The Spring Street Brief

Spring Street Management Group
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The Spring Street Brief is your daily intelligence briefing on affordable housing in America. In under 3 minutes, get the news that matters: LIHTC allocations, Section 8 voucher updates, HUD policy changes, private activity bonds, state housing finance agency deals, and emerging trends in affordable housing development. Designed for LIHTC investors, affordable housing developers, syndicators, lenders, and policy makers who need to stay ahead of the curve. AI-powered. Human-curated. Brought to you by Tom Carter at Spring Street Management Group.

  1. 6h ago

    Episode 116: HUD Moves to Rescind FFRMS Flood Standards

    HUD has proposed a rule to rescind the Federal Flood Risk Management Standard (FFRMS) final rule and its associated regulations, originally published in April 2024. The proposed rule would restore HUD's Part 55 floodplain management regulations to their pre-April 2024 state — removing the elevated site elevation and freeboard requirements that affected HUD-assisted and HUD-insured projects in or near floodplains. For LIHTC developers relying on FHA-insured debt or other HUD program dollars, the proposal would reduce site selection friction and eliminate costly engineering requirements triggered by the 2024 rule. Comments are due September 8, 2026. Key Takeaways: HUD's proposed rule targets the FFRMS final rule published in April 2024 — a full rescission of its elevated flood hazard standards. HUD's Part 55 floodplain management regulations would generally revert to their pre-April 2024 state. Flexibilities related to floodways, categorical exclusions, exemptions from Part 55 applicability, and the decision-making process would be preserved — not rescinded. Deals using FHA 221(d)(4) or 223(f) financing on sites near Special Flood Hazard Areas are directly affected — reduced elevation and freeboard requirements lower development cost and complexity. Developers and syndicators with deals in the pipeline structured around FFRMS requirements should revisit site engineering assumptions with environmental counsel. The public comment period closes September 8, 2026 — state HFAs, syndicators, and developers have a direct opportunity to shape the final rule. The proposed rule represents a broader rollback of Biden-era climate risk standards embedded in HUD program requirements. This proposal is a significant policy reversal with real deal-level implications. For teams active in HUD-insured lending or layering HUD grants into LIHTC transactions, now is the time to assess how the FFRMS has affected your underwriting and site selection — and whether the retained flexibilities adequately address floodplain risk management going forward. Engaging in the comment process before September 8 is the clearest way to influence the final outcome. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  2. 1d ago

    Episode 115: Ohio OHFA Opens 9% LIHTC QAP Technical Amendment Comment

    The Ohio Housing Finance Agency (OHFA) has opened a public comment period on the first draft of its 2026–2027 9% LIHTC Qualified Allocation Plan (QAP) Technical Amendment, alongside updated opportunity area data and maps from the Urban Institute. For developers, syndicators, and investors with active Ohio pipeline, this mid-cycle amendment has direct implications for site scoring, geographic eligibility, and additional credit allocation strategies heading into the next competitive round. Key Takeaways: OHFA has posted the first draft of its 2026–2027 9% LIHTC QAP Technical Amendment for public comment — a mid-cycle revision with potential scoring implications across the state. Updated Urban Institute data and maps have been published alongside the draft, directly affecting how OHFA defines opportunity areas and eligible geographies for competitive scoring. The comment period also covers OHFA's additional credits policy, which governs how allocations beyond standard awards are handled — a key lever for deals with above-average credit need. The comment deadline is 5 p.m. on the date published on OHFA's website; written submissions must be received by that time. Developers should cross-reference active Ohio sites against revised Urban Institute maps immediately — a change in opportunity area designation can materially alter a deal's competitive scoring position. Ohio operates one of the most active 9% LIHTC programs in the Midwest, making QAP amendments consequential for a large share of regional affordable housing pipeline. Substantive public comment during this window is the last point of real leverage to influence final QAP language before the amendment is locked for the cycle. Mid-cycle QAP technical amendments don't happen in a vacuum — when an agency like OHFA updates its underlying opportunity mapping through a partner like the Urban Institute, the ripple effects on deal competitiveness can be significant. Teams with Ohio pipeline should treat this comment period as an active workstream, not a passive notification. Review the maps, assess your sites, and engage with the additional credits policy language if it touches your capital stack. The window is open now. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  3. 2d ago

    Episode 114: The 21st Century ROAD Act Is Now Law

    The 21st Century Road to Housing Act — the ROAD Act — became law on July 11, 2026, without a presidential signature, after Congress passed it on June 23. Described as the most significant federal housing reform in a generation, the nearly 400-page bill includes dozens of provisions touching manufactured housing, zoning, Community Development Block Grants, the Rental Assistance Demonstration program, and bank investment capacity. For LIHTC investors, developers, syndicators, and lenders, several provisions have direct and near-term implications for deal structure, financing capacity, and preservation pipelines. Key Takeaways: Section 203 raises the Public Welfare Investment Cap from 15% to 20% of overall bank capital, expanding balance-sheet room for CRA-driven affordable housing equity investment. Section 204 reforms CDBG to permit new housing construction for the first time, allowing cities to allocate up to 20% of their CDBG funds toward new development. Section 212 expands the Rental Assistance Demonstration (RAD) program, giving PHAs broader authority to take on debt for unit preservation and rehabilitation. Section 301 eliminates HUD's permanent steel chassis requirement for manufactured homes; Section 303 updates FHA lending rules to allow home improvement loans for manufactured homes used as ADUs — opening a new federally backed financing lane. Section 208 authorizes a $200 million innovation fund for communities that increase housing supply, subject to congressional appropriation. HUD is directed under Section 107 to develop zoning and land use best practices for localities — guidance that could influence future state QAP incentive structures. The bill does not appropriate new demand-side dollars, does not address HUD staffing cuts, and leaves the mixed-status rule and housing-first policy questions unresolved. The ROAD Act's passage required genuine cross-aisle cooperation — Senate Banking Chair Tim Scott and Ranking Member Elizabeth Warren, House Financial Services Chair French Hill and Ranking Member Maxine Waters all had to find common ground. That political signal matters as much as the technical provisions: housing affordability is now a durable bipartisan priority, which sets the table for future, potentially larger reforms. For practitioners, the immediate focus should be on HUD implementation guidance for the CDBG construction flexibility and the Public Welfare Investment Cap increase, and on how state HFAs begin to incorporate the new manufactured housing financing pathways into upcoming QAP cycles. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  4. 6d ago

    Episode 113: Trump Administration Moves to Kill HUD's Restore-Rebuild

    The Trump administration's effort to eliminate HUD's Restore-Rebuild initiative is now a national story, following a Politico report that highlights the program's cancellation and its cascading effects on public housing authorities and affordable housing developers. The San Diego Housing Commission is walking back plans for 700 units; the Council of Large Public Housing Authorities says the move contradicts HUD's stated mission. For LIHTC investors, developers, and lenders with Restore-Rebuild exposure in their pipelines, the implications are immediate and concrete. Key Takeaways: The Trump administration is moving to shut down HUD's Restore-Rebuild initiative, drawing national coverage from Politico. The San Diego Housing Commission is walking back plans to build 700 new affordable units that were structured around Restore-Rebuild funding. CLPHA CEO La Shelle Dozier called the move a direct contradiction of HUD's stated goal to expand affordable housing supply. Restore-Rebuild was one of the few remaining federal tools capable of delivering deep affordability layering in markets where 9% credits alone cannot close the financing gap. NH&RA led a letter-signing effort to HUD as recently as June 24 urging reconsideration — a sign that organized industry advocacy is underway but has not reversed course. Deals with Restore-Rebuild assumptions in their financing stacks face repricing, restructuring, or collapse without a replacement mechanism. State HFAs may face pressure to respond through QAP incentives or state-funded bridge programs as the federal gap widens. With the fiscal year-end approaching and congressional appropriators still engaged on housing funding, there is a narrow window for legislative intervention. Developers and PHAs with active Restore-Rebuild pipelines should begin stress-testing their financing structures now and engaging state HFAs about potential gap-filling strategies. The program's elimination is not yet finalized in statute, but the administrative intent is clear — waiting is not a strategy. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  5. Jul 9

    Episode 112: HUD's 2023 LIHTC Tenant Data Shows Record Low Incomes

    HUD's newly released LIHTC Tenant Tables for 2023 reveal that 57.2% of LIHTC residents earn 30% or less of area median gross income — the highest share of extremely low-income tenants ever recorded in the dataset. With a national median tenant income of just $18,600 and nearly half of all residents receiving rental assistance, the data paints a clear picture of who the program is actually serving and raises urgent questions for investors, developers, and policymakers about income targeting, layered subsidy, and underwriting assumptions. Key Takeaways: 57.2% of LIHTC residents are classified as extremely low-income (≤30% AMI) — the highest share ever recorded in this dataset. Only 6.2% of residents earn more than 60% AMI, meaning the program is heavily concentrated well below its statutory eligibility ceiling. 48.3% of LIHTC residents received monthly rental assistance in 2023 — the highest share since HUD began tracking this figure in 2015. The national median LIHTC tenant income was $18,600; nearly 20% of households reported annual income of $10,000 or less. The growing share of assisted tenants signals deepening interdependence between the LIHTC program and the Housing Choice Voucher system. This data strengthens the policy case for extremely low-income set-asides and deeper income targeting in state QAPs. Developers and underwriters should reassess rent collection risk assumptions given the declining income profile of the LIHTC tenant population. The 2023 Tenant Tables arrive at a moment when state housing finance agencies are refining their qualified allocation plans and Congress is debating the future of both the LIHTC program and the voucher system. The convergence of these policy tracks matters: if nearly half of LIHTC tenants depend on rental assistance to afford a tax credit unit, program design decisions made in Washington and in state capitals are more tightly coupled than ever. Stakeholders across the capital stack should be using this data now — in QAP comment periods, in advocacy, and in deal structuring. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  6. Jul 8

    Episode 111: USDA Section 515 Portfolio Is Shrinking Fast

    The Housing Assistance Council's latest research brief confirms what many rural housing advocates have feared: USDA's Section 515 Multifamily Housing portfolio is shrinking faster than scheduled maturities alone would explain. With 504 properties already gone ahead of their loan maturity dates and seven Midwestern states each losing more than 10% of their Section 515 stock since 2021, the affordable rural housing supply is eroding now — and USDA's own projections show the worst is still ahead, with exits peaking around 2040 and the program potentially depleted by 2056. Key Takeaways: 504 Section 515 properties have exited the portfolio before their mortgage maturity date — signaling early opt-outs and deterioration, not just scheduled wind-down. Seven states — Nebraska, North Dakota, Michigan, South Dakota, Wisconsin, Indiana, and Iowa — each lost more than 10% of their Section 515 housing stock between 2021 and 2026. Michigan recorded the largest unit loss: 2,072 affordable rural housing units departed the program in just five years. Losses are concentrated in the Midwest and Upper Great Plains, where early Section 515 loans are now reaching maturity — making this a regional crisis first, but a national one soon. USDA projects annual exits will accelerate sharply, peaking around 2040, with complete program depletion possible by 2056. Section 515 markets largely fall outside the LIHTC financing stack, meaning lost units are rarely replaced by conventional affordable housing mechanisms. Preservation opportunities exist now in the seven hardest-hit states — before the exit curve steepens further. For LIHTC investors, syndicators, and rural lenders, this brief is a signal to watch for preservation vehicles targeting Section 515 — including potential loan restructuring programs, new USDA appropriations, and rural housing tax credit proposals that have been circulating in Congress. The states losing the most units today are also the states most likely to assemble preservation pipelines first. That's where the near-term deal flow will be. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  7. Jul 7

    Episode 110: FY 2026 CoC NOFO Faces New Legal Challenge

    A coalition of local governments and nonprofits has filed a supplemental complaint challenging HUD's FY 2026 Continuum of Care Notice of Funding Opportunity, arguing it mirrors the version a federal court already found likely unlawful in December 2025. With applications still due August 26, developers and syndicators structuring supportive housing deals with CoC operating subsidies face real underwriting uncertainty as the litigation advances. Key Takeaways: Plaintiffs filed a supplemental complaint in the existing CoC lawsuit, extending the legal challenge from the FY 2025 NOFO to the newly released FY 2026 NOFO. A preliminary injunction issued in December 2025 already blocked HUD's altered FY 2025 CoC NOFO, reverting to the prior FY 2024–25 version. Plaintiffs argue the FY 2026 NOFO "bears many similarities to the version the court already determined likely to be unlawful" — strong language signaling a high-confidence legal posture. FY 2026 CoC applications are still due August 26, despite the active litigation — applicants must decide whether to proceed under a potentially enjoined NOFO. CoC operating subsidies are frequently paired with LIHTC equity in permanent supportive housing deals; litigation-driven disruption creates bankability risk for deals in predevelopment. Any emergency motion for a temporary restraining order before August 26 could force HUD to extend the deadline or revert to prior NOFO terms. Developers and syndicators with CoC-dependent deals should build contingency language into timelines and monitor court dockets closely. This case is a live test of HUD's authority to reshape the CoC program's criteria and emphasis through the NOFO process alone. If the court extends injunctive relief to the FY 2026 cycle, it would mark the second consecutive year HUD's CoC funding notice has been blocked — a significant constraint on the agency's ability to redirect the program without statutory or regulatory change. Stakeholders across the supportive housing spectrum should treat August 26 as a fluid target and maintain close contact with their legal counsel and CoC intermediaries as the case develops. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

  8. Jul 6

    Episode 109: Connecticut CHFA Releases Draft 2027–2028 QAP

    The Connecticut Housing Finance Authority (CHFA) has released its draft Qualified Allocation Plan (QAP) for 2027 and 2028, opening a brief public comment window that closes July 10, 2026. For LIHTC developers, syndicators, investors, and lenders active in Connecticut, this two-year plan will govern how CHFA scores and ranks tax credit applications through the end of 2028 — making early engagement critical for anyone with a Connecticut pipeline. Key Takeaways: CHFA's draft QAP covers two full allocation cycles — 2027 and 2028 — giving it an unusually long governance horizon for Connecticut LIHTC deals. A virtual public hearing is scheduled for July 7, 2026 at 10:00 AM ET via Zoom; all stakeholders are invited to participate. Written comments are accepted through close of business July 10, 2026 — just three days after the hearing. Submissions can be sent by email or by mail to Terry Nash Giovannucci, CHFA, 999 West Street, Rocky Hill, CT 06067. QAP provisions that merit close review include scoring criteria, set-aside allocations, geographic targeting, income targeting requirements, and developer fee caps — all of which directly affect deal feasibility. Syndicators and investors should use the draft to anticipate deal flow composition (project type, location, tenant population) from Connecticut over the next two years. Any party with active or planned Connecticut LIHTC applications should prioritize submitting formal comments before the July 10 deadline. With a two-year QAP, CHFA is setting the rules of the road for Connecticut affordable housing finance through the end of 2028. Changes embedded in this draft — whether to basis limits, scoring weights, or set-aside priorities — will compound across two full funding rounds. Stakeholders who engage now, during the comment period, have the best opportunity to shape outcomes before the plan is finalized. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.

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The Spring Street Brief is your daily intelligence briefing on affordable housing in America. In under 3 minutes, get the news that matters: LIHTC allocations, Section 8 voucher updates, HUD policy changes, private activity bonds, state housing finance agency deals, and emerging trends in affordable housing development. Designed for LIHTC investors, affordable housing developers, syndicators, lenders, and policy makers who need to stay ahead of the curve. AI-powered. Human-curated. Brought to you by Tom Carter at Spring Street Management Group.

Information

  • Creator
    Spring Street Management Group
  • Years Active
    2025 - 2026
  • Episodes
    115
  • Rating
    Clean
  • Copyright
    © 2026 Spring Street Management Group

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