ACTION Recommendations in Response to COVID-19


Correction: Please see the correct ACTION letter here.

Responding to the COVID-19 Crisis

First and foremost, we hope that everyone is taking care to stay healthy. Each day brings new developments, and we are all doing our best to navigate these unchartered waters. There are so many unexpected consequences stemming from the COVID-19 crisis, and that includes threats to the housing stability of millions of low-income Americans.

While the ACTION Campaign will always continue to advocate for the Affordable Housing Credit Improvement Act, we have to be rapidly adaptive and responsive as new challenges arise. As many of you know, the COVID-19 crisis and response measures may – and in some cases already have – result in consequential disruptions in transactions and construction for a variety of reasons including understaffed lenders, suspended site inspections, broken supply chains for materials, and local suspensions on construction. Congress is moving quickly to pass COVID-19 relief packages, and therefore we have to act swiftly to advocate for critical federal actions that can help the stability of the Housing Credit program.

With the help of many of our Steering Committee partners, we quickly identified and developed immediate statutory recommendations for Congress to include in the next COVID-19 relief package. The Housing Credit program has a number of programmatic deadlines required under the Internal Revenue Code that we expect could be difficult or impossible to meet as the pace of development is being slowed down. ACTION urges Congress to provide a one-year extension for three key program deadlines:

  • 10 percent test deadlines. Currently, at least 10 percent of the anticipated basis of a development must be expended within one year of the Housing Credit allocation. We propose temporarily extending this deadline to the end of the second year of allocation for properties that received Housing Credit allocations between December 31, 2016 and January 1, 2022.
  • Placed in service deadlines. Buildings must currently be placed in service by the end of the second year after the calendar year of the Housing Credit allocation. We proposed temporarily extending this deadline to the end of the third year after the calendar year of allocation for properties that received Housing Credit allocations between December 31, 2016 and January 1, 2022.
  • Rehabilitation expenditure deadlines. These are currently required to be placed in service within 24 months. We propose temporarily extending the rehabilitation expenditures deadline to be met at the close of 36-months.

ACTION also recommends that Congress enact a minimum 4 percent Housing Credit rate to bolster future production and preservation of affordable housing. With federal borrowing rates effectively zeroed out in response to COVID-19’s economic impacts, the 4 percent Housing Credit rate is at an all-time low of 3.12 percent, and will likely dip even further next month. Enacting a minimum 4 percent Housing Credit rate would provide parity to the 9 percent Housing Credit rate, for which Congress enacted a minimum rate as part of the response to the 2008 economic collapse in recognition of the critical role of affordable housing in the recovery.

We have sent this ACTION letter to key Congressional offices, as we understand that drafting of the next relief package is well underway. We welcome you to echo these important statutory fixes.

We know the landscape is still changing, that new challenges will emerge, and that there are other important ideas being developed – and we encourage you to share them with us. We will be developing a longer list of statutory asks for future relief packages. We will also be developing a comprehensive list of regulatory asks for the IRS. If you have ideas to share, please email Sarah Brundage at sbrundage and Jennifer Schwartz at jschwartz.

As a reminder, ACTION’s next field call is scheduled for Friday, April 3, at 2 pm EST. We will keep you updated with major developments in the meantime. You can also find updates and resources at the following websites:

Please do not hesitate to reach out to us with other developments, concerns, questions, or suggestions.

HUD Publishes COVID-19 FAQ for Public Housing and HCV Programs

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The Department of Housing and Urban Development has published a new Frequently-Asked-Questions (FAQ) document on COVID-19. The document provides answers to questions related to emergency preparedness, operational concerns, eligible uses of funds, and relocation. Additionally, the document announces a new email address (PIH-COVID) that can be used to contact HUD with additional questions about operating in this new environment. Links to this and other information have been posted to NAHRO’s coronavirus resource page.

HUD’s Office of Public and Indian Housing (PIH) has put out this document to help guide PHA operations and expects the Department to continue updating this guidance and publishing additional guidance as additional operational questions arise.

Keep informed about the COVID-19 event by closely monitoring the Centers for Disease Control and Prevention COVID-19 website.

A letter from PIH and the Office of Multifamily Housing can be found here.

The full FAQ can be found here.

Encourage your residents to fill out the 2020 U.S. Census online

It’s time to fill out the census – are you and your residents ready to be counted? An accurate count of everyone who lives in Oklahoma is extremely important so we ask that you please encourage your residents to fill out the census. Starting March 12, the U.S. Census Bureau mailed out postcards with a code that will allow residents to fill out the census at If you don’t have your code you can still fill out the questionnaire online using your home address. Filling it out online takes under 10 minutes.

The federal government uses census data to allocate billions of dollars for programs like the Low Income Housing Tax Credit, Medicare/Medicaid, transportation funding, federal research and more. The census also determines Oklahoma’s representation in the U.S. House of Representatives.

Every household that does not complete the census will cost our community $1,675 per person every year over the next 10 years. In 2010, Oklahoma had the second-lowest participation rate in the country and an undercount of only 2% could cost our state as much as $1.8 billion in funding.

It is important to remember that individual census data is confidential and won’t be shared. In April, residents will begin receiving the census through the mail.

For more information visit

Please help us ensure that Oklahoma will not be underserved the next decade by encouraging your residents to participate in the 2020 census.

Federal coronavirus actions: What to know about tax changes and other actions

From our Friends at CohnReznick:

What to know about tax changes and other actions from the House’s proposed Families First Coronavirus Response Act, the Treasury, and the SBA
The House of Representatives made technical corrections on March 17 to H.R. 6201, the Families First Coronavirus Response Act, which looks to provide supplemental appropriations to support Americans during the outbreak of COVID-19. The act would provide paid leave to those affected by COVID-19, as well as tax credits to certain employers, food and nutritional assistance, expanded unemployment insurance, and increased funding to health and nutrition programs, and would require certain insurers to fully cover testing and other services related to the virus.

Read on to learn about Treasury updates, provisions Included in The House’s Act, and SBA loans to small businesses impacted by COVID-19.


OHFA March Board of Trustees Meeting Cancelled

The Oklahoma Housing Finance Agency has cancelled the regularly scheduled meeting of Oklahoma Housing Finance Agency’s (“OHFA”) Board of Trustees scheduled for 10:00 a.m. Wednesday, March 25, 2020 at 100 Northwest 63rd, Will Rogers Conference Room, Oklahoma City, Oklahoma has been cancelled as the risk of exposure to COVID-19 continues to increase in Oklahoma and in an effort to protect the public and comply with President Donald Trump’s directive to avoid groups of 10 or more people.

Affordable Housing Day at the Capitol Postponed Indefinitely…

The 2020 Affordable Housing Day at the Capitol has been postponed indefinitely due to the coronavirus.

Beginning today, only elected officials, essential staff, certain state employees and credentialed press will be allowed in the state Capitol building until further notice. Although the building will be closed to the public, legislative leadership indicated they will continue to hold session and continue to build the state’s budget for the upcoming fiscal year.

Additional information about this and other Coalition events will be updated as soon as possible. If you are a sponsor this year, Andrea Flowers-Householter, Coalition Manager, will be in touch with you soon.

Thank you in advance for your understanding during this time. Please email ocah with any concerns or questions.

NLIHC: Housing & Coronavirus Webinar


NLIHC’s Housing and Coronavirus
Legislative Priorities & How to Take Action

Learn what bills NLIHC is tracking and supporting, as well as what more needs to be done immediately by members of Congress to respond to the coronavirus pandemic – and what you can do help move these priorities forward – during a webinar, “NLIHC 2020 Policy Priorities,” tomorrow, March 18, at 2:00 p.m. ET.

The webinar will explore NLIHC’s policy priorities for 2020, including what we need lawmakers to do urgently in response to the pandemic for people experiencing homelessness, extremely low-income renters, and their front-line services and housing providers. While the coronavirus pandemic canceled our Capitol Hill Day in DC next week, members of Congress still need to hear from informed constituents about the importance of accessible, safe, and affordable homes for those most in need and about the need for Congress to take immediate action to stave off a crisis for these people at great risk during the coronavirus outbreak.

Click here to Register
The NLIHC Policy Team will discuss immediate homelessness and housing priorities during the pandemic and other key bills before Congress, as well as the specific requests advocates should make. The NLIHC Field Team will provide resources and tips for ways advocates can take action, including NLIHC’s new Legislative Action Center. The Legislative Action Center will serve as a one-stop-shop for information and advocacy tools you can use to urge your members of Congress to champion affordable housing solutions for the lowest-income people.

If you are interested in advocacy basics, you can watch the recording of NLIHC’s March 5 webinar on the fundamentals of advocacy and lobbying at: