By: Eric Oberdorfer, Director of Policy and Legislative Affairs

June 1, 2026 — Today, NAHRO submitted comments on HUD’s HOME Investment Partnerships Program: Further Program Updates and Streamlining supplemental proposed rule. NAHRO’s comment letter generally supports efforts to reduce administrative burden and increase flexibility in the HOME program, while cautioning against changes that could make affordable housing development more difficult. The letter responds to HUD’s supplemental proposed rule, which reopens comments on provisions related to tenant protections, green building incentives, and manufactured housing. NAHRO emphasizes that HOME remains one of the most important federal affordable housing production tools and argues that regulatory changes should focus on expanding housing supply and improving program efficiency rather than creating additional compliance obligations.

A major focus of the letter is HUD’s proposal to reconsider provisions that would have allowed participating jurisdictions to exceed HOME’s maximum per-unit subsidy limits for projects meeting certain green building standards. The letter also comments on tenant protection provisions that were included in the 2025 HOME final rule but whose implementation has been repeatedly delayed. NAHRO generally argues that tenant protections should be balanced with local program administration realities and should not create excessive operational burdens that discourage participation in HOME-assisted development. HUD has indefinitely delayed the effective date of these provisions while it considers additional public comments.

The letter also supports HUD’s efforts to provide greater flexibility for scattered-site manufactured housing projects and other program streamlining measures that could increase affordable housing production. Throughout the comment letter, NAHRO advocates for policies that preserve local decision-making, reduce unnecessary regulatory complexity, and help participating jurisdictions deploy HOME funds more quickly and effectively.

NAHRO’s comments can be found here.

[mo-optin-form id="NIrLFwofHp"]