Annual Meeting & Member QAP

The OCAH Annual Meeting will be held on July 15, immediately following the OHFA Board of Trustees Meeting. Be sure to mark your calendar and join us as we celebrate the Coalition’s 5 Year Anniversary.

Immediately following the Annual Meeting, OCAH will hold the annual QAP Meeting for VOTING MEMBERS only. Registration will open next week for both events. Please direct any questions to ocah@outlook.com

Please read our updated Covid-19 Event Policy below for the Annual Meeting.  

Location of Meeting

Oklahoma Coalition for Affordable Housing Event Policy re. Covid-19

Due to Covid-19, our new on-site event rules are clear and the expectation is as follows:

  • No Handshakes. We understand that other events “recommend” no handshakes, but we have decided to simply have a firm No Handshakes rule at the Annual Meeting. Yes, it may feel a bit strange at first and you will see No Handshakes signs around. However; our first priority is the health and wellness of our attendees.
  • Please be courteous to other attendees and keep a minimum of 3 feet apart.
  • We require you to wear a Face-mask (except when you are eating).
  • Wash, Wash, Wash. Please wash your hands before entering the event. Please wash your hands at every possible opportunity. Hand sanitizer will be provided, but washing your hands is preferred if possible.
  • Tables will be seated with 4 chairs instead of 8.
  • Lunch will be plated and served instead of buffet style.

Thank you for your understanding and helping us ensure the safest, healthiest way to hold our Annual Meeting in person on July 15, 2020. The OCAH Event Policy Re. Covid-19 can and will be revised and updated periodically based on current best practices and information.

Please note that Important Health & Safety Rules will be periodically updated here, on the OCAH website and via email.

Please contact the Andrea Flowers-Householter, Coalition Manager, should you have any questions. Email her at ocah@outlook.com.

2020 Annual Meeting Sponsors: Please contact Andrea Flowers-Householter at ocah@outlook.com if you did not receive an email from Cvent regarding registering employees/staff with your comp tickets for the Annual Meeting.

Thank You to the 2020 Coalition Sponsors:

Oklahoma Housing Conference Presenting Sponsor

Premier Event Sponsors

Diamond Event Sponsors

Platinum Event Sponsors

Silver Event Sponsor

Bronze Event Sponsors

Friend Event Sponsors

CFPB Proposes to Remove DTI Limit and Implement Price Thresholds for QM Loans

The Consumer Financial Protection Bureau (CFPB) on Monday released a proposed rule amending its Ability-to-Repay/Qualified Mortgage (ATR/QM) underwriting guidelines. The proposal rescinds the 43 percent debt-to-income (DTI) ratio limit loans must meet to qualify as Qualified Mortgages (QMs) and creates a new price-based threshold for QM loans.

The ATR/QM rule, which took effect in January 2014, outlines the steps mortgage originators must take to obtain and verify information to determine whether a consumer can afford to repay a mortgage. It also establishes a set of criteria a mortgage loan must meet to be considered a “qualified mortgage.” If a mortgage loan meets the QM criteria, the originator is presumed to have complied with the requirements of the ATR rule. HFA program loans are exempt from the ATR/QM rule requirements.

The proposed rule repeals a provision of the ATR/QM rule requiring, for a loan to qualify as a QM, the consumer to have a total debt payments-to-income ratio (including payments on other obligations besides the mortgage) of no more than 43 percent. Instead, the rule would require that QM loans have an annual percentage rate (APR) that is less than two percent higher than the average prime offer rate (APOR) for the market. The limit would be higher for smaller loans, with loans under $69,939 requiring an APR less than 6.5 percent over APOR, and loans under $109,898 limited to less than 3.5 percent over APOR. The APR for subordinate liens would also be set at less than 3.5 percent over APOR.

CFPB says it is enacting these changes because it does not believe a borrower’s DTI is a strong indicator of their ability to repay their mortgage and such a strict DTI limit could reduce access to credit for creditworthy borrowers, particularly low- and moderate-income individuals and minorities. It includes in the proposed rule the results of its internal analysis which it says shows there is a stronger correlation between loan price and performance, as measured by early delinquencies.

The proposed rule says lenders must continue to consider a borrower’s DTI ratio or residual income when examining their ability to repay their mortgage. It also eliminates Appendix Q of the ATR/QM rule, which prescribed the standards and procedures lenders are supposed to use when determining a borrower’s monthly debt and income. Many industry participants say Appendix Q is too rigid and tough to understand. In its place, the proposed rule would allow lenders to use various income standards specified by CFPB, including those used by Fannie Mae, Freddie Mac, and the Federal Housing Administration.

CFPB is proposing these changes to respond to the upcoming expiration of the “GSE Patch,” a provision of the ATR/QM rule that automatically qualifies as QMs all loans approved through either Fannie Mae’s or Freddie Mac’s underwriting systems, regardless of whether they meet the 43-percent DTI limit. Because of the GSE Patch, lenders have been able to originate many QM loans in recent years that otherwise would not have qualified. According to an analysis conducted by the Urban Institute, nearly 3.3 million loans over the past five years have qualified as QM because of the GSE Patch, accounting for nearly one-fifth of Fannie Mae’s and Freddie Mac’s guaranteed loans during that time period.

The GSE Patch is set to expire January 10, 2021, raising concerns that many creditworthy borrowers, particularly low- and moderate-income borrowers and borrowers of color, would lose access to affordable home loans. CFPB estimates the GSE Patch expiration could impact nearly one million loans next year. The agency issued an Advance Notice of Proposed Rulemaking (ANPR) last summer seeking industry input on potential revisions to the ATR/QM rule in light of the patch’s expiration.

In its comments on the ANPR, NCSHA urged CFPB to repeal the DTI threshold, arguing it could severely curtail home financing options for low- and moderate-income and other underserved borrowers. Also, while HFAs are exempt from the ATR/QM rule, they represent a small share of the market, making it likely that Fannie Mae, Freddie Mac, and other HFA partners would simply adjust their underwriting standards so they would not approve or underwrite any loans with a DTI above 43 percent, to avoid any possible liability.

CFPB also issued a second proposed rule on Monday extending the GSE Patch until the other proposed rule takes effect. The CFPB anticipates any changes to the ATR/QM rule will not be implemented until six months after a final rule is published, a timeline CFPB does not expect to be completed until at least April 1, 2021. CFPB proposes to maintain the GSE Patch in the interim to avoid market disruption.

CFPB will be seeking comment on both proposed rules for 60 days after they are published in the Federal Register, which is expected shortly. NCSHA will be submitting comments on behalf of state HFAs.

Senators Wyden and Cantwell Introduce Legislation Paralleling Housing Credit Provisions in House Infrastructure Bill

Yesterday, Senate Finance Committee Ranking Member Ron Wyden (D-OR) and Senator Maria Cantwell (D-WA) introduced standalone Senate companion legislation to the Housing Credit provisions included in the Moving Forward Act (H.R. 2), the infrastructure legislation released in the House earlier this week. The bill, the Emergency Affordable Housing Act of 2020, does not have a bill number at this time; however, the bill text, a one-page summary, and a more detailed summary are all available.

Like the Moving Forward Act, the Emergency Affordable Housing Act of 2020 would:

  • permanently increase the annual Housing Credit authority from $2.81 per capita to $4.56 per capita, and increase the small state minimum from $3,217,500 to $5,214,051, both phased in over two years;
  • set a permanent minimum 4 percent rate for tax-exempt bond-financed properties;
  • lower the “financed-by” threshold for tax-exempt bond financing necessary to trigger the 4 percent Credit from 50 percent to 25 percent;
  • establish new 30 percent basis boosts for properties in rural and Indian areas and for bond-financed properties for which the state agency determines a basis boost is needed for financial feasibility;
  • establish a new 50 percent basis boost for properties in which at least 20 percent of the units are reserved for and affordable to extremely low-income (ELI) households (the basis boost would be available proportionally based on the percent of ELI units in the property);
  • provide states an increase of 10 percent above their annual Housing Credit ceiling to finance properties receiving the aforementioned ELI basis boost;
  • temporarily extend the 10 percent test and placed-in-service deadlines by 12 months, applicable to properties that receive an allocation of Credits between December 31, 2016, and January 1, 2022;
  • temporarily extend the rehabilitation expenditure deadline by 12 months, applicable to properties that receive an allocation of Credits between December 31, 2016, and January 1, 2022;
  • repeal the “Qualified Contract” provision in the tax code that allows owners to terminate the affordability restrictions on a property before the end of the property’s extended use period for properties that receive an allocation of Credits after January 1, 2020; and for existing properties, modify the Qualified Contract price to base it on fair market value as restricted;
  • prohibit requirements for local approval or local contributions as a condition of receiving Credits and remove the requirement that state agencies notify the local elected officials in areas in which a proposed building would be located;
  • establish a taxpayer election to receive an accelerated 150 percent first-year credit to offset delays resulting from the COVID-19 crisis;
  • create a new 25 percent tax credit for contributions to a qualified, supportive housing reserve fund for Housing Credit properties.

Many of the bill’s provisions are NCSHA legislative priorities, included in either the Affordable Housing Credit Improvement Act or the Save Affordable Housing Act. Others are priorities NCSHA has adopted as a result of the COVID-19 pandemic. NCSHA worked closely with Senator Wyden’s and Senator Cantwell’s staffs and with their counterparts on the House Ways and Means Committee on crafting the legislation.

Annual Meeting & Member QAP 2020

The OCAH Annual Meeting will be held on July 15, immediately following the OHFA Board of Trustees Meeting. Be sure to mark your calendar and join us as we celebrate the Coalition’s 5 Year Anniversary.

Immediately following the Annual Meeting, OCAH will hold the annual QAP Meeting for VOTING MEMBERS only. Registration will open next week for both events. Please direct any questions to ocah@outlook.com

Please read our updated Covid-19 Event Policy below for the Annual Meeting.  

Location of Meeting

Oklahoma Coalition for Affordable Housing Event Policy re. Covid-19

Due to Covid-19, our new on-site event rules are clear and the expectation is as follows:

  • No Handshakes. We understand that other events “recommend” no handshakes, but we have decided to simply have a firm No Handshakes rule at the Annual Meeting. Yes, it may feel a bit strange at first and you will see No Handshakes signs around. However; our first priority is the health and wellness of our attendees.
  • Please be courteous to other attendees and keep a minimum of 3 feet apart.
  • We require you to wear a Face-mask (except when you are eating).
  • Wash, Wash, Wash. Please wash your hands before entering the event. Please wash your hands at every possible opportunity. Hand sanitizer will be provided, but washing your hands is preferred if possible.
  • Tables will be seated with 4 chairs instead of 8.
  • Lunch will be plated and served instead of buffet style.

Thank you for your understanding and helping us ensure the safest, healthiest way to hold our Annual Meeting in person on July 15, 2020. The OCAH Event Policy Re. Covid-19 can and will be revised and updated periodically based on current best practices and information.

Please note that Important Health & Safety Rules will be periodically updated here, on the OCAH website and via email.

Please contact the Andrea Flowers-Householter, Coalition Manager, should you have any questions. Email her at ocah@outlook.com.

2020 Annual Meeting Sponsors: Please contact Andrea Flowers-Householter at ocah@outlook.com if you did not receive an email from Cvent regarding registering employees/staff with your comp tickets for the Annual Meeting.

Thank You to the 2020 Coalition Sponsors:

Oklahoma Housing Conference Presenting Sponsor

Premier Event Sponsors

Diamond Event Sponsors

Platinum Event Sponsors

Silver Event Sponsor

Bronze Event Sponsors

Friend Event Sponsors

House Infrastructure Package Includes Housing Credit and Housing Bond Priorities

Yesterday, the House released bill text for its infrastructure package, The Moving Forward Act, H.R. 2, which includes an expansive section to strengthen and expand the Low-Income Housing Tax Credit (Housing Credit).

Housing Credit & Housing Bond Provisions

The Moving Forward Act includes all of the ACTION Campaign’s legislative priorities for Covid-19 relief, such as a permanent 4 percent Housing Credit rate, as well as several priorities that ACTION partners have been pursuing through regulatory relief. Many of the provisions are also based on those in the bipartisan Affordable Housing Credit Improvement Act (AHCIA), S.1703 and H.R.3077, and other provisions are new Housing Credit proposals. The Moving Forward Act also includes provisions related to multifamily housing bonds (Housing Bonds).

  • Sec. 90601. Extension of period for rehabilitation expenditures (page 2254). Extends the rehabilitation expenditure deadline by 12 months (from 24 to 36 months) for projects receiving an allocation after December 31, 2016 and before January 1, 2022. As proposed in NCSHA letter to IRS.
  • Sec. 90602. Extension of basis expenditure deadline (page 2254). Extends the 10 percent expenditure rule deadline by 12 months (from 12 to 24 months) after the date of allocation for projects receiving a Housing Credit allocation after December 31, 2016 and before January 1, 2022. As proposed in NCSHA letter to IRS.
  • Sec. 90603. Tax-exempt bond financing requirement (page 2256). Lowers the “50 percent” threshold for tax-exempt bond financed developments to qualify for the 4 percent Housing Credit to 25 percent for buildings placed in service in 2020 and 2021. This is based on an ACTION priority for Covid-19 response.
  • Sec. 90604. Minimum credit rate (page 2256). Sets a permanent minimum 4% Housing Credit rate for tax-exempt bond financed developments, effective for buildings placed in service after December 31, 2019. This is an ACTION priority for Covid-19 response and based on a provision from the AHCIA.
  • Sec. 90605. Increases in State allocations (page 2257). Makes permanent the temporary 12.5 percent increase in Housing Credit allocation authority enacted in 2018 and increases the annual Housing Credit allocation authority and small state caps, phased-in over two years, by 27 percent in 2021 and by 62 percent after that. This is a similar to an ACTION priority for Covid-19 relief and a provision in the AHCIA.
  • Sec. 90606. Increase in credit for certain projects designated to serve extremely low-income households (page 2258). Provides a 50 percent basis boost for the portion of properties serving extremely low-income (ELI) households (available to properties where 20 percent or more of the units are designated for ELI households). It also provides a 10 percent increase in state Housing Credit allocations for these properties. The basis boost portion of this provision is in the AHCIA.
  • Sec. 90607. Inclusion of Indian areas as difficult development areas for purposes of certain buildings (page 2260). Provides developments in Indian areas with a 30 percent basis boost by defining Indian areas as difficult development areas (DDAs); effective for buildings placed in service after December 31, 2019. This is an ACTION priority for Covid-19 response and based on a provision from the AHCIA.
  • Sec. 90608. Inclusion of rural areas as difficult development areas (page 2262). Provides developments in rural areas with a 30 percent basis boost by defining rural areas as difficult development areas (DDAs); effective for buildings placed in service after December 31, 2019. This is an ACTION priority for Covid-19 response and based on a provision from the AHCIA.
  • Sec. 90609. Increase in credit for bond-financed projects designated by housing credit agency (page 2263). Enables state housing agencies to provide a 30 percent basis boost as needed for properties financed by Housing Bonds. This is an ACTION priority for Covid-19 response and based on a provision from the AHCIA.
  • Sec. 90610. Repeal of qualified contract option (page 2263). Repeals the qualified contract option for properties which receive Housing Credit allocations after December 31, 2019, and modifies the qualified contract pricing on existing properties (receiving Housing Credit allocations before January 1, 2020) to be fair market value as determined by housing credit agencies. This is based on the Save Affordable Housing Act (S.1956/H.R.3479).
  • Sec. 90611. Prohibition of local approval and contribution requirements (page 2266). Prohibits the consideration of local or elected official support or opposition or local government contributions in Qualified Allocation Plans. This is based on a provision in the AHCIA.
  • Sec. 90612. Adjustment of credit to provide relief during COVID–19 outbreak (page 2267). Provides the option of claiming 150% of otherwise allowable credits for the first or second taxable year of a building’s credit period for building’s whose first year in the credit period ends between July 1, 2020 July 1, 2022, which also have construction or leasing delays occurring on or after 1/1/20. The credit boost is recaptured in subsequent years pro rata. This is a new proposal that has emerged in response to Covid-19 to accommodate credit adjuster issues.
  • Sec. 90613. Credit for low-income housing supportive services (page 2269). Creates a new tax credit for investors equal to 25 percent of a qualified supportive housing contribution, with a max contribution amount of $120,000 per low-income unit. This is a new proposal.
  • Sec. 90104. Volume Cap on Private Activity Bonds (page 2124). Increases the ceiling on private activity bond volume cap by nearly 30 percent, thereby allowing states to issue more multifamily Housing Bonds. This is a new proposal.

Additional Affordable Housing Provisions

The Moving Forward Act would also authorize more than $100 billion in affordable housing infrastructure:

  • $70 billion for the Public Housing Capital Fund;
  • $10 billion for Community Development Block Grants (CDBG);
  • $5 billion for the HOME Investment Partnerships Program;
  • $5 billion for the Housing Trust Fund;
  • $2.5 billion for the Capital Magnet Fund;
  • $1 billion for the USDA’s Multifamily Preservation and Revitalization Demonstration program; and
  • $1 billion Native American Housing Block Grant program.

The Housing section of the Moving Forward Act also includes the enactment of the Neighborhood Homes Credit (page 2277), which was first introduced in the Neighborhood Homes Investment Act (H.R. 3316). The Neighborhood Homes Credit is designed to stimulate private investment to build or rehabilitate owner-occupied, single family homes in distressed communities.

What’s Next?

The House is expected to vote on its infrastructure package before the July 4th recess. The Senate may introduce its own infrastructure package; however, it is still considered unlikely for Congress to pass an infrastructure package of this size in the near future. Meanwhile, the Senate continues to consider its response to the House passed HEROES Act, i.e. the next Covid-19 response package, which it is expected to address before the August recess.

The Moving Forward Act will hopefully set a precedent that Housing Credit and Housing Bond provisions should be included in any future infrastructure package, and demonstrates that there is strong Congressional support for our Housing Credit priorities. In addition to advocating for our priorities to be retained through infrastructure package negotiations, the ACTION Campaign will continue to press for the 4 percent Housing Credit rate to be included in the next Covid-19 response package.

Thank you to everyone in the field contributing to these advocacy efforts!

Click here to view the full bill text.

Click here to view the section-by-section summary.

Sixty-Seven Mayors Sign Bipartisan Letter Urging Congress to Include Low-Income Housing Tax Credit Provisions in Next Covid-19 Response Legislation

In a June 1 bipartisan letter to Congress, 67 mayors representing communities across 28 states and the District of Columbia called for the inclusion of the ACTION Campaign’s Low-Income Housing Tax Credit (Housing Credit) priorities in the next Covid-19 response bill. The letter, which was circulated by the Seattle Office of the Mayor and the ACTION Campaign, urges Members of Congress to advance ACTION’s proposals for immediate Housing Credit relief: the enactment of a minimum 4 percent Housing Credit rate and the lowering of the “50 percent test” bond financing threshold for 4 percent Housing Credit developments. The mayors cite the urgent need for affordable rental housing in their cities, particularly in light of the economic downturn in the face of Covid-19, and highlight these proposals as immediate solutions to include in the next round of response legislation.

Enterprise and its ACTION Campaign partners urge affordable housing advocates to share the mayoral sign-on letter with their Members of Congress, particularly members of the Senate, who are likely currently drafting their version of the next response package. Other mayors can still sign-on to the letter, which will be updated on ACTION’s website on a rolling basis. 

House Holds Hearing Examining Impact of Covid-19 on CDFIs and Minority Depository Institutions

Earlier this month, the House Financial Services Subcommittee on Consumer Protection and Financial Institutions held their first virtual hearing to discuss the impact of Covid-19 on Community Development Financial Institutions (CDFIs) and Minority Depository Institutions. The witnesses testified that Congress should modify the PPP to better serve minority-owned small businesses and promote inclusive lending. Speakers also recommended a simpler forgiveness application, suggesting that the current 11-page application is too complex for business owners trying to survive the pandemic. A streamlined forgiveness process for small dollar loans would allow vulnerable communities to get the relief they need. Additionally, the witnesses called for increased appropriations to the CDFI Fund to upgrade their technological capacity and promote financial equity following COVID-19. Included in the House-passed HEROES Act was $1 billion for the CDFI Fund to help prevent, prepare for and respond to the coronavirus. The Senate has not yet put forth proposed language for the next Covid-19 relief package. Click here to watch a recording of the hearing.   

Congress Makes Changes to Paycheck Protection Program

Earlier this month, President Trump signed H.R. 7010, the Paycheck Protection Program Flexibility Act (PPPFA). The bipartisan bill relaxes rules governing the Paycheck Protection Program (PPP), increasing flexibility for loans that are originated under the PPP from this point forward. The bill extends the “covered period” during which businesses must expend their PPP funds, from eight weeks to 24 weeks—although recipients that received PPP loans before the enactment of the legislation may opt to retain the eight-week covered period. The legislation also reduces the proportion of funds that must be spent on payroll in order for the loan to qualify for forgiveness from 75 percent to 60 percent, allowing businesses greater flexibility when deciding how to expend their PPP funds. The legislation makes other changes to the CARES Act, striking a section that prohibited businesses that have their PPP loans forgiven to benefit from the payroll tax deferral provisions in the Act. The PPPFA also extends the loan deferral period authorized in the CARES Act to ten months from the end of the loan’s covered period. Finally, the PPPFA includes a minimum maturity of five years for newly originated PPP loans, and makes changes to exemptions in the CARES Act’s PPP forgiveness provisions to provide forgiveness for businesses that can prove in good faith that they were unable to meet the payroll requirements due to employee unavailability. These changes to the PPP follow two Interim Final Rules (IFRs) issued by the Small Business Administration (SBA) that went into effect May 28. These IFRs provided guidance on PPP Loan Forgiveness and SBA Loan Review Procedures, respectively.

Request your absentee ballot by June 23 for upcoming primary elections

As important primary and special elections approach, Oklahomans have options for exercising their right to vote. Any registered voter in Oklahoma may vote by absentee ballot to avoid the long lines and health concerns that might present themselves on Election Day.

With your name and date of birth, you can request an absentee ballot online using the OK Voter Portal. You can also print an application or learn more about absentee voting at OK.gov/elections. All requests for absentee ballots must be made by 5 p.m. on June 23.

Because of COVID-19, the state enacted new options for absentee voter verification for the June 30 elections. Instead of having your signature notarized or witnessed by two people, you have the option of attaching a copy of your ID to your affidavit envelope instead. Read the instructions for voting by absentee ballot sheet enclosed with your ballot for more information.

Some in-person voters will also have a change of polling location due to the ongoing pandemic. Affected voters will receive a notice in the mail if their polling location has changed, but if you are concerned, consider voting absentee.

The June 30 primary and special elections will include important positions at every level of government, including State Question 802. SQ 802 would allow Oklahomans to vote on Medicaid expansion. If approved, SQ 802 would return more than $1 billion in Oklahoma’s taxpayer dollars to the state so that 200,000 more people would have access to health care.

See a complete list of what races will be on the ballot in Oklahoma, Canadian, Cleveland and Pottawatomie counties.

OHFA HOME and NHTF Update

The 2020 HOME limits have been released. These limits are effective July 1, 2020 and should not be implemented until this date.

The limits can be found by clicking on the links provided below from the HUD Exchange website OR by going to the HOME Implementation Manual

HOME Income Limits in Chapter 8 of the Implementation Manual

HOME Rent Limits in Chapter 8 of the Implementation Manual

The 2020 National HTF limits have been released. These limits are effective July 1, 2020 and should not be implemented until this date.

The limits can be found by clicking on the links provided below from the HUD Exchange website or by going to the NHTF Implementation Manual found here:

NHTF Income Limits in Chapter 7 of the Implementation Manual

NHTF Rent Limits in Chapter 19 of the Implementation Manual