom







1 Bedroom







2 Bedroom







3 Bedroom







4 Bedroom







a. Includes county portions in New England, where multiple maximum rents can exist within the same county.

b. Includes counties where rents at 30% of 30% of AMI or 30% of federal poverty guideline are equal.


To illustrate the challenge, we calculated the potential cost burden for a 3-person family with income at 30% of AMI in each county at the maximum HTF rent for a two-bedroom apartment. They are available at In the median county where the maximum rent is based on the federal poverty guideline, a family of this size and income could spend 38.3% of their income on rent. In the worst cases, it would be 52.1%. The poorest counties, where the federal poverty guideline is much higher than 30% of AMI, will have the highest potential cost burdens. Cost burdened households have difficulty affording other basic necessities such as food, transportation, and health care and are at greater risk of housing instability if they experience a sudden financial crisis.

Table 2 presents a sample budget for a 3-person family with income at 30% of AMI in Orange County, FL. A two-bedroom apartment priced at the maximum HTF rent, based on the federal poverty guideline, would take 38.3% of the family’s income. Even after receiving the maximum benefit from the Supplemental Nutrition Assistance Program (SNAP), the family would be unable to meet all of their expenses without additional assistance.

Table 2: Sample Monthly Budgets for Family of 3 in Orange County, FL

Monthly Income

Maximum SNAP Benefit for Family of 3

HTF Maximum Rent for 2BR Unit

Cost of Food on USDA Thrifty Plan*

Cost of Transportation**

Cost of Health Care ***

Income Remaining for All Other Expenses

3 Person Household at 30% AMI








*Based on USDA Thrifty Food Plan estimates in May 2016 for a single female head of household between the ages of 19-50 with two children aged 6-8.

**Cost of transportation for family of 3 (1 adult, 2 children) in Orlando-Kissimmee-Sanford, FL MSA retrieved from Economic Policy Institute Family Budget Calculator (2015).

*** Cost of health care for family of 3 (1 adult, 2 children) in Orlando-Kissimmee-Sanford, FL MSA retrieved from Economic Policy Institute Family Budget Calculator (2015).

The national HTF is an important new resource in addressing the housing needs of the nation’s poorest renters. While rents affordable to households at 30%, 20%, or even 15% of AMI are challenging to achieve given development and operating costs, developers and stakeholders across the country are finding creative ways achieve them. NLIHC organized a webinar that recently attracted almost 1,000 registrants to discuss how to finance and operate ELI housing. We encourage advocates to use these and other tools to continue pressing to reward rents targeted to the lowest income households in their states HTF allocation plans. In these ways, we can assure that the national HTF meets the needs of the lowest income renters.

[1] This definition for ELI was applied to other HUD programs in the Consolidated Appropriations Act of 2014.

[2] Includes county portions in New England, where multiple maximum rents can exist within the same county.

Disaster Housing Recovery Update, Tuesday, June 5, 2018

Federal Response

Eight Senators introduced the Housing Victims of Major Disasters Act of 2018 on May 31, which will require FEMA to enter into an interagency agreement with HUD to activate the Disaster Housing Assistance Program (DHAP) as may be necessary in any of the 2017 disasters, including Hurricane Maria. This is in response to FEMA’s denying Puerto Rico Governor Ricardo Rossello’s request for DHAP five months after it was requested.  In a press release from Senator Warren, NLIHC President and CEO Diane Yentel offered strong support for the bill on behalf of the NLIHC-led Disaster Housing Recovery Coalition. 

Representative Ann Wagner (R-MO) amended a bill to permanently authorize the Community Development Block Grant-Disaster Recovery (CDBG-DR) program. Focused on the equitable distribution of funds, especially for low income households, one of the amendments requires FEMA to share with HUD–and make publicly available–all data collected and analyzed during the course of the disaster recovery.  The markup for the CDBG-DR bill in the House Financial Services Committee is this Thursday, June 7.

Representative Sean Maloney (D-NY) issued a letter to FEMA Administrator Brock Long urging him to reconsider FEMA’s May 15 denial of Puerto Rico Governor Rossello’s request that DHAP be activated for survivors of Hurricane Maria. In a press release, he noted the swifter provision of disaster relief by FEMA in Texas and Florida compared to that in Puerto Rico.

Fourteen members of Congress sent a letter to House Natural Resources Committee Chair Rob Bishop (R-UT) in response to the recent study that cited over 4,646 deaths in Puerto Rico due to Hurricane Maria. The Members requested the Committee hold a hearing on Puerto Rico to address this new information.

A report from the U.S. Government Accountability Office (GAO)—covering the period from 2008-2016– found that guidelines for why FEMA accepted or rejected requests for Individual Assistance from states were unclear and inconsistent. It also found that FEMA regions did not consistently obtain and document information on all elements of established IA regulatory factors when making IA recommendations to headquarters.

FEMA representatives are in the greater Houston area to provide expertise and advice on how to protect homes and prepare for the 2018 hurricane season. Locations, dates, and times can be found here.

FEMA spent $74.7 million on a ‘floating hotel’ cruise ship for federal workers in the US Virgin Islands. While the ship was supposed to house 2,056 workers, the average number of nightly passengers was under 800. This came at a rate of $5,959 per person per week, which was entirely paid for with tax-payer dollars.

HUD announced new job opportunities in Houston and San Juan, including Regional Relocation Specialists and Environmental Protection Specialists in the Office of Community Planning and Development.

State Action
The Texas General Land Office (GLO) is partnering with the University of Texas at Austin to conduct research on homeowners and renters to best assess the housing needs of those affected by Hurricane Harvey. This will facilitate the GLO in identifying the best type of housing assistance for individuals receiving CDBG-DR funds. The survey is open for two weeks, beginning on June 4, and can be found here:

Local Perspectives
A protest was held outside of the United Nations Headquarters in New York City on June 2 demanding an audit on the number of casualties caused by Hurricane Maria. This demonstration was in response to the recently published study which estimated the death toll from Hurricane Maria to be over 4,646 people, despite the official death toll of 64.

Citizens in Puerto Rico also protested the inaccurate death toll by placing shoes to represent those who died from Hurricane Maria In front of the capitol building in San Juan. 

Hurricane Maria tore away over 250,000 roofs, leaving most citizens in substandard living conditions. The Army Corps of Engineers (USACE) installed 59,500 tarps (or blue roofs) designed to last only a month, and many survivors were forced to install these tarps without professional assistance. It was reported that only 0.11% of applicants to FEMA’s Individual Housing program received the maximum assistance of $33,000, while most received less than $5000.

It is estimated that one quarter (100,000) of first-lien, home mortgages in Puerto Rico are in some stage of delinquency or foreclosure—well over half of these are hurricane-related. For the third time since Hurricane Maria made landfall, HUD has announced a foreclosure moratorium for survivors across Puerto Rico until August 16.

Working Groups on Disaster Housing Recovery

Puerto Rico
WG leaders met by phone with FEMA’s Office of the Chief Counsel in Washington to propose two affidavits designed by leaders in Puerto Rico to address the challenge of survivors without legal title to their property qualifying for assistance.  A second in-person meeting is being scheduled for next week when the FEMA counsel travels to Puerto Rico.
Next meeting:  June 19 at 3:00 pm EDT

Next meeting:  June 26 at 3:00 PM EDT

Data Transparency
Individuals from the WG combed through FEMA’s Individual Assistance Program and Policy Guide draft to identify an initial set of 17 comments.  These will be edited by the larger WG and shared with the entire DHRC for submissions by each organization during the public comment period, ending COB June 7th.
Next meeting:   June 6 at 3:30 PM EDT

The DHRC Policy WG decided to support Representative Wagner’s bill to permanently authorize the CDBG-DR program and to continue to advocate for ways to improve it through the legislative process. If your organization wants to be listed as a supporter of the bill, reach out to Sarah Mickelson ( The WG encourages you to reach out to your Representatives–especially if they are on the House Financial Services Committee—and urge them to support the bill scheduled for a vote in committee on June 7.
Next meeting:  June 12, 12:30 EDT

Read previous Disaster Housing Recovery updates at:

Hurricanes, Wednesday, September 27, 2017

General Updates

  • The U.S. Department of Education released guidelines for state and local educational agencies and schools to provide some flexibility and support post-disaster. The guidelines include flexibility on deadlines, alternatives and strategies for providing program services after disruption, and methods for ensuring continuity of services.
  • The National Law Center on Homelessness and Poverty, the Council of Parent Attorneys and Advocates, and the Southern Legal Counsel will hold a free webinar to discuss ways to help ensure educational continuity and stability for students displaced by the hurricanes and other disasters. The webinar will take place Thursday, October 5, 2017 at 3:30 pm ET. More information and registration is here.
  • FHLBanks Relief Fund. The Council of Federal Home Loan Banks (FHLBanks) has established a $1 million relief fund to help communities recovering from Hurricane Irma. Funds will be allocated to specific regional and national organizations.


  • Increased Federal Cost Sharing. President Trump authorized an increase in federal cost sharing 100% federal for debris removal and emergency protective measures in Puerto Rico and the Virgin Islands for 180 days after their respective disaster declarations.


  • Hospitals and ports. Power is restored at two Puerto Rico hospitals, and hospitals on St. Croix and St. Thomas are re-energized and re-established as mobile hospitals. In Puerto Rico, three ports are fully open and another five are open but with restrictions. Nine ports in the Virgin Islands are open but with restrictions.
  • Commodity Points of Distribution. Thirty-two commodity points of distribution (PODs) are now open, with 16 each in Puerto Rico and the Virgin Islands.




  • By the Numbers: (unchanged from 9/25)
    • 144,407 Individual Assistance (IA) applications approved*
    • $124,387,092 Individual & Household Program (IHP) approved*
    • $56,284,303 Housing Assistance (HA) approved*
    • $68,102,790 Other Needs Assistance (ONA) approved*

*Assistance dollars approved but not necessarily disbursed.

  • SBA Disaster Recovery. Next to insurance, the U.S. Small business Administration (SBA) is survivors’ primary source of funds for long-term rebuilding. Homeowners and renters should apply; if they are found ineligible, they may be referred to FEMA to be considered for additional assistance.
    • A homeowner may be eligible for a disaster loan up to $200,000 to repair or replace disaster-damaged or destroyed real estate.
    • Homeowners or renters may be eligible for up to $40,000 to repair or replace disaster-damaged or destroyed personal property.

Puerto Rico

  • Amendment Number 4. A fourth amendment to the initial disaster declaration enables residents in six more municipalities to apply for Individual Assistance (IA) and three more to apply for Public Assistance (PA).


  • Two More Eligible Counties. Amendment Number 2 to the initial disaster declaration makes residents in Charlton and Coffee counties eligible for FEMA Individual Assistance (IA).


  • Letter to HUD. Members of the Congressional Texas delegation have sent a letter to HUD Secretary Ben Carson requesting the immediate release of CDBG-DR funds for Texas. The letter also requests HUD to:
    • Exercise the authority given to it by Congress to lower to 50%, CDBG’s statutory requirement that 70% of the funds benefit households with income less than 80% of the area median income;
    • Avoid specified percentages of CDBG-DR be used for housing, infrastructure, or mitigation efforts; and
    • Shorten the usual CDBG public comment period regarding a draft disaster action plan from 30 days to seven days (last year’s CDBG-DR instructions allowed a 14-day public comment period).


  • By the Numbers: (no change from 9/25)
    • 213,062 Individual Assistance (IA) applications approved*
    • $407,677,861 Individual & Household Program (IHP) approved*
    • $276,665,092 Housing Assistance (HA) approved*
    • $131,012,769 Other Needs Assistance (ONA) approved*
    • $203,906,217 Public Assistance Grants (PA) obligated** all of which are for Emergency Work (Categories A-B)

*Assistance dollars approved but not necessarily disbursed.

**Funds made available to the State via electronic transfer following FEMA’s final review and approval of Public Assistance projects.

  • Floodplain or historic property restoration activities.  FEMA posted an initial public notice concerning activities that may affect historic properties, activities that are located in or affect wetland areas or the 100-year floodplain, and critical actions within the 500-year floodplain.
    • Presidential Executive Orders 11988 and 11990 require that all federal actions in or affecting floodplains or wetlands be reviewed for opportunities to relocate, and be evaluated for social, economic, historical, environmental, legal, and safety considerations. Where there is no opportunity to relocate, FEMA is required to undertake a detailed review to determine measures that can be taken to minimize future damage. The notice sets out four criteria that must be met to determine that there are no alternatives to restoration in the floodplain. The public is invited to participate in the process of identifying alternatives and analyzing their impacts.
    • Housing Individual Assistance (IA) actions may adversely affect a floodplain or wetland, or may result in continuing vulnerability to floods. Actions may include repair, restoration, or construction of housing, purchase and placement of travel trailers or manufactured housing units, or repair of structures as minimum protective measures. This is the only public notice concerning these actions.
    • The National Historic Preservation Act requires federal agencies to take into account the effects of their actions on historic properties. Actions or activities affecting buildings, structures, districts, or objects 50 years or older or that affect archeological sites or undisturbed ground will require further review to determine whether the property is eligible for listing on the National Register of Historic Places (Register). If the property is determined to be eligible for the Register, and FEMA’s actions will adversely affect it, FEMA will provide additional notices. For historic properties not adversely affected by FEMA’s actions, this will be the only notice.

Local Perspective

  • County Buyout. The Harris County Commissioners Court voted to spend $20 million to purchase more than 200 homes damaged during Hurricane Harvey. Commissioners hope these funds will speed up the recovery process.