Affirmatively Furthering Fair Housing
- Leadership Conference 2024 priorities for HUD (February 2024)
- Comments regarding the Capital Magnet Fund and AFFH (September 2023)
- PRRAC response to Federal Housing Finance Agency request for input on tenant protections in GSE backed multifamily properties (July 2023)
- Letter to Congress Re Opposing AFFH Rider in House THUD Bill (July 2023)
- Letter to Senate Appropriations Committee urging members to support flexibility in the use of Section 8 voucher funds (7/13/23)
- National Fair Housing Groups AFFH Sign-on Letter
- FHEO Principal Deputy Secretary Demetria McCain Re: Proposed AFFH Rule (Fair Housing/Fair Lending Task Force of the Leadership Conference on Civil and Human Rights, February 2022)
- Meaningful Collaboration Between Housing and Education Agencies in the Implementation of AFFH (PRRAC et al, September 2021)
- To HUD on Implementing Tenant Protections in AFFH (Alliance for Housing Justice, October 2021)
- Recommendations for a Renewed AFFH Regulation (LCCUL, NAACP LDF, NFHA, NHLP, NHLIC, & PRRAC, August 2021)
- Restoring AFFH Definitions and Certifications (Civil Rights Orgs, July 2021)
- OMB Equity RFI (PRRAC, July 2021)
- Affirmatively Furthering Fair Housing (AFFH)
- AFFH Rule (PRRAC, March 2020)
- ANPR on 2018 AFFH Rule (PRRAC et al, October 2018)
- Comment Letter: Reconsideration of Assessment of Fair Housing Tool (PRRAC et al, July 2018)
- Fair Housing Regulatory Agenda (PRRAC et al, June 2017)
- OMB Re Final Assessment of Fair Housing Tools (PRRAC et al, November 2016)
- Revised State AFH Tool (PRRAC et al, October 2016)
- Revised AFFH PHA Tool (PRRAC et al, October 2016)
- Revised Assessment of Fair Housing Tool – Local Jurisdictions (PRRAC et al, September 2016)
- Incorporating the Affirmatively Furthering Fair Housing Obligation into EPA’s 2020 Environmental Justice Action Agenda (PRRAC et al, July 2016)
- HUD AFH Tool for Local Governments (PRRAC et al, May 2016)
- On HUD Assessment of Fair Housing Tool for Public Housing Agencies (PRRAC et al, May 2016)
- HUD AFH Tool for State Governments (PRRAC et al, May 2016)
- EPA-HUD AFFH Coordination (Title VI Alliance, March 2016)
- Revised AFFH “Assessment Tool” for HUD Entitlement Jurisdiction (PRRAC et al, August 2015)
- AFH Delay Notice (PRRAC et al, February 2015)
- AFFH Assessment Tool (PRRAC et al, November 2014)
- HUD’s Proposed Fair Housing Assessment Form (PRRAC et al, November 2014)
- Proposed Rule, “Affirmatively Furthering Fair Housing,” 78 Fed. Reg. 43710 (PRRAC et al, September 2013)
- Anticipated AFFH regulation (PRRAC et al, October 2010)
- Recommended Civil Rights-Related Research at the HUD Office of Policy Development & Research (PRRAC et al, October 2009)
- AFFH Regulation (PRRAC et al, July 2009)
- To Secretary Donovan Regarding the Westchester County Case (PRRAC et al, March 2009)
Civil Rights & the Administrative State
Civil Rights & Housing Finance Reform
- PRRAC comments on proposed Community Reinvestment Act regulations, August 2022
- Request for Input Regarding the Enterprises’ Equitable Housing Finance Plans (PRRAC, October 2021)
- OMB Equity RFI (PRRAC, July 2021)
- FHFA “Duty to Serve” Proposed Rule (PRRAC, March 2016)
- Community Reinvestment Act Interagency Questions and Answers Regarding Community Reinvestment (November 2014)
- On Housing Finance Reform (PRRAC et al, February 2014)
- Affirmatively Furthering Fair Housing in the Disposition of REO Properties (PRRAC et al, September 2011)
Community Development Block Grant and HOME Investment Partnerships Program
Convention on the Elimination of All Forms of Racial Discrimination (CERD)
Cross-Program Advocacy
Disparate Impact
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (CLPHA and Reno & Cavanaugh, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (CBPP, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Urban Institute, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Shriver Center, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (National Women’s Law Center, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (NHLP, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (National Association of Home Builders, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Earthjustice, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Enterprise, Housing Partnership Network, LISC, National Housing Trust & SAHF, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (National Association of Affordable Housing Lenders, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Lawyers’ Committee Affiliates, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Civil Rights Clinic & Georgetown University Law Center, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Center on Race, Inequality, & the Law at New York University School of Law, October 2019)
- Comment Letter: Disparate Impact (Environmental Justice, Health, & Fair Housing Organizations and Practitioners, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Stacy Seicshnaydre, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (New York State Homes and Community Renewal, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (New Jersey Housing and Mortgage Finance Agency, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Lawyers’ Committee for Civil Rights Under the Law, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Fair Housing Justice Center, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Civil Procedure Law Professors, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Center for Responsible Lending, Self-Help Credit Union, & Self-Help Federal Credit Union, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Joshua Stein on behalf of 22 AGs, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (NAACP LDF, October 2019)
- Comment Letter: HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard (NFHA, October 2019)
- Implementation of the Fair Housing Act’s Disparate Impact Standard (PRRAC, EJ, & Fair Housing Orgs, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (Pennsylvania Housing Finance Agency, October 2019)
- Comment Letter: Implementation of the Fair Housing Act’s Disparate Impact Standard (ACLU, October 2019)
- Implementation of the Fair Housing Act’s Disparate Impact Standard (PRRAC & Klein Hornig LLP, October 2019)
Environmental Justice, Health, & Transportation
- Final Comments to EPA on Technical Guidance for Assessing Environmental Justice in Regulatory Analysis (Title VI Alliance, January 2024)
- Final Letter to EPA and DOJ on Environmental Justice and Civil Rights (Title VI Alliance, October 2023)
- Environmental Justice Comments on the Proposed Affirmatively Furthering Fair Housing Rule (April 2023)
- Comments on the EPA “Environmental and Climate Justice Block Grant Program” (Title VI Alliance April 2023)
- Letter to HUD re Civil Rights in CDBG Disaster Recovery Administration (Title VI Alliance, February 2023)
- RE: Comments on EPA’s Civil Rights Obligations in Designing and Implementing the Greenhouse Gas Reduction Fund (Title VI Alliance, December 2022)
- ECRCO Affirmative Compliance Selection Review (Title VI Alliance, February 2022)
- On Proposed NEPA Implementing Regulations Revisions (Title VI Alliance, December 2022) (NAACP LDF, PRRAC, et al, November 2021)
- EPA Strategic Plan (Title VI Alliance, November 2021)
- Advancing Health, Environmental, and Housing Justice Together: Recommendations for HUD (NAACP LDF, PRRAC, et al, June 2021)
- Support for the Equity and Inclusion Enforcement Act, H.R. 2574 (PRRAC et al, September 2020)
- On New Federal Strategy to Reduce Childhood Lead Exposures (Title VI Alliance, November 2017)
- To USCCR on Environmental Justice Enforcement at the EPA (Title VI Alliance, August 2017)
- Revised AFFH PHA Tool (PRRAC et al, October 2016)
- Revised Assessment of Fair Housing Tool – Local Jurisdictions (PRRAC et al, September 2016)
- Incorporating the Affirmatively Furthering Fair Housing Obligation into EPA’s 2020 Environmental Justice Action Agenda (PRRAC et al, July 2016)
- On the Department of Interior Environmental Justice Plan (Title VI Alliance, May 2016)
- Fair Housing Comments on the Capital Magnet Fund Interim Rule (PRRAC et al, May 2016)
- EPA-HUD AFFH Coordination (Title VI Alliance, March 2016)
- HUD’s Responsibility to Residents of Flint, Michigan (PRRAC & LCCUL, March 2016)
- Shriver Center/Loyola Petition for Rulemaking on Lead-Based Paint Protocols (PRRAC et al, February 2016)
- DOT Proposed Rule on Statewide Metropolitan Transportation Planning (PRRAC, October 2014)
- EPA Draft Title VI Policy Papers (Title VI Alliance, March 2013)
- Transportation Equity Caucus on FTA New Starts Guidance (PRRAC et al, March 2013)
- Comments on Federal Transit Administration proposed rule on transit oriented development (March 2012)
- EPA Draft Report, “Creating Equitable, Healthy, and Sustainable Communities” (PRRAC et al, March 2012)
- Fair Housing Comments on HUD EJ Strategy (PRRAC et al, November 2011)
- Transit-Oriented Affordable Housing in High Opportunity Communities (May 2011)
- Comment letter to Dept. of Transportation on Discretionary Grants NOFA (June 1, 2009)
- Letter to Secretaries Donovan and LaHood on smart growth and fair housing (April 6, 2009)
Fair Housing and Community Development
- Capital Magnet Fund application form (November 2024)
- NFHA Coalition letter on Treasury Department housing programs (February 2024)
- Comments regarding the Capital Magnet Fund and AFFH (September 2023)
- PRRAC comments on proposed methodology for calculation of Fair Market Rents (July 2023)
- Letter to the Interagency Community Investment Committee (December 2022)
- RE: Comments on EPA’s Civil Rights Obligations in Designing and Implementing the Greenhouse Gas Reduction Fund (Title VI Alliance, December 2022)
- PRRAC comments on proposed Community Reinvestment Act regulations, August 2022
- Request for Input Regarding the Enterprises’ Equitable Housing Finance Plans (PRRAC, October 2021)
- Advance Notice of Proposed Rulemaking (ANPR) Regarding the Community Reinvestment Act (PRRAC, November 2018)
- Letter to IRS on Treasury Department Notice 2016-77, Re: the “Concerted Community Revitalization Plan” Requirement (PRRAC et al, February 2017)
- Fair Housing Comments on Capital Magnet Fund Interim Rule (PRRAC, LCCUL, & NFHA, May 2016)
- Affirmatively Furthering Fair Housing in the Disposition of REO Properties (PRRAC et al, September 2011)
- Comment letter to Dept. of Transportation on Discretionary Grants NOFA (June 1, 2009)
- Testimony of PRRAC and The Inclusive Communities Project on the Community Reinvestment Act
Fair Housing and Equal Opportunity
Housing-Schools Nexus
Low-Income Housing Tax Credit
- Comments regarding the Capital Magnet Fund and AFFH (September 2023)
- Civil rights comments on NCSHA Recommended Practices for state LIHTC plans (August 2023)
- Social Housing Goals in the LIHTC Program (August 2023)
- LIHTC fair housing reforms 11-9-21
- NCSHA Recommended Practices in Housing Credit Administration (PRRAC, August 2017)
- Letter to IRS on Treasury Department Notice 2016-77, Re: the “Concerted Community Revitalization Plan” Requirement (PRRAC et al, February 2017)
- Fair Housing Comments on Capital Magnet Fund Interim Rule (PRRAC, LCCUL, & NFHA, May 2016)
- Follow-up to Civil Rights Guidance in the LIHTC Program (PRRAC et al, March 2016)
- Treasury Department Administrative Guidance on the LIHTC Program (PRRAC et al, November 2015)
- Proposed Treasury Department Title VI Rule (PRRAC et al, September 2015)
- Fair Housing Comments to Working Group on Community Development & Infrastructure, Responding to Treasury Department Proposal for LIHTC (PRRAC, LCCUL, & NFHA, April 2015)
- Draft Audit Technique Guide, IRC §42, LIHTC (PRRAC, March 2014)
- Continuation and Expansion of the Low Income Housing Tax Credit (PRRAC et al, May 2013)
- Recommendations to LIHTC Interagency Working Group (PRRAC et al, April 2013)
- Urging Treasury Department to release Title VI regulations for LIHTC program (PRRAC et al, June 2012)
- Urging Treasury Department’s Release of Title VIII Guidance and Regulations for LIHTC program (PRRAC et al, May 2012)
- Civil Rights and “Compliance Harmonization” (PRRAC et al, August 2011)
- Treasury Dept. Regulations (PRRAC et al, October 2010)
- To IRS Re: Proposed Information Collection for its Regulation (NHLP, Oregon Law Center, & PRRAC, September 2010)
- Treasury Department Regulations (PRRAC et al, August 2010)
- Civil Rights Comments, Housing Tax Credit Coordination Act (PRRAC et al, June 2009)
- To Treasury Department Re: Capital Magnet Fund (PRRAC et al, May 2009)
- To HUD Secretary Donovan on LIHTC Requirements in the Stimulus Bill (PRRAC et al, March 2009)
- To IRS on Civil Rights Requirements in LIHTC Guidebook (PRRAC et al, March 2004)
Miscellaneous HUD Programs
- Fair Housing Regulatory Agenda (PRRAC et al, June 2017)
- Opposing Regulatory Accountability Act of 2017 (PRRAC et al, May 2017)
- Interim Guidance Implementing Section 2 of the Executive Order of January 30, 2017, Titled “Reducing Regulation and Controlling Regulatory Costs (PRRAC et al, February 2017)
- EPA-HUD AFFH Coordination (Title VI Alliance, March 2016)
- HUD’s Responsibility to Residents of Flint, Michigan (PRRAC & LCCUL, March 2016)
- Shriver Center/Loyola Petition for Rulemaking on Lead-Based Paint Protocols (PRRAC et al, February 2016)
- Revision of Public Housing Agency Plans to Conform to AFFH (PRRAC et al, January 2016)
- Continued Funding for Project-Based Vouchers (PRRAC et al, June 2013)
- Stalled Regulations at HUD (PRRAC et al, May 2012)
- Proposed Housing Trust Fund Regulations(PRRAC et al, December 2010)
Moving to Work
- NHLP, PRRAC Letter Regarding SAFMR and MTW (February 5, 2024)
- MTW Expansion Notice (PRRAC, June 2017)
- Regarding Missing Civil Rights Related Data for MTW Agencies (PRRAC, April 2016)
- Follow-up on MTW Contract Extensions (PRRAC et al, April 2015)
- Detailed Advocates’ Recommendations on Contract Extensions for MTW Public Housing Agencies (PRRAC et al, January 2015)
- Housing Advocates Requesting Transparent and Inclusive MTW Extension Negotiations (PRRAC et al, November 2014)
School Diversity
Section 8 Voucher Reform/Housing Mobility
- PRRAC comments on proposed Direct Rental Assistance demonstration (August 2024)
- Comments on proposed rule “Reducing Barriers to HUD-Assisted Housing” (June 2024)
- Letter to Senate Appropriations Committee re flexibility in the use of voucher funds, and support for housing mobility programs (June, 2024)
- NHLP, PRRAC Letter Regarding SAFMR and MTW (February 5, 2024)
- Letter re HUD guidance on Source of Income Discrimination (October 3, 2023)
- PRRAC comments on proposed methodology for calculation of Fair Market Rents (July 2023)
- Letter to Senate Appropriations Committee urging members to support flexibility in the use of Section 8 voucher funds (7/13/23)
- PRRAC comments on adverse tenant screening practices affecting families with vouchers (May 2023)
- Letter Urging SEMAP and SAFMR Expansion (May, 2023)
- Rescreening and Portability letter 5-1-23
- PRRAC recommendations on SEMAP reform January 2023
- Section 8 Voucher Funding Sign-on (June 2022)
- Flexibility in the use of Housing Choice Voucher funds to increase utilization of vouchers and expand access to opportunity (June 2022)
- Rent Reasonableness Recommendations Memo to HUD (NHLP & PRRAC, April 2022)
- Suggestions for Implementing New Housing Mobility Funding in the 2022 Congressional Appropriations Act Memo (CBPP & PRRAC, April 2022)
- Concerning Enhanced Vouchers and Fair Housing (PRRAC et al, April 2022)
- Mobility Works Praises Inclusion of $25 Million for Housing Mobility Services in Bipartisan FY 2022 Omnibus Spending Bill
- Supporting Biden Administration’s Funding Level Requests for the Housing Choice Voucher Program (PRRAC et al, August 2021)
- Appropriations FY-22 Sign-On Letter: Supporting Biden Administration’s Funding Level Requests for the Housing Choice Voucher Program (PRRAC et al, August 2021)
- Appropriations FY-22 Sign-On Letter: Supporting Biden Administration’s Funding Level Requests for the Housing Choice Voucher Program (PRRAC et al, August 2021)
- Housing Choice Voucher Reform and the President’s Budget Memo to HUD (February 2021)
- Fair Housing Comments on HOTMA Proposed Regs Payment Standards (January 2020)
- Fair Housing Comments on HOTMA Proposed Regs Payment Standards (January 2021)
- HOTMA Proposed Regs Payment Standards (PRRAC et al, January 2020)
- Federal Court Order Reinstating Small Area FMRs (December 2017)
- American Bar Association Resolution 119A (urging federal, state, local, tribal, and territorial governments to enact legislation prohibiting discrimination in housing on the basis of lawful source of income) (adopted by ABA Housing of Delegates August 14-15, 2017)
- HUD letter suspending mandatory Small Area FMR implementation (August 2017)
- Inclusive Communities Project, Inc. v. The State of Texas (February 2017)
- On Proposed Housing Choice Voucher Administrative Fee Rule (PRRAC & CBPP, October 2016)
- Comments of the Inclusive Communities Project on the Small Area FMR proposal (August 2016)
- ESOP comments on proposed Small Area Fair Market Rent rule (August 2016)
- Proposed Small Area Fair Market Rent Rule (PRRAC et al, August 2016)
- Coalition comments on proposed Small Area Fair Market Rent rule (August 2016)
- On Inadequate Payment Standards in Yonkers Housing Mobility Program (PRRAC, April 2016)
- To House Subcommittee Supporting Housing Mobility Demonstration in the President’s 2017 Budget (PRRAC et al, April 2016)
- To Senate Subcommittee Supporting Housing Mobility Demonstration in the President’s 2017 Budget (April 2016)
- Policy Brief: The Need for a National Housing Mobility Infrastructure (March 2016)
- Testimony of Professor Stefanie DeLuca in support of MD HOME Act (February 2016)
- A new housing mobility program in New Jersey
- CBPP/PRRAC comments on Housing Choice Voucher Administrative Fee reform (August 2015)
- Housing Choice Voucher Administrative Fee Reform (PRRAC & CBPP, August 2015)
- Comments on Small Area FMR expansion proposal (July 2015)
- On Small Area FMR Expansion Proposal (PRRAC et al, July 2015)
- Section 8 Renewal Funding Formula (PRRAC et al, June 2015)
- Comments on proposed PHA streamlining regulations restricting Section 8 lease dates (March 2015)
- Proposed PHA Streamlining Regulations Restricting Section 8 Lease Dates (PRRAC et al, March 2015)
- PHA Consortia rule (PRRAC et al, September 2014)
- Inclusive Communities Project v. HUD (Dallas Section 8 FMR litigation, part two) (complaint filed April 2014)
- Coalition letter on second term rulemaking priorities (February 2013)
- Second-Term Rulemaking Priorities (PRRAC et al, February 2013)
- Comments on proposed HUD rule streamlining Section 8 portability (May 2012)
- Proposed HUD Rule Streamlining Section 8 Portability (PRRAC et al, May 2012)
- Coalition letter on racial impacts of 2012 housing bill (January 2012)
- Racial Impacts of 2012 Housing Bill (PRRAC et al, January 2012)
- Housing coalition letter on delayed HUD regulations (September 2011)
- Delayed HUD regulations (PRRAC et al, September 2011)
- Fair Housing in Federal Programs (March 2001)
Social Housing
- Comments on proposed rule “Reducing Barriers to HUD-Assisted Housing” (June 2024)
- Social Housing Goals in the LIHTC Program (August 2023)
- AHJ 2023 AFFH Comment Letter (April 2023)
- Supporting social housing and tenant protections in the 2024 budget (AHJ, October 2022)
- Supporting the Housing Choice Voucher Tenant Engagement and Organizing in the President’s 2023 Budget (PRRAC & NHLP, December 2021)
- Supporting the California Social Housing Act of 2021, A.B. 387 (PRRAC et al, September 2021)
