CLPHA Advocacy

CLPHA supports the nation’s largest and most innovative housing authorities by advocating for the resources and policies they need to solve local housing challenges and create communities of opportunity. We frequently champion our members' issues, needs, and successes on the Hill, at HUD, and in the media. In these arenas CLPHA also advocates for legislation and policies that help our members, and the public and affordable housing industry as a whole, strengthen neighborhoods and improve lives.

Click below for links to congressional testimonies, statements for the record, action alerts, comments to HUD and other federal agencies, and the latest information about CLPHA's multi-pronged housing advocacy.

Action Alerts

7.11.25

ACTION ALERT: Urge Your Member of Congress to Fully Fund Rental Assistance

CLPHA, Industry Partners and Over 700 National, State and Local Organizations Send Letter Asking Congress to Fully Fund Rental Assistance

CLPHA urges our members to work with your representatives in the House and Senate to fully fund rental assistance. The House of Representatives is set to unveil their Transportation, Housing and Urban Development, and Related Agencies (THUD) Fiscal Year 2026 (FY26) bill next week, despite the House not releasing their total funding request.

What’s at Stake?

Critical affordable housing programs that help millions of households afford a place to live and maintain housing stability.

How Can You Help?

Share Two Important Materials with your Members of Congress:

Joint Industry Letter: This morning, CLPHA joined industry partners and over 700 national, state, and local organizations in sending a letter to Congress advocating for full funding of the Housing Choice Voucher program, project-based rental assistance, and continued assistance for Emergency Housing Voucher households. This letter is in response to the administration’s proposal to convert several federal rental assistance programs into a State Rental Assistance Program block grant, which would greatly destabilize the voucher program and put many families at risk of losing their housing assistance.
Joint Funding Request: Earlier this week, CLPHA and industry group partners sent a joint funding request that fully funds rental assistance to the House Appropriations Committee.

Stay on Top of the Appropriations Process

The House Appropriations THUD Subcommittee will meet on Monday, July 14 at 5:00 p.m. ET to consider the legislation. The House Appropriations Full Committee will then meet on Thursday, July 17 at 10:00 a.m. ET to consider the THUD legislation. The Senate is expected to release their bill and hold their markup shortly after the House. A markup is a formal meeting scheduled for members to review and provide amendments to their version of the bill before it is sent to the full chamber for a vote.

CLPHA will continue to monitor the 2026 appropriations process as it proceeds and will update members about key developments.

For questions, contact Madeline Morris, mmorris@clpha.org, or Cynthia Cuestas, ccuestas@clpha.org.

7.8.25

ACTION ALERT: Urge Your Member of Congress to Fully Fund Rental Assistance In 2026 Federal Government Budget

Share CLPHA’s Budget Request before House Appropriations Committee Meets Next Week

The House of Representatives is set to unveil their Transportation, Housing and Urban Development, and Related Agencies (THUD) Fiscal Year 2026 (FY26) bill next week, despite not releasing the total amount of funding to be requested. CLPHA and our industry group partners have generated a joint funding request that fully funds rental assistance. We urge CLPHA members to share our joint FY26 HUD budget request to their representatives in both the House and Senate as Congress moves forward with the Appropriations process.

In response to President Trump’s FY26 budget proposal released last month, CLPHA, the Public Housing Authorities Directors Association, the National Association of Housing and Redevelopment Officials, the Local Housing Administrators Coalition, and the MTW Collaborative released our joint FY26 funding recommendations for HUD. Among other requests, we urge HUD to fully fund the Public Housing Fund, including $5 billion for the Capital Fund, $5.72 billion for the Operating Fund, and $580 million to address the Operating Fund shortfall. Furthermore, we requested $300 million for the Choice Neighborhoods Initiative, $37.487 billion for Housing Choice Voucher (HCV) Renewals, $3.622 billion for HCV Administrative Fees, and $500 million for Tenant Protection Vouchers.

House Appropriations Subcommittee on THUD will meet on Monday, July 14 at 6:00 p.m. ET to consider the legislation. The full House Appropriations Committee will then meet on Thursday, July 17 at 10:00 a.m. ET. The Senate is expected to release their bill and hold their markup shortly after the House. A markup is a formal meeting scheduled for members to review and provide amendments to their version of the bill before it is sent to the full chamber for a vote. The House and Senate Appropriations Committees held their FY26 HUD budget hearings last month. The House and Senate are now working to release their own FY26 THUD appropriations bills.

CLPHA will continue to monitor the 2026 appropriations process as it proceeds and will update members about key developments.

1.28.25

URGENT: Contact Your Members of Congress to Communicate How the Pause in Federal Funding Is Impacting Your PHA

Yesterday, the Office of Management and Budget (OMB) published a memorandum, which directs all federal agencies to pause all “federal financial assistance” (FFA) "to the extent permissible under applicable law." The temporary pause in funding will become effective on January 28, 2025 at 5:00 p.m. ET.

According to news reports, OMB distributed a questionnaire to federal agencies this morning asking them to provide information about whether their programs are in compliance with the Trump administration’s policy goals and executive orders. OMB’s questions for agencies concern undocumented immigration, environmental and climate justice programs, and diversity, equity, and inclusion policies and initiatives.

Capitol Hill staff, HUD staff, advocacy organizations, and other stakeholders appear uncertain about how the memo will be enforced, which programs are affected, and how long this pause will last.

Housing authorities are reporting that they are locked out of eLOCCS before the 5:00 p.m. deadline. We are investigating if this is a systemwide issue or if it is deliberate. We anticipate that PHAs will be locked out of eLOCCS after 5:00 p.m. ET today.

If you are locked out of eLOCCS, contact your member of Congress and Senators to make sure they are aware of the problem. Congress needs to hear how this pause is disrupting daily operations of public housing authorities.

When speaking with Members of Congress highlight the following points:

Highlight how the pause is affecting your daily operations, especially if you are locked out of eLOCCS. Your Member of Congress/Senator may not understand what exactly what eLOCCS is. Explain that it is the system that allows public housing authorities to access federal funds for key housing programs such as vouchers and public housing.
Highlight the breakdown of residents you serve who will be impacted by the pause: the number of seniors, children, veterans who could lose access to federal housing assistance at your PHA.
Highlight the economic impact that your public housing authority has in your community, such as jobs created, number of private landlords affected, and if the pause would halt any development deals.

Please share the outcome of your conversations with Members of Congress with CLPHA Legislative Manager Cynthia Cuestas at ccuestas@clpha.org.

12.6.24

ACTION ALERT: Contact Your Member of Congress to Support Full Funding for Housing Choice Voucher Renewals in the FY25 Appropriations Bill

7.31.24

ACTION ALERT: TAX BILL EXPANDING HOUSING CREDIT HEADED TO SENATE FLOOR

4.15.24

ACTION ALERT: Urge the Senate to Pass the Tax Relief for American Families and Workers Act of 2024

In February, the House of Representatives passed H.R. 7024, The Tax Relief for American Families and Workers Act of 2024, which received overwhelming bipartisan support. The bill includes two Low-Income Housing Tax Credit (LIHTC) provisions that would restore the 12.5% allocation increase for 2023 to 2025 and lower the 50% bond financing threshold to 30% for Private Activity Bond allocations made in 2024 to 2025. The bill also includes a $33 billion expansion of the Child Tax Credit (CTC) for the next three years. While the CTC in this bill is not as generous as the 2021 provision included in the American Rescue Plan, this expansion and continuation of the program acknowledges that the benefits provided by the CTC should be continued.

The legislation faced various roadblocks in the Senate, including opposition from Senate Finance Committee Chair Mike Crapo (R-ID) due to the CTC provisions included in the bill. However, ongoing discussions are still happening to possibly move the bill forward for a floor vote. We strongly ask that CLPHA members continue to reach out to your Senators and urge them to pass H.R. 7024, the Tax Relief for American Families and Workers Act of 2024.

ACTION:

When asking your Senator to support the Tax Relief for American Families and Workers Act of 2024, mention the importance of, and share your support for, the two LIHTC and CTC related provisions in the bill and ask that the housing provisions are retained in the Senate:

LIHTC provisions:

Restore the 12.5% allocation increase for 2023 – 2025. This allocation increase was initially enacted in 2018 but expired in 2021.
Lower the 50% bond financing threshold to 30% for Private Activity Bond (PAB) allocations made in 2024 – 2025.

CTC provisions:

“Lookback rule” allowing families to use their earnings from the prior year to calculate their credit if they exceed the family’s earnings in the current year.
Increases the maximum refundable amount per child to $1,800 in tax year 2023, $1,900 in tax year 2024, and $2,000 in tax year 2025, along with the inflation adjustment described below.
Adjust the $2,000 value of the child tax credit for inflation in tax years 2024 and 2025, rounded down to the nearest $100.

The ACTION Campaign, where CLPHA is a Steering Committee member, has prepared background and advocacy materials about the Tax Relief for American Families and Workers Act of 2024.

2.2.24

ACTION ALERT: Contact the Senate to Pass the Tax Relief for American Families and Workers Act of 2024

On February 1, 2024, the House of Representatives passed H.R. 7024, The Tax Relief for American Families and Workers Act of 2024 which includes two Low-Income Housing Tax Credit (LIHTC) provisions that were also included in the Affordable Housing Credit Improvement Act (H.R. 3238/S. 1557). According to Novogradac, the provisions which would restore the 12.5 percent allocation for 2023-2025 and lower the 50 percent bond financial threshold to 30 percent for 2024-2025, would finance more than 200,000 additional affordable homes.

The bill still needs to be considered by the Senate, which faces several challenges, including a busy legislative agenda for February. Members of the Senate have also floated the idea of scheduling a potential markup of the bill which could potentially amend the legislation and further delay any vote to bring the bill on the Senate floor. The Tax Relief for American Families and Workers Act may also be the last opportunity for Congress to pass any tax related provisions until 2025.

The ACTION Campaign, where CLPHA is a Steering Committee member, has prepared background and advocacy materials about the Tax Relief for American Families and Workers Act of 2024.

ACTION:

We strongly ask that CLPHA members reach out to your Senators and urge them to pass H.R. 7024, the Tax Relief for American Families and Workers Act of 2024.
When asking your Member of Congress to support H.R. 7024, mention the importance and share your support for the two LIHTC related provisions in the bill and ask that the housing provisions are retained in the Senate:
- Restore the 12.5 percent allocation increase for 2023 – 2025. This allocation increase was initially enacted in 2018 but expired in 2021.
- Lower the 50 percent bond financing threshold to 30 percent for Private Activity Bond (PAB) allocations made in 2024 – 2025.

For questions or additional information, contact Gerard Holder, CLPHA Legislative Director at gholder@clpha.org. or Cynthia Cuestas, CLPHA Legislative Assistant, at ccuestas@clpha.org.

11.28.22

ACTION ALERT: Ask Congress to Pass a FY23 THUD Funding Bill Before the December 16 Deadline

Congress Needs To Increase Public And Affordable Housing Funding

Background:

The federal government is currently funded under a continuing resolution (CR) that expires December 16 this year. If the government does not take additional action it runs out of money and has to shut down. Given the uncertainty of what will happen in the appropriations process during the next Congress beginning in January, it is critical that the current Congress finish the work already begun and pass a full year FY23 appropriations bill. CLPHA is particularly concerned with the Transportation, Housing and Urban Development, and Related Agencies (THUD) proposed legislation currently in final negotiations between the House and Senate.

CLPHA and industry partners recently sent a letter and revised joint appropriations request to the leadership of the House and Senate appropriations committees asking for specific funding levels and authorizing language be included in the final THUD appropriations bill. Among our requests, we ask Congress to increase funding for the HUD defined shortfalls in the public housing operating fund program to $345 million to accommodate all eligible housing authorities. We ask the committees to accept the Senate-proposed level of $364 million in set-aside funding for tenant protection vouchers (TPVs) since HUD recently indicated that the current demand for TPVs has exceeded its initial projections for FY23 and they again anticipate not being able to fund replacement TPVs for vacant units in calendar year 2023 without additional funding. We also ask that HUD be directed to determine the impact of recent changes to the calculation of FY23 Fair Market Rents (FMRs), because of the recent extension of regulatory waivers increasing payment standards up to 120 percent of the FMR in local housing markets affecting the need for additional housing assistance payments (HAP) set-aside funding.

ACTION:

CLPHA is calling on members to:

1) Ask your Members of Congress to support the recommendations included in the public housing industry joint funding request and joint industry letter.

2) Ask your Members of Congress to support the THUD funding bill.

3) Ask your Members of Congress to support final passage of a full-year FY23 appropriations bill.

For questions or additional information, contact Gerard Holder, CLPHA Legislative Director at gholder@clpha.org.

7.12.22

ACTION ALERT: Urge Congress to Reinsert Annual Contributions Contract (ACC) Language in the FY 2023 HUD Appropriations Bill

BACKGROUND:

CLPHA and our industry partners today sent a letter (and attachments Exhibit 1 and Exhibit 2) to House and Senate Appropriations Committee members asking to include legislative language that prevents HUD from implementing unilateral changes to the ACC in the forthcoming FY23 appropriations bill. This joint industry request was made by CLPHA, the MTW Collaborative, the National Association of Housing and Redevelopment Officials (NAHRO) and the Public Housing Authorities Directors Association (PHADA).

CLPHA and our industry partners remain concerned that HUD’s continued attempts to revise the ACC will circumvent the Administrative Procedure Act (APA), unilaterally change the contractual relationship between HUD and public housing agencies (PHAs), and strip PHAs of their ability to challenge HUD’s breach of contract actions, which PHAs have recently successfully litigated. Without the inclusion of the legislative language mentioned in our letter, we are concerned that HUD’s ability to make problematic changes to the ACC has been renewed.

This week the full House passed six appropriations bills including its version of the FY23 HUD bill. Since the Senate has not yet taken action on their bill version, we hope to have the ACC language included in the Senate bill, and we are seeking eventual conference committee action between the House and Senate to include the ACC language and committee report language.

ACTION:

We are asking housing authorities to sign and send a similar letter asking their representatives in both the House and Senate to reinstate the legislative language regarding the ACC in the General Provisions section of the FY23 HUD appropriations legislation.

We’ve drafted a sample letter as a guide for you.

Download the Letter Template

Once you’ve downloaded the sample letter, fill out the highlighted fields and personalize the letter as appropriate.
We recommend that you email the letter(s) to your representatives.

If you have any questions, contact Gerard Holder, CLPHA Legislative Director, at gholder@clpha.org.

CLPHA Recent Comments

10.6.25

CLPHA Submits Comments on FY26 Fair Market Rents

9.15.25

CLPHA and Reno & Cavanaugh Oppose HUD’s Plan to Add Personal and Citizenship Information to HUD Records as a Violation of the Privacy Act

8.11.25

CLPHA, Reno & Cavanaugh Ask HUD for Reforms to Section 18 Program

Request Greater Flexibility for PHAs to Manage Portfolio

3.3.25

CLPHA Calls for Reform of Long-Term Costs for Affordable Housing Developers

10.15.24

CLPHA Comments on Choice Neighborhoods Program

Comments Call for Aligning CN Requirements with Other Programs, Streamlining Application to Fit Typical Development Processes

6.17.24

CLPHA Submits Final Comments on Reducing Barriers to HUD-Assisted Housing Proposed Rule

CLPHA, along with Reno & Cavanaugh PLLC,

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View All CLPHA Comments

Latest News

3.3.26

HUD Revokes Requirement of 30-Day Notification Prior to Lease Termination for Nonpayment Effective March 28, 2026

CLPHA Supports Revocation in HUD Statement

HUD recently published an Interim Final Rule in the Federal Register that will revoke the 30-day notification requirement prior to termination of lease for nonpayment of rent. Regulatory requirements for notice of termination for nonpayment of rent will return to pre-2021 requirements, which range from 5 days to 30 days for HUD programs and depend on state and local laws. Additionally, this interim final rule removes provisions requiring PHAs and owners to include certain information in their notice to tenants of lease termination for nonpayment of rent.

This Interim Final Rule will go into effect on March 28, 2026. Once this Interim Final Rule is effective, programs will return to the following notification timelines consistent with pre-2021 regulations:

Program

Timeline

Public Housing

24 CFR 966.4

Non-payment notice: In the case of termination for nonpayment of rent, a PHA shall provide at least 14 days' written notice.

Project-based Rental Assistance (includes Section 202 and Section 811)

24 CFR 247.4(c)

Non-payment notice: For termination for nonpayment of rent, a termination notice must be provided with enough advance time to comply with both the rental agreement or lease and State laws.

Other good cause notice: For termination of tenancy for “other good cause,” HUD regulations require 30 days' notice along with the provision of specific information to the tenant.

Project-Based Section 8 (includes Section 8 New Construction)

24 CFR 880.607(c)(2);

24 CFR 247.4(c)

Non-payment notice: For termination for nonpayment of rent, the time of service must be in accordance with the lease and State law.

Other good cause notice: For termination of tenancy for “other good cause,” HUD regulations require 30 days' notice along with the provision of specific information to the tenant

Section 8 Moderate Rehabilitation

24 CFR 882.511(d)(1)(i)

Non-payment, notice: 5 working days’ notice required before tenancy termination for non-payment

CLPHA and Reno & Cavanaugh previously gathered feedback from members and submitted public comments on the 30-day notification requirement.

In HUD’s statement announcing the revocation, CLPHA CEO La Shelle Dozier said, “CLPHA appreciates HUD’s action to revoke the federal regulations that required PHAs to provide 30 days’ notice prior to termination for nonpayment. While research shows that PHAs make every effort to avoid terminating residents, the 30-day notice requirement creates unnecessary administrative burdens and additional liabilities for PHAs. Revoking this requirement restores state and local authority over eviction notification procedures and returns to the standard notification requirements that existed prior to the implementation of those regulations.”

View Interim Final Rule

2.25.26

HUD Estimates 2026 HCV Funding Will Not Cover Expected Shortfall of Approximately $700 Million

HCV HAP Proration Set at 99%

Yesterday, HUD shared with CLPHA and industry stakeholders that 2026 HCV funding will not cover the expected shortfall of approximately $700 million. The increased shortfall amount is driven by per-unit costs that continue to outpace rental market inflation as measured by Renewal Funding Inflation Factors (RFIFs) despite a relatively high HCV HAP proration of 99% under the recently passed 2026 appropriations bill.

The HCV shortfall confirmation follows two letters HUD has sent to PHA executive directors. The first in December 2025 and the second was sent last week on February 18. The letters are directing PHAs to immediately implement cost-saving measures to address anticipated shortfalls in the HCV program.

The February 18 letter confirms that 2026 HAP funding will be distributed in the spring after HUD reconciles 2025 Voucher Management System (VMS) data. In the meantime, HUD is strongly encouraging all PHAs to consider the following cost-saving measures to prevent terminations of assistance as HUD expects that the HCV HAP funding renewal funding may not be enough to fully support every HCV participant.

Cease issuance of new vouchers (with the exception of HUD-VASH vouchers and Foster Youth to Independence (FYI) vouchers)
Pause entering into new project-based voucher agreements and commitments (with the exception of public housing repositioning efforts)
HUD strongly encourages PHAs to consider the most cost-effective methods of responsibly repositioning, including the Section 18 program
Reduce payment standards, including ending the use of any approved exception payment standards, and remain within the basic range except for reasonable accommodations, as necessary
Assess rent reasonableness policies and procedures to ensure compliance with statutory and regulatory requirements
Adopt other cost savings measures in PIH Notice 2025-28

PHAs that received shortfall awards in 2025 remain subject to their Action Plans with HUD's Shortfall Prevention Team and may not issue vouchers outside of the very limited circumstances those plans allow. HUD's SPT will follow up with 2025 shortfall PHAs after funding allocations are released to reassess their risk status. HUD has also confirmed it will conduct statutory offsets of excess reserves for both MTW and non-MTW agencies in 2026.

HUD Offers Technical Assistance

HUD is offering technical assistance throughout 2026 to help PHAs with budget planning. PHAs experiencing per-unit cost inflations that outpace their RFIFs are especially encouraged to reach out for technical assistance. Requests can be submitted to shortfallinquiries@hud.gov.

Feb. 18 Letter to Executive Directors

Dec. 22 Letter to Executive Directors

PIH Notice 2025-28

2.19.26

CLPHA and Reno & Cavanaugh Urge HUD to Rescind Disparate Impact Proposed Rule

Proposed Rule Would Create Regulatory Vacuum and Increase PHAs’ Operational Complexity and Legal Risk

CLPHA and Reno & Cavanaugh urged HUD to repeal its proposed rule on the implementation of the Fair Housing Act’s disparate impact standard in comments submitted last week.

The disparate impact standard under the Fair Housing Act is a legal framework used to evaluate policies that are neutral on their face but have a discriminatory effect on a protected class (such as race, national origin, disability, sex, religion, or familial status). Notably, disparate impact does not require proof of intentional discrimination. Instead, it focuses on whether a policy or practice results in unequal outcomes.

CLPHA and Reno & Cavanaugh oppose the proposed rule because it creates a regulatory vacuum that increases both operational complexity and legal risk for PHAs. The primary concerns include:

By rescinding a national standard for disparate impact claims without providing a replacement, HUD removes vital regulatory guidance. This leaves PHAs, developers, and housing providers exposed to increased litigation risk and inconsistent legal interpretations.
The rulemaking process is viewed as a violation of the Administrative Procedure Act. HUD's justifications are deemed inadequate, and the abbreviated public comment period denies stakeholders the necessary time to fully evaluate the rule's significant operational and financial impacts.
Instead of offering clarity, the proposal complicates compliance, potentially driving up costs and creating administrative confusion across the housing sector.

For questions about our comments, contact Madeline Morris, mmorris@clpha.org.

Read Our Comments

Read the Proposed Rule