On August 18, NMHC led a coalition of real estate organizations in sending a letter to the Administration outlining a number of desired Emergency Rental Assistance Program (ERAP) reforms. This latest communication to lawmakers comes just weeks after the coalition sent a letter and issued a press release encouraging lawmakers to focus on efficiently and effectively disbursing rental assistance rather than reimposing the federal eviction moratorium.
“Changes are needed to maximize the reach of ERAP funds to renters and housing providers and to ensure greater consistency across programs, especially in areas of overlapping coverage,” the August 18 letter reads. “Without action to improve disbursement of ERAP and increased participation in the program, renters are faced with further uncertainty and a mounting debt cliff, while rental property owners move closer to foreclosure, bankruptcy, or a forced sale of the property—putting the overall stability of the rental housing sector and broader real estate market in peril.”
To achieve more efficient and timely distribution of funds, the coalition recommends:
- Aligning ERAP income restrictions and eligibility requirements with the federal eviction moratorium.
- Directing grantees to allow housing providers to apply on behalf of residents and establish a safe harbor for those attempting to obtain documentation from uncommunicative residents to support those applications.
- Allowing ERAP to reimburse rental property owners even if the renter has moved and prohibit program requirements that force housing providers to return payments when residents move out.
- Requiring residents to demonstrate eligibility for rental assistance through an affidavit or self-attestation.
- Clarifying that renter eligibility is not contingent on having a COVID-19 diagnosis.
- Requiring state and local grantees to facilitate bulk processing of applications and payments.
- Prohibiting program grantees from imposing program requirements or proscriptions unrelated to payment of outstanding or future rental assistance.
Relatedly, Treasury released new guidance on August 25 that addresses a number of the issues we continue to raise regarding execution of the program. Specifically, Treasury has clarified provisions related to self-attestation and how funds can be applied to arrears. View the updated Treasury FAQ here.
NMHC will continue to work with policymakers to ensure the nearly $47 billion in ERAP funds make it into the hands of struggling renters and property owners. For more information on NMHC’s COVID-19 related advocacy work, please visit the NMHC COVID-19 advocacy webpage.
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