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Policy Update 2-26-21

Pamela Atwood, Director of Housing Policy

Around the State

General Assembly Update
The North Carolina General Assembly appears to be having a busy week. Committee meetings and budget appropriations work starts moving in earnest this week. Last week the Fiscal Research Division presented their revenue projections and budget recommendations to the General Assembly. Surprisingly, revenue is only expected to dip slightly and a fairly “normal” budget amount can be expected. Fiscal Research staffers recommended a base budget of $25 billion for FY 2021-2022, with about $2-3 billion remaining to be appropriated. 

For housing this represents some positive news as cuts to the Housing Trust Fund will be less likely. The Workforce Housing Loan Program as a non-recurring item, will need to be advocated for, however, with the positive budget outlook, the odds of receiving an allocation of similar size to recent years ($20 million) are improved.

The GA will also begin focusing this week on allocating the remaining federal COVID-19 relief funds that were not yet allocated (approximately $2 billion). The Coalition will keep an eye out on housing impacts as the GA legislates the remaining relief funds. 

Outreach to chairs of key committees will be necessary. The House Committee on General Government Appropriations will be important to discussion on funds related to housing resources. In the Senate, the Committee on Base Budget Appropriations will be most relevant. For links to committee chairs, see the following:

HOPE Program Updates
Updated statistics regarding the HOPE Program (the state’s rental assistance program) have been shared recently. According to Laura Hogshead, approximately $135 million in funds have been committed for rent or utility assistance payments as of 2/17/2021. Over 54,000 awards have been approved across over 35,000 households. Rent and utilities are considered separate awards (i.e. a household needing both rental and utility assistance, would receive two “awards). 

NCORR continues to process applications and make payment disbursements. The process of administering rental assistance has been challenging and delays have occurred. According to Hogshead many of those challenges are similar to what we’ve all faced – figuring out how to do our work remotely. Regarding other issues, NCORR is making policy and programmatic changes to address concerns and to improve their capacity to potentially administer the most recent round of emergency rental assistance. Over 170 new employees have been hired to help manage the demand for assistance and to prepare for administering the next round of rental assistance funds.

For those that have applied for assistance and are inquiring about their status, Hogshead urges people to visit the new applicant portal or reach out to 211 to request to speak to their case manager.

As of this writing, an official announcement regarding the re-opening of the HOPE Program has yet to be made. The Treasury Department has finally released revised guidance. (See below for more details.) Program officials should now be able to move forward with making sure that the next iteration of rental assistance is in line with federal guidelines. The Coalition will keep members informed as details emerge on additional rental assistance.

First Citizens Bank Announces Community Benefits Agreement
Last week, First Citizens Bank and the National Community Reinvestment Coalition (NCRC) announced that agreement had been reached regarding a $16 billion community benefits plan. First Citizens Bank, which is headquartered in North Carolina, is in the process of merging with the CIT Group. As part of the regulatory process concerning bank mergers, First Citizens has been in negotiations with NCRC, and its coalition of stakeholders, to develop a community benefits plan that helps to reinvest in low- and moderate-income communities and neighborhoods of color. 

The $16 billion five-year commitment features the following:

  • $6.9 billion for community development lending and investments, including affordable housing opportunities
  • $5.9 billion for lending to small businesses, supporting the growth of companies with less than $1 million in annual revenues and in LMI and majority/minority geographies; and
  • $3.2 billion for home purchase mortgage loans, focusing on LMI and minority borrowers and/or minority/majority geographies.

NCHC is among the numerous organizations across the country that participated in the negotiations and have signed on to the agreement. For more details visit:

Rental Housing Search Website Revamped
The statewide rental housing search portal,, has recently undergone an overhaul. The North Carolina Housing Finance Agency that partners to operate the site, has made aesthetic changes and made the site more user-friendly. The new website can be seen here:


Treasury Finally Releases Revised Guidance Document
Monday afternoon (2/22) the U.S. Treasury Department released revised guidance pertaining to the utilization and administration of the Emergency Rental Assistance Program enacted at the end of 2020. The program directs over $700 million to North Carolina, with the state receiving $546 million and localities (with populations over 200,000) receiving the remainder. The Frequently Asked Questions (FAQ) document provides much needed clarity for state and local administrators and housing advocates. Generally advocates and administrators are pleased with the revisions, which include many of the recommendations and information they called for.

Background Information
On January 19th the Treasury Department, led by out-going Secretary Steve Mnuchin, released an FAQ guidance document. Although intended to provide guidance to state and local government, the document created more questions than answers. The guidance contradicted or exceeded the enacting statutes. Housing advocates and program administrators immediately called for the Treasury Department to rescind or revise the January 19th document. Earlier this month the Treasury Department confirmed that they would revise the guidance and finally posted the revised guidance on Monday.

Highlights from the Revised Guidance
The revised FAQ, which can be found here, supersedes the January document and should provide enough information for administrators to reopen existing programs or stand up new ones. Officials that have been “waiting” on this information no longer have that available as an excuse. There are some issues, such as some finer details on reporting, that need clarification. However, the Treasury reports that they intend to release additional formal guidance in the near future. They will also be conducting an information webinar in partnership with HUD to provide additional explanation and answer questions. 

Some of the key information provided are listed below:

  • Self-certification (or “self-attestation”) is permitted for most eligibility criteria, including income, COVID-19 impacts, and demonstrating risk of homelessness. Grantees (local or state agencies) may opt for self-attestations in order to process applications more quickly. Many agencies, such as NCORR, report that collecting the correct documentation is among the most time-intensive tasks. 
  • Applicants must still provide documentation to show that they reside at the address for which assistance is being requested. 
  • Residents of federally subsidized housing, including users of housing vouchers, are eligible for assistance as long as it is not duplicative of other assistance the applicant receives or which subsidies cover. 
  • Costs related to accessing the internet can be covered as “other allowable housing expenses” if the internet is required so that members of the household may utilize the internet for distance learning, teleworking, and telemedicine. The Internet is not considered a “utility service” and other services/costs that may run alongside internet service (such as cable television) cannot be covered.
  • Up to 10% of the state or localities funds may be used for “housing stability services.” Administrative costs are not to be included in the same pot as housing stability services and should be taken out separately. The January guidance was not clear on this provision. Housing stability services can include legal assistance related to evictions (such as Legal Aid services), housing counseling, case management, and domestic abuse assistance. 
  • The timeframe for payments directly to renters can be as short as 10 calendar days in situations where the landlord has either been unresponsive or has refused assistance. Again, NCORR and other agencies report this to be an issue that slows down processing. 
  • The guidance does not include any details pertaining to citizenship or residency status and does not require that renter social security numbers be collected. 

While the guidance provides many answers and useful information, some issues remain unclear. Among them is regarding income targeting. The statute allows for a maximum of 80% of AMI and advises grantees to “prioritize” households with incomes less than 50% of AMI. The FAQ guidance does not elaborate further on this. Advocates are concerned that lower-income households with greater needs could be overlooked.

Another key issue to note is that the guidance states that grantees “may” do many of these things, such as self-certification. The guidance allows for jurisdictions to include additional measures as they see fit. While it appears that the federal guidance is quite flexible, advocacy will be needed to ensure that renters needing assistance are able to access the help they need and that administrators are able to efficiently do their jobs. 

With this new guidance, we are one step closer to the deployment of additional rental assistance that can help tens of the thousands of households in the state. The Coalition continues to monitor the status of the HOPE Program and will keep members informed. 

Update on Next COVID-19 Relief Package: The “American Rescue Plan Act”
The budget reconciliation process continues to move forward in Congress. Last week the House Budget Committee combined multiple spending bills from individual committees into one bill, now known as the “American Rescue Plan Act.” On Monday, the combined bill was approved by the House Budget Committee and is expected to come for a vote before the full House on Thursday or Friday. Then it will move to the Senate. 

In terms of housing resources, the bill contains about $40 billion in assistance for renters, people experiencing homelessness, and homeowners all struggling to find or keep housing, including the following:

  • $25 B for ERA (including $ for rural areas & tribal entities)
  • $9.9 B for mortgage assistance
  • $100 M for housing counseling
  • $ 5 B for additional assistance to people currently experiencing homelessness or in immediate risk of homelessness
  • $4.5 B for utility payment assistance 

In total the current bill amounts to $1.956 trillion, going over the original budget resolution request of $1.889 trillion. Unfortunately, the overage of $67 billion will need to be removed in order to pass the relief package per budget reconciliation rules. It is unclear at this point where those cuts will be made. For housing concerns, it is vital that people continue to reach out to NC’s delegation to ensure that housing resources remain in the final bill. 

At this time, Congress appears on-track to pass additional relief by mid-March. Assuming the bill moves to the Senate, there will not be any committee markups in that chamber. The bill will move straight to the floor and Senators have agreed to 20 hours of debate. Again, vigilance will be necessary to ensure that housing provisions remain included in the bill.

Sign-On Letter to Extend, Strengthen, and Enforce CDC Eviction Moratorium
The CDC eviction order is currently set to expire on March 31. While the Biden administration recently directed federal agencies to extend the foreclosure moratorium and forbearance period, the duration of the moratorium on evictions was left out of that directive. While the CDC, under new leadership, has been collecting feedback on evictions, they have yet to make any additional changes to extend, strengthen, or enforce the moratorium. The National Low Income Housing Coalition (NLIHC) has reopened a sign-on letter for those who support the need to enhance and extend the moratorium. The Coalition, as one of NLIHC’s State Partners, has signed onto the letter previously. Those who would like to sign-on can do so here.

Controversial USICH Director Removed
Robert Marbut was removed from his post as Executive Director of the United States Interagency Council on Homelessness (USICH) on February 16. Marbut was appointed in 2019 by the Trump administration to lead the agency. The appointment is controversial amongst housing and homelessness advocates because of his publicly stated policy approach. Instead of the “Housing First” perspective that most advocates now agree is vital to eliminating homelessness, Marbut espouses  “housing fourth” and believes that people must “earn” their right to shelter. For some history on homelessness policy, please listen to the recording of our Housing Call featuring Debra Susie of the NC Coalition to End Homelessness.


Consumer Finance Protection Bureau – Help for homeowners and renters

National Women’s Law Center – Fact Sheet on Gender and Racial Justice in Housing

Urban Institute – Community Voice Is Expertise

Center on Budget Policy Priorities – Housing Assistance in House COVID Bill Would Prevent Millions of Evictions, Help People Experiencing Homelessness

Urban Institute – How Policymakers Can Ensure the COVID-19 Pandemic Doesn’t Widen the Racial Wealth Gap

USA Today – COVID crisis: Laid off and evicted, more people make cars their home

Recommended read

2021 Legislative Agenda

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