MAJORITY STAFF REPORT

COMMITTEE ON THE BUDGET

MICHAEL B. ENZI, CHAIRMAN

UNITED STATES SENATE

OCTOBER 2020

HOUSING 

PROGRAMS 

THE NEED FOR 

ONE ROOF 
ii 

Table of Contents 

1. Executive Summary .................................................................................................. 3

2. Introduction .............................................................................................................. 4

3. Examples of Housing Overlap.................................................................................... 8

A. HUD’s and USDA’s Loan Guarantee and Rental Assistance Programs Overlap....8

B. HUD’s Rental Assistance Programs Serve Similar Populations.....................10

C. The HOME Program and the Housing Trust Fund Overlap..............................14

D. The Lack of Cost Data Hinders Program Evaluation.........................................17

E. The Federal Government Also Supports Housing Through Billions in Tax 

Expenditures...........................................................................................17

4. Major Findings and Conclusions .............................................................................. 20

Appendix: GAO’s Inventory of Housing Assistance Programs ......................................... 24
 3 

1. EXECUTIVE SUMMARY 

Our housing assistance system is broken. The goals of our nation’s housing programs 

should not be to maintain a bureaucracy, but rather to serve those in need efficiently and 

effectively. Moreover, we should ask the foundational question: If designing a system 

from scratch, would it look anything like the current system? 

The federal government spends over $50 billion per year on low-income housing 

assistance programs, guarantees $2 trillion in home loans, and provides billions more 

through the tax code. A Government Accountability Office analysis identified 20 different 

entities administering 160 housing assistance programs and activities. 

This sprawling, fractured system is the result of 80-plus years of legislative efforts to 

address shifting goals. Those changing priorities and other shifts have led to duplication 

and overlap. For example: 

 The loan guarantee and rental assistance programs of the departments of 

Agriculture (USDA) and Housing and Urban Development (HUD) overlap in terms 

of the assistance offered, service delivery, and areas served. 

 HUD’s three main rental assistance programs—Public Housing, Housing Choice 

Vouchers, and Section 8 project-based rental assistance—each have similar 

eligibility rules and serve largely similar populations. 

 Two block grant programs, the Housing Trust Fund and the HOME Investment 

Partnerships Program, are identical in many respects and should be consolidated 

or streamlined. They are the same in terms of their allocation, administrative 

funds, fund commitment and expenditure deadlines, and overall goal of affordable 

housing. 

 The government also supports housing through tax preferences. The Low Income 

Housing Tax Credit is a multi-billion dollar tax expenditure that overlaps with other 

housing programs, most notably project-based Section 8 and the tenant-based 

Housing Choice Voucher Program. 

This byzantine system is failing the neediest Americans. We spend billions each year, yet 

over half a million people in this country were homeless in a single night in 2019. 

Programs are scattered across agencies, creating confusion and headaches for those 

seeking assistance. The system can and should be improved. 

To that end, this report seeks to begin a needed conversation about reforming our 

housing system. An important first step would be consolidating some of these programs 

under one roof. 
 4 

2. INTRODUCTION 

“....[T]he Nation's housing laws today . . . contain internal inconsistencies, numerous 

duplications, cross-purposes, and overlaps as well as outright conflicts and 

gimmickry. In some cases, the objectives themselves are open to serious question. 

“The complicated maze of HUD program laws, filling hundreds of pages in the 

statute books, are properly recognized as replete with inconsistencies, conflicts, 

and obsolete provisions and without overall design or coordinated structure. All 

this is magnified in the red tape flowing from implementing regulations.” 

 – The U.S. Department of Housing and Urban Development, 19741

In fiscal year 2019, the federal government spent over $50 billion per year on low-income 

housing assistance programs, guaranteed about $2 trillion in home loans, and provided 

billions more through the tax code.2 

How is that money spent, and where does it go? And why are people not getting needed 

services? It’s complicated. 

An Overly Complex System 

In 2012, the Government Accountability Office (GAO) found that 20 different entities 

administered 160 programs, tax expenditures, and other tools supporting 

homeownership and rental housing in fiscal year 2010. Thirty-nine programs helped with 

buying, selling, or financing a home. Twenty-five programs provided assistance for 

financing the construction of affordable rental housing or subsidizing rental payments for 

low-income households.3 GAO restated these findings in September 2020.4

In short, the system is a sprawling, tangled, and expensive mess. How can we provide 

adequate assistance, and properly steward taxpayer dollars, when housing assistance 

programs are scattered under so many different roofs? How can we help the neediest 

when we don’t know precisely how, where, and to whom billions of dollars are flowing? 

We can’t. But we could provide more effective housing assistance with the same level of 

resources if the current array of federal housing programs were more streamlined and 

less complicated. Congress should undertake sensible reforms to reorganize and 

consolidate housing programs to improve efficiency and effectiveness, save taxpayer 

dollars, and better serve those in need. 

Shifting Goals 

To move forward, we need to understand how we got here. 

Today’s housing assistance system is the result of more than 80 years of efforts to 

address shifting goals and priorities. Those changing priorities, combined with other 

changes, have led to numerous areas of duplication and overlap. 
 5 

Federal involvement in housing dates back to 1913, when the new income tax allowed for 

the deduction of mortgage interest and property taxes from federal income.5 Two decades 

later, in the 1930s, the United States began providing housing assistance as part of 

recovery efforts from the Great Depression.6 

Over time, our nation’s housing policy goals and mechanisms have changed. Congress 

first created the framework for government to build and own housing. Later Congress 

enacted legislation that sought to encourage private development of affordable housing 

through construction subsidies for developers. For example, in the 1986 tax bill, Congress 

used the tax code to encourage housing development through tax credits for affordable 

housing construction. Congress also created programs to provide housing assistance to 

specific groups, such as veterans, the elderly, the disabled, and many others. Table 1 

below outlines certain key housing laws through the years. 

Table 1: Key Housing Laws and Their Provisions 

1930s and 1940s 

 The Housing Act of 1934: Set forth provisions to support the mortgage market in response to the turmoil of 

the Great Depression. Its reforms were designed to encourage investment in housing and boost 

construction employment. Key provisions included creation of the Federal Housing Administration and the 

Mutual Mortgage Insurance Fund.7 

 The U.S. Housing Act of 1937: Created a framework for funding the creation of affordable rental housing. 

States could establish local public housing authorities, which could apply for funds to build developments 

for low-income families. The law also created the United States Housing Agency—a forerunner to today’s 

U.S. Department of Housing and Urban Development (HUD)—to administer the program.8 

 The Housing Act of 1949: Enacted to address a perceived shortage of affordable and safe housing in the 

years following World War II. Its provisions included new programs for urban redevelopment, money for 

public housing construction, and expanded mortgage insurance to encourage home buying and 

construction. This Act also created a program specifically targeted at improving farm and rural housing 

within the U.S. Department of Agriculture.9 

 

1950s and 1960s 

 

 The Housing Act of 1959: Marked the first significant use of incentives encouraging private developers to 

build affordable housing for low- and moderate-income households.10 

 The Housing Act of 1961: Further expanded the private sector’s role in providing housing.11

 The Housing and Urban Development Act of 1965: Created HUD and the Rent Supplement program.12

 The Housing and Urban Development Act of 1968: Created rental and homeownership programs for lowerincome families, and spun off Ginnie Mae from Fannie Mae.13

 The Civil Rights Act of 1968: Prohibited housing discrimination.14

1970s into the 2000s 

 The Housing Act of 1974: Created the Section 8 program and Community Development Block Grants.15

 The Tax Reform Act of 1986: Created the Low Income Housing Tax Credit program. 

 The Stewart B. McKinney Homeless Assistance Act of 1987: Was the United States’ first comprehensive 

approach to addressing homelessness.16

 The National Affordable Housing Act of 1990: Authorized the HOME Investment Partnerships program.17 

 The Housing and Economic Recovery Act of 2008: Created the Housing Trust Fund.18
 6 

Today, low-income housing assistance programs cover three broad areas: rental housing 

assistance, federal assistance to state and local governments, and homeowner assistance.19 But 

even these areas are not always mutually exclusive.20 For example, some assistance to states 

and localities can be used to provide housing finance or homeownership assistance.21 And no 

one program dominates the landscape.22 That means within the federal housing assistance 

system, no one program serves a clear majority of low-income recipients, with some of the 

poorest households not being served at all.23

The number of agencies involved further complicates these programs. The U.S. Department of 

Housing and Urban Development (HUD) administers most low-income housing assistance 

programs, but the U.S. Department of Agriculture (USDA), the Department of Veterans Affairs 

(VA), the Treasury Department, and several others also provide housing assistance.24

The system is byzantine and bloated. It does little to support affordable housing, responsibly 

steward billions in taxpayer dollars, or deliver services to the neediest Americans. If starting 

from scratch, no one would design our current federal housing assistance system. 

The Senate Budget Committee’s Housing Roundtable 

On September 16, 2020, the United States Senate Committee on the Budget held a roundtable 

discussion entitled “Examining Federal Housing Assistance Programs.” Daniel Garcia-Diaz of 

GAO called the system “exceedingly complex and fragmented,” and said the federal government 

“only reaches a small fraction” of the “significant” housing needs of lower-income families. 

Professor Edgar Olsen of the University of Virginia said low-income housing assistance is 

“fertile ground” for reform, with most recipients “served by programs whose cost is enormously 

excessive for the housing provided.” Diane Yentel of the National Low Income Housing Coalition 

supported some efforts to streamline and realign housing programs, but advocated expanding 

and fully funding housing programs.25

There was bipartisan agreement that the system needs improvement. There also seemed to be 

agreement around the concept of giving greater control to tenants. Perhaps most notably, 

bipartisan consensus emerged that housing vouchers were a particularly effective affordable 

housing tool. This high-level agreement merits further exploration, and gives hope that there is 

common ground on which to build reforms.26

Starting the Conversation 

Building on the roundtable’s promise, this report aims to begin a conversation about reforming 

federal housing assistance programs. 

Section 3 provides examples of overlap. It also highlights the redundancies in HUD’s major 

rental assistance programs. This section further shows that the similarities between the HOME 

Investment Partnerships program and the Housing Trust Fund suggest opportunities for 

consolidation and streamlining. It also raises important transparency and evaluation concerns: 

the lack of even basic information about the administrative costs of these programs, and the 

number of employees administering them. Finally, this section discusses housing-related tax 

expenditures, particularly the Low Income Housing Tax Credit (LIHTC). While not intended to be 
7 

used in isolation, the LIHTC overlaps with the project-based Section 8 and tenant-based Housing 

Choice Voucher programs, among other programs. 

Section 4 sets out the report’s conclusions. In summary, our current housing assistance 

programs need reform. Under such consolidation, HUD appears to be the most logical agency to 

house many of the existing programs. This section also addresses some anticipated objections 

to reform. 

Reforming Housing 

There are numerous federal housing programs serving similarly-situated individuals and—

while they may have some variation—their goal is the same: affordable housing. 

This point is obvious, but important. If the housing assistance system isn’t reformed sooner 

rather than later, difficult changes may lie ahead. Millions are already left out in the cold. We can 

and should do better. 

If home is where the heart is, then we should care about our housing assistance system and 

pursue meaningful reform now. 
8 

3. EXAMPLES OF HOUSING OVERLAP 

A. HUD’s and USDA’s Loan Guarantee and Rental Assistance 

Programs Overlap 

GAO’s report on opportunities for collaboration and consolidation in housing programs identified 

a total of 88 HUD housing programs and 18 USDA housing programs. GAO reported overlap in 

HUD and USDA loan guarantee and rental assistance programs. 

1. Loan Guarantee Programs 

Both HUD, through the Federal Housing Administration (FHA), and the USDA’s Rural Housing 

Service (RHS) administer single-family and multi-family guaranteed loan programs. 

A. Single-Family Loan Guarantee Programs 

FHA and RHS single-family loan programs guarantee 30-year fixed-rate mortgages with little or 

no down payment and low up-front fees. The programs differ slightly in the extent to which the 

agencies cover losses to the lender, and RHS loan guarantees are limited by income and 

geography, but both serve the same basic purpose of helping homebuyers get access to credit.27

GAO has recommended that Congress require HUD and USDA to examine consolidation of 

certain housing assistance programs, and this program appears to be a prime candidate for 

such a consolidation.28 The Trump Administration proposed moving the single-family loan 

guarantee program to HUD in its 2018 government reorganization proposal.29

Data from single-family loan programs show overlap in the income and location of households 

served. USDA limits borrower income to 115 percent of area median income (AMI) for RHS 

single-family loan guarantees, and restricts participation to eligible rural areas. But FHA 

insures the majority of mortgages for borrowers eligible for both FHA and RHS programs. This 

fact calls into question whether a program specifically for rural homebuyers is needed, as 

current rural homebuyers are more likely to use FHA than RHS already.30 

In the last decade, first in 2012 and then in 2016, GAO issued two reports comparing FHA and RHS 

single-family loans. In 2012, GAO found that 1,291,000 (or 74 percent) of FHA borrowers met 

income eligibility requirements for RHS’s single-family loan guarantee program for fiscal year 

2009.31 FHA guaranteed more loans to borrowers with incomes at or below 115 of AMI than RHS 

and the VA combined that year.32 

In 2016, GAO reported that significant percentages of RHS borrowers could have met key criteria 

such as credit score, payment-to-income (PTI) ratio, debt-service-to-income (DTI) ratio, and 

loan size for FHA guaranteed home purchase loans for 2010-2014. This means most RHS 

borrowers could have used the FHA program. GAO estimated that of the 614,148 borrowers with 

RHS guaranteed loans from 2010-2014, 432,612 borrowers (or 70 percent) could have met those 

FHA loan guarantee criteria. These results were not unexpected, GAO noted, as RHS has 

relatively stricter benchmarks for credit score, PTI, and DTI ratios.33 
9 

The data also show significant overlap in geographic areas served. In 2015, 97 percent of the land 

area of the United States and 37 percent of the population was in RHS-eligible areas.34 In 2012, 

GAO reported that FHA served a larger number of borrowers in RHS-eligible areas than RHS.35

For fiscal year 2009, FHA guaranteed more than 210,000 loans in rural zip codes, compared to 

59,000 for RHS.36 The conclusion is that FHA is already serving rural Americans. 

For the years 2010-2014, FHA continued to serve more borrowers than RHS in RHS-eligible 

areas.37 Over this period, FHA guaranteed about 880,000 loans in RHS-eligible areas, compared 

with about 614,000 loans for RHS (a 36 percent difference).38 In 2018, the Office of Management 

and Budget reported that FHA guaranteed approximately 633,000 single-family loans in zip 

codes that were 100 percent USDA-eligible from fiscal years 2015 to 2017, compared to 258,000 

loans guaranteed by USDA.39 Further, of the 1,088,000 loans guaranteed by either FHA or USDA 

for calendar year 2018 (the most recent data available), FHA guaranteed about 90 percent of 

them.40 

The data is clear. FHA serves more borrowers that meet RHS eligibility requirements than RHS 

is serving. In the past, RHS helped rural populations face unique housing challenges. But many of 

these challenges requiring a separate, stand-alone agency in the Department of Agriculture no 

longer exist. Consolidating these programs could save money on duplicative government 

bureaucracy. 

B. Multi-Family Loan Guarantee Programs 

FHA and RHS multi-family loan programs help finance the development of new rental units or 

the preservation of existing units through refinancing or rehabilitation. The programs differ in 

property and tenant eligibility requirements. FHA-guaranteed loans can be used for any 

property nationwide and have no tenant income limits, while RHS loan guarantees are limited to 

rental properties in eligible rural areas that serve moderate-income tenants. 

But aspects of the programs are similar. Both programs guarantee 40-year, fixed-rate loans. 

Both programs set limits on the dollar amount that can be borrowed for each unit and the 

maximum property values that can be financed. And loan guarantees for both cover 90 percent 

of lender losses. 

Comparisons of multifamily guarantee programs show that properties financed with USDA 

guaranteed loan programs were more concentrated in rural areas, while properties financed 

with guaranteed loans through the selected HUD programs were concentrated primarily in 

urban and suburban areas.41 This trend indicates there is potentially less overlap in the 

geographic location of the population served than is seen with single-family loan guarantee 

programs. But similarities in the delivery structure of the multifamily programs suggests that 

consolidation could lead to a more streamlined and less bureaucratic experience. 

In its 2012 report, GAO noted RHS multifamily direct and guaranteed lending programs were 

more prevalent in rural areas than the much larger FHA multifamily guaranteed loan program. 

But other than to maintain existing properties, RHS was moving away from new direct loans in 

favor of more guaranteed loans. RHS multifamily properties also tended to be much smaller in 

terms of units than FHA, indicating RHS products served a unique market segment.42 HUD has 

made several attempts to pilot small project guaranteed loans in the past, and RHS has had 
10 

apparent success in guaranteeing such projects. The consolidation of multifamily programs 

could help transfer the successful aspects of RHS’ model to FHA, which reaches a broader 

population.

2. HUD and USDA Rental Assistance Programs 

HUD and USDA both administer project-based rental assistance (PBRA) programs. These 

programs provide rental subsidies to property owners that provide housing for low-income 

households. In 2012, GAO compared USDA’s Rural Rental Assistance Payments (Section 521) 

with HUD project-based rental assistance. GAO stated these programs were similar in that they 

provide direct payments to rental property owners on behalf of tenants for a designated number 

of units. The payments are subject to contracts with property owners (generally for one year), 

and property owners are responsible for ensuring households meet program eligibility 

requirements. But the programs differ in contract administration. HUD contracts are managed 

through state or local housing authorities, while USDA contracts are managed directly via USDA 

national, state, and local offices.43 

Despite these differences, OMB in 2018 proposed moving USDA’s rental housing programs to 

HUD. OMB noted that because HUD serves all communities across the nation, there is no clear 

need for USDA to administer separate, rural-focused housing programs. Further, the programs 

share the same general goal of making rent affordable to low-income tenants by paying the 

difference between a unit’s rent and 30 percent of a household’s adjusted income.44 

Given the similarities, OMB proposed consolidating programs under HUD, both as a first step 

toward improving operational efficiency and service delivery, and to produce savings by 

reducing agency bureaucracy costs.45 This proposal aligns with the 2012 GAO report, which found 

that the RHS did not have the same access to wage matching data as HUD, even though those 

data are needed to assure the accuracy of rental payments under RHS rental assistance 

programs.46 In addition to less overhead, placing these rental assistance programs under one 

agency would eliminate the need to negotiate separate data sharing agreements. This is one 

example of an increase in operational efficiency that could result from sensible consolidation. 

B. HUD’s Rental Assistance Programs Serve Similar Populations 

1. HUD’s Three Primary Rental Assistance Programs 

In FY 2019, rental assistance accounted for 79 percent of HUD’s discretionary appropriations.47

The three main HUD rental assistance programs are: 

 

 Public Housing. Created by the Housing Act of 1937, the Public Housing program was 

established to provide rental housing for low-income families, the elderly, and the 

disabled.48 HUD provides aid to local housing agencies that manage properties for lowincome residents at affordable rents.49 Families in public housing generally pay rent 

equal to 30 percent of their adjusted gross income.50 

 

 Housing Choice Vouchers. The Housing Choice Voucher (HCV) program helps very lowincome families (those with incomes at or below 50 percent of the local area median 
11 

income), the elderly, and the disabled afford housing in the private market.51 Local public 

housing agencies (PHAs) administer these “portable” vouchers, which recipients can use 

to lower their rents.52 

 

 Project-Based Section 8. Section 8 project-based rental assistance (PBRA) gives 

subsidies directly to the owners of multifamily housing subsidizing the rent for specific 

rental units.53 

Together, these three programs account for the overwhelming majority of HUD rental 

assistance funding and HUD-subsidized households. A closer look at them illustrates why the 

nation’s housing programs need a complete review. 

2. Multiple Programs Serving Similar Populations 

The existence of multiple low-income housing programs could be justifiable if the separate 

programs served different populations with distinct housing needs. But while HUD’s main rental 

assistance programs deliver assistance in different ways, they each have similar eligibility rules 

and serve largely similar populations. 

Eligibility for HUD rental assistance is generally limited to households that have incomes at or 

below 50 percent of the HUD area median income (AMI). Additionally, federal income targeting 

rules require a certain minimum percentage of newly assisted households in public housing, 

project-based rental assistance, or the Housing Choice Voucher program to be “extremely lowincome” (i.e., with incomes at or below 30 percent of the area median income). 

For each program, about three-quarters of assisted households have incomes at or below 30 

percent of the area median income.54 Because over 60 percent of units in privately owned 

multifamily projects are efficiencies or one-bedroom units, units in project-based Section 8 tend 

to be somewhat older, smaller, and less likely to include children than households receiving 

public housing or vouchers.55 Otherwise, resident characteristics are largely similar across 

HUD’s three major rental assistance programs, as demonstrated in Table 2. 

 
12 

Table 2: HUD-Subsidized Households in 2019 

 

All HUD 

Programs 

Public 

Housing 

Housing 

Choice 

Vouchers 

ProjectBased 

Section 8 

Smaller 

Multifamily 

Programs 

Households (thousands) 4,619 915 2,300 1,218 188 

People (thousands) 9,440 1,909 5,249 2,063 218 

Avg. Household Size 2 2.1 2.3 1.7 1.2 

Avg. Household Income 14,835 15,738 15,373 13,301 13,787 

% Extremely Low Income 75% 72% 75% 77% 75% 

% of Residents with a 

Disability 

23% 24% 24% 18% 26% 

% Households Age 62+ 37% 34% 28% 50% 75% 

% of Households with 

Children 

36% 37% 41% 27% 4% 

% of Households in 1-

bedrooms 

44% 41% 32% 62% 93% 

% Minority 65% 71% 70% 56% 50% 

Source: 2019 data from HUD’s Picture of Subsidized Households, https://www.huduser.gov/portal/datasets/assthsg.html (last 

visited Oct. 2, 2020). “Smaller Programs” includes Moderate Rehabilitation, Rental Assistance Program, Rent Supplement, the 

Section 236 program, the Section 221(d)(3) Below Market Interest Rate, Section 202 Housing for the Elderly, and Section 811 

Housing for Persons with Disabilities.

Smaller project-based programs, such as Housing for the Elderly (Section 202) and Housing for 

Persons with Disabilities (Section 811), are targeted to particular demographic groups. The 

former is open to very low-income households with at least one person age 62 years or older, 

while the latter is open to very low-income persons with disabilities who are between 18 and 62 

years of age.56 But HUD’s larger rental assistance programs also serve many households with 

elderly or disabled members, with the Housing Choice Voucher program serving more elderly 

households and people with disabilities than any other HUD rental assistance program. 

There are some regional differences in the populations receiving assistance from different HUD 

programs. Public housing tenants are most concentrated in the Northeast, while the voucher 

program has a regional distribution that more closely tracks the distribution of all very-low 

income renters. Roughly a third of all HUD-assisted housing is in the South (see Table 3). 

Table 3: Distribution of HUD-Assisted Housing by Region in 2017 

Census 

Region 

Tenants in Public 

Housing 

Voucher Recipients Tenants in Privately 

Owned MF Units 

All Very-Low 

Income Renters 

Northeast 36.5% 24.4% 26.8% 22.0% 

Midwest 21.4% 19.2% 26.7% 20.3% 

South 33.4% 33.4% 31.6% 35.2% 

West 8.8% 22.9% 14.8% 22.4% 

Source: HUD’s Characteristics of HUD-Assisted Renters and Their Units in 2017 (March 2020), 

https://www.huduser.gov/portal/sites/default/files/pdf/HUD-Assisted-Renters-2017.pdf (last visited Oct. 2, 2020). 
13 

This is more attributable to the age of the programs than any regional differences in housing 

needs or program efficacy. The majority of public housing units were built before 1970 and were 

concentrated in the urban centers of the Northeast.57 

3. Why So Many Rental Assistance Programs? 

Given all the overlap and duplication among the 160 programs GAO identified, the natural 

question is why do so many programs exist? 

First, the history of housing programs reflects an evolution from public housing, to subsidized 

private housing, to vouchers. Public housing was the only major form of housing assistance until 

the 1960s, and a majority of currently occupied units were built before 1969.58 Privately-owned 

and subsidized housing programs were rolled out in the 1960s, and their production accelerated 

after 1974 when Section 8 project-based rental assistance was created. By the 1980s these 

privately-owned programs accounted for a plurality of HUD-assisted units. Since then, the 

inventory of privately-owned and subsidized housing has declined. Owners can choose not to 

renew their contracts with HUD once they expire and instead rent out their properties at market 

rates. Many opted out in the 1990s and early 2000s. Tenant-based assistance began in 1974, and 

the voucher program is now HUD’s largest low-income housing subsidy program. 

These developments reflect changing evidence on the effectiveness of different programs and 

attitudes towards how housing assistance should be delivered. Over time, evidence emerged 

highlighting problems with the federal government’s primary mechanisms for providing housing 

assistance—first public housing and then privately owned subsidized projects—suggesting that 

new approaches were needed. As early as the 1950s, for example, many began to recognize 

issues with the public housing program and how it contributed to racial and economic 

segregation.59 In the 1970s, new research found that programs creating new, subsidized housing 

did not help those who lived in physically adequate housing, but could not make rent.60 

Another reason for the large number of rental assistance programs is that some had aims 

beyond delivering housing assistance. When the Housing Act was first enacted during the Great 

Depression, it was partially justified as a public works program that would create jobs for the 

construction sector.61 Slum clearance was also a major goal of public housing in the early years 

of the program.62 And later programs had the goals of furthering civil rights and reducing 

segregation.63 These separate historical aims help explain the proliferation of housing programs 

and the lack of coherence in the federal government’s approach to housing. 

A final reason for the large number of rental assistance programs is politics. An enacted housing 

bill was to some “a Christmas tree bill bearing gifts for all,” noted a HUD report from the 1970s.64

In the housing context, as elsewhere, old programs endure because of powerful political 

constituencies and fear that a new program may not work as well. These political forces can 

shape not only the contours of policy, but also lead to the existence of multiple, complicated 

programs in multiple jurisdictions. In 1973, for example, the Nixon Administration announced a 

moratorium on new expenditures for subsidized low-income housing programs, and suggested 

a policy of direct assistance to tenants. This shift was forcefully opposed by interest groups 

representing builders, local governments, and others who benefited from existing projectbased housing programs. The ensuing debate in Congress ultimately led to the Housing and 
14 

Community Development Act of 1974, which introduced tenant-based assistance while also 

significantly expanding project-based programs.65

Many housing policy experts have argued that tenant-based vouchers that directly subsidize 

low-income renters are in many ways superior to programs subsidizing the production and 

operation of low-income housing.66 But while the problems of project-based assistance have 

been known for many years, such programs continue to account for about half of all HUDassisted households and about half (47 percent)of HUD’s budget.67 This is partly because some 

remain concerned that a total shift toward vouchers would make affordable housing less 

available, or that certain groups would be unable to find suitable housing, despite limited 

evidence supporting these claims.68 

Project-based programs also have strong constituencies that support their continuation. 

Indeed, some experts contend that the proliferation of multiple separate housing assistance 

programs for low-income families was “due more to political forces than any coherent overall 

plan or policy motivation.”69 

In 1995, for instance, the Clinton Administration proposed consolidating about 60 individual HUD 

programs into three performance-based block grants, and replacing the entire federal system 

of public and assisted housing tied to project subsidies with vouchers issued to tenants.70 But 

while subsequent legislation merged earlier forms of tenant-based assistance into the Housing 

Choice Voucher program, there was no sweeping consolidation of programs or a complete shift 

from place-based subsidies to vouchers. This ensured that the status quo remains. The lack of 

comprehensive review and piling of program upon program is not limited to these examples, as 

demonstrated in the next section. 

C. The HOME Program and the Housing Trust Fund Overlap 

The Housing Trust Fund (HTF) and the HOME Investment Partnerships Program (HOME), both 

within HUD, are overlapping programs that should be consolidated or streamlined. Each are 

examples of programs with good intentions, but similar goals. They evidence an ongoing issue: 

whenever a new problem arises, a new program is created rather than reforming our existing 

programs to address the issue. 

1. The Housing Trust Fund 

The Housing and Economic Recovery Act of 2008 established the HTF to provide funds to states 

to use for affordable housing, particularly for rental housing for extremely low-income 

households.71 

The HTF provides formula-based grants to states to use for affordable housing. By law, each 

state and the District of Columbia receives a minimum annual grant of $3 million. Most funds 

must go toward rental housing, but states can use up to 10 percent of grants for certain 

homeownership activities. Grantees and any subgrantees must submit plans to HUD explaining 

how they will allocate HTF funds.72

HUD administers the HTF, but Fannie Mae and Freddie Mac fund it.73 Most recently, in February 

2020, the Federal Housing Finance Agency authorized a disbursement of $326.4 million to HUD 

for the HTF.74 States have received $660 million in HTF allocations since 2016.75
15 

2. HOME Investment Partnerships Program 

The National Affordable Housing Act of 1990 authorized the HOME program, which gives funding 

to states and localities for affordable housing activities benefiting low-income households.76

These block grant funds are used for four purposes: the rehabilitation of owner-occupied 

housing; assistance to home buyers; the acquisition, rehabilitation, or construction of rental 

housing; and tenant-based rental assistance.77 HOME funds may also be used for demolition, 

relocation, and other activities.78 Similar to the HTF, eligible states or localities must submit 

plans to HUD explaining how they will allocate HOME funds.79

HUD receives an annual appropriation for HOME, which it disburses by formula: 40 percent to 

states and 60 percent to localities.80 The HOME program received $1.35 billion in funding for fiscal 

year 2020.81 The Trump Administration has proposed eliminating the program, noting it has been 

unauthorized since 1994.82

3. The Programs’ Similarities Show Redundancy and Overlap 

 These two programs have several similarities, as shown in Table 4: 

Table 4: The Housing Trust Fund and HOME Program

 

 

 

 
16 

Table 4: The Housing Trust Fund and HOME Program (cont’d.) 

Source: U.S. Department of Housing and Urban Development, Comparison of Housing Trust Fund and the HOME Investment 

Partnerships Program, https://files.hudexchange.info/resources/documents/Comparison-Chart-HTF-vs-HOME.pdf (last 

visited Oct. 8, 2020). 

As shown above, these two affordable housing block grant programs are identical in terms of 

their allocation (by formula), administrative funds (up to 10 percent of the annual grant and 

program income received), and fund commitment and expenditure deadlines (24 months/5 

years). Both have a minimum grant threshold of $3 million, though an “alternate methodology” 

may be used for the HTF if minimum funding isn’t available. They also have the same overall 

goal—affordable housing—and are even administered by the same office within HUD: the Office 

of the Assistant Secretary for Community Planning and Development.83 To be sure, these 

programs have some differences, as in the areas of minimum income targeting, eligible 

activities, and the limitations on those activities. But on balance, the similarities show that 

opportunities for efficiencies and consolidation exist. 

These similarities are not surprising. According to the Congressional Research Service, the 

HTF’s critics argued that “the federal government already provides funding for affordable 

housing through other programs, including flexible block grant programs such as the HOME 

program,” and that the HTF “is duplicative of other programs since the activities that it funds are 

also eligible uses of other sources of federal funds.”84 
17 

In a 2010 proposed rule implementing the HTF, HUD stated that “[t]he HOME program is similar in 

most aspects to the proposed HTF,” and that “[m]any of the program requirements applicable to 

the HOME program are applicable to the HTF.” HUD also said they “modeled” the HTF regulations’ 

organization after the HOME program’s regulations, and “elected to adopt many existing HOME 

program requirements.”85

Consolidating or streamlining these two programs, established less than two decades apart, 

would be advantageous for several reasons. First, service delivery could improve if HUD 

administered a single program, rather than two similar ones. Second, merging the programs 

would likely lower their administrative costs, ultimately allowing more money to flow to the 

neediest recipients. Third, consolidation or harmonizing program requirements would cut down 

on the need for grantees to create multiple plans for similar projects, reducing red tape, 

confusion, and regulatory burdens for potential applicants. Finally, a single program would have 

one bureaucracy instead of two, allowing HUD to more efficiently allocate staff expertise and 

other resources. 

D. The Lack of Cost Data Hinders Program Evaluation 

For many of the federal housing assistance programs surveyed, basic information about the 

administrative costs of these programs, and the number of full-time equivalent (FTE) employees 

working on them, is not publicly available. 

Such information may be found occasionally by office. But “offices” within federal agencies can 

administer multiple programs and have hundreds, or even thousands, of employees. Someone 

looking for basic cost and FTE data about a specific program is usually out of luck. 

This lack of transparency raises serious questions about the true costs of these programs and 

how well agencies administer them, including how they allocate staff and other resources. It 

also prevents quantitative analysis of what savings might result from streamlining or 

consolidating these programs. 

The administrative costs of such programs should be publicly available. That way Congress, 

independent auditors, and other advocates could evaluate the cost-effectiveness of improving 

and reforming these programs. Any program should always be able to determine how many 

people are working to administer it and how much the administrative costs are. 

E. The Federal Government Also Supports Housing Through Billions 

in Tax Expenditures 

The federal government provides significant and costly support for housing through a number of 

tax provisions benefiting homeowners and builders. 

While identifying such “tax expenditures” is somewhat subjective and there is no definitive list, 

the Joint Committee on Taxation and the Treasury Department both identify the following 

housing-related provisions as tax expenditures: 
18 

Table 5: Housing-Related Tax Expenditures, 2019 

Provisions FY 2019 estimate 

(in millions) 

Capital gains exclusion on home sales $43,610 

Deductibility of mortgage interest $25,130 

Low Income Housing Tax Credit $8,760 

Accelerated depreciation on rental housing $8,000 

Deductibility of State and local property tax $6,010 

Deferral of income from installment sales $1,460 

Exclusion of interest on rental housing bonds $1,030 

Exclusion of interest on owner-occupied 

mortgage subsidy bonds 

$790 

Source: Treasury Department, https://home.treasury.gov/policy-issues/tax-policy/tax-expenditures (last visited Oct. 2, 2020). 

Each expenditure is briefly explained in Table 6: 

Table 6: Housing-Related Tax Expenditures, In Brief 

Capital gains exclusion on home sales. Typically, when 

taxpayers sell an asset for more than its purchase price, 

they pay capital gains taxes on any profits realized from 

the sale. But homeowners may exclude from taxable 

income up to $250,000 (or $500,000 if filing jointly) of 

capital gains from the sale their house if it has been their 

principal residence for at least two of the five years 

preceding the sale. 

Mortgage interest deduction. Taxpayers who itemize 

may deduct mortgage interest paid on their primary 

residence and one secondary residence. The deduction 

is typically limited to interest on mortgage debt of no 

more than $1 million, but for tax years beginning after 

December 31, 2017, and before January 1, 2026, the $1 

million limit is reduced to $750,000 for mortgage debt 

incurred after December 15, 2017. This deduction 

primarily benefits higher-income taxpayers who are 

more likely to itemize, face higher marginal tax rates, 

and have larger mortgages. The Tax Policy Center 

estimates over 90 percent of the tax benefits of the 

deduction went to taxpayers with incomes over $100,000 

in 2018.86 

The Low Income Housing Tax Credit (LIHTC). The LIHTC 

was created by the Tax Reform Act of 1986 and has 

become the federal government’s largest policy tool for 

the development of affordable rental housing.87

Generally, the federal government issues the credits to 

states, which allocate them to private developers who in 

turn sell them to investors for equity financing.88 The 

credit is not targeted to the lowest income households. 

Less than half of LIHTC tenants in 2015 had incomes at or 

below 30 percent of AMI.89 The Internal Revenue Service 

and state housing finance agencies administer the 

LIHTC.90

Accelerated depreciation on rental housing. The tax 

code allows new rental housing to be depreciated in 

equal amounts over 27.5 years. This can be considered a 

tax expenditure compared to a “pure” comprehensive 

income tax, as it allows rental housing to be depreciated 

faster than the property’s estimated loss of economic 

value over time. 

Property tax deduction. Though never intended to 

encourage homeownership,91 the property tax deduction 

is another tax benefit assisting homeowners. 

Homeowners who itemize may deduct State and local 

property taxes paid on real property. For taxable years 

beginning after December 31, 2017, and before January 1, 

2026, the deduction for state and local taxes is limited to 

$10,000. As with the mortgage interest deduction, 

higher-income households generally see the greatest 

benefit from the deduction. In 2018, over 80 percent of 

the deduction’s benefits went to taxpayers with incomes 

above $100,000.92 

Deferral of income from installment sales. An 

installment sale is a sale of property in which some 

payments are received after the year the sale occurs. 

Certain taxpayers selling real estate property can 

effectively defer taxes on income from up to $5,000,000 

of installment sales, with transactions where the sales 

price is less than $150,000 not counting toward the 

limit.93 

Exclusion of interest on rental housing bonds and 

mortgage subsidy bonds. Interest earned on state and 

local bonds used to finance multifamily rental housing 

projects or mortgage subsidies for first-time 

homebuyers is exempt from tax. These bonds are 

subject to a state’s annual volume cap on private activity 

bonds. 
 19 

The interaction between these expenditures and the housing assistance system is beyond the 

scope of this report. But the LIHTC and its overlap with other federal housing assistance 

programs warrants mention. 

The LIHTC overlaps with various housing programs, but perhaps most conspicuously with 

project-based Section 8 and the tenant-based Housing Choice Voucher program.94 The reasons 

for this redundancy are complex,95 but one consideration is that the LIHTC is intended to be used 

with other programs. For example, state housing finance agencies that award LIHTCs require 

that projects have funding in addition to LIHTC equity. Developers may cover funding gaps with 

HOME and HTF dollars, in addition to other loans and grants, and HOME itself has a leveraging 

requirement. And the LIHTC can be combined with rental assistance, typically project-based 

vouchers, to make units affordable to the lowest-income households. Thus, a low-income 

housing developer in a given city might build low-income rental housing by relying on various 

subsidy sources. From 2009-2016 in California, for example, 90 percent of approved projects had 

at least two other development funding sources beyond a conventional first mortgage and tax 

credits, two-thirds had at least three, and more than a fifth had at least five.96

Overlap also occurs at the recipient level. Half of LIHTC households receive other forms of rental 

assistance.97 How much overlap is difficult to quantify because estimates vary widely. A 2018 

Urban Institute report stated, “[a]lthough overall LIHTC costs appear to be about one-fifth the 

cost of all other major federal housing assistance programs combined, overlap with other 

federal housing assistance programs (anywhere from 18 to 70 percent of LIHTC residents 

receive other rental assistance) makes it difficult to disentangle cost by program . . . .”98 This 

makes untangling the duplication regarding LIHTC even more challenging. Making matters 

worse, the LIHTC’s performance has been called “woeful.”99

LIHTC is another example of our balkanized housing system. It illustrates how overlap can occur 

at both the program and individual levels, making it harder to assess program costs, 

performance, and effectiveness. The complexity should be simplified. Congress can start the 

process of evaluating and reforming these programs so they operate in a thoughtful, costeffective manner. 

 
 20 

4. MAJOR FINDINGS AND CONCLUSIONS 

We Must Improve and Simplify an Overly Complex System 

This report makes the following findings:

1. The federal housing assistance system is failing those who need it most. All too often, it 

serves the bureaucracy. Few, if given the chance, would design a system to look like the 

current one. 

2. Merging programs to eliminate duplication and overlap will make funding for housing 

programs go further. These programs, in turn, would be able to serve more people 

because they would be less confusing. This would make solutions easier to find and 

utilize. Reform would also push federal employees to focus on finding the best solutions 

for those seeking assistance as opposed to trying to preserve their isolated programs. 

3. We spend billions each year on federal housing assistance, but the system is duplicative 

and too complicated. 

4. Decades of shifting federal priorities have led to a system that is a patchwork of 

programs, laws, and regulatory red tape across multiple agencies. Congress over the 

years has had one good idea after another, but by default created a system that is too 

confusing to be efficient or effective. 

5. Basic information about the administrative costs of housing assistance programs, and 

the number of employees who work on them, is not publicly available. Among other 

challenges, this lack of transparency prevents objective analysis about where savings 

could be found. 

6. Our current approach is no way to deliver services to the neediest Americans or 

responsibly steward billions in taxpayer dollars. 

7. Congress should undertake bipartisan review and reforms to create a modern housing 

assistance program to improve effectiveness and efficiency. A September 2020 Senate 

Budget Committee roundtable revealed bipartisan support for several reform ideas with 

certainly more areas for review. 

8. Reformers suggest HUD is the most logical agency to house these programs, given its 

mission “to create strong, sustainable, inclusive communities and quality affordable 

homes for all.”100

 
 21 

Our System is Failing People and Needs Reform 

The system is failing people now. Some may fear that a different approach could mean that their 

needs will not be met in the same way. There may be a certain comfort in the existing 

dysfunction. But a dysfunctional system, no matter how familiar it may be, does not best serve 

those in need. 

As highlighted during the Senate Budget Committee roundtable, we spend billions on housing 

assistance, yet over half a million people are homeless each night.101 There are years-long 

waiting lists for public housing. Studies have shown that public housing and project-based 

programs can trap families in high-poverty neighborhoods, with significant long-term 

consequences for their health and well-being. Programs are scattered across agencies, 

creating confusion and headaches for those seeking assistance. During the roundtable, a robust 

discussion suggested we could provide assistance to more families through vouchers, which 

have been shown to be more cost-effective than place-based programs. 

Streamlined programs and fewer bureaucrats would not mean less direct assistance to those in 

need. Instead, it could mean less administrative costs, including expensive bureaucratic 

salaries, and fixing or consolidating underperforming programs. It would also mean more 

dollars to the programs that are effective and actually making a difference. 

Yet some insist that spending more money is the answer. More money does not equal better 

housing. In light of the nation’s declining fiscal condition, the better approach is to carefully 

assess what is and is not working, before throwing billions more at a flawed system. The savings 

realized from consolidating or simplifying programs could then go toward helping needy 

families and others. “Well-designed” reforms, argued roundtable witness Professor Olsen, 

“would not only alleviate poverty, but also largely eliminate homelessness and evictions.”102

Objections to Reform Fall Short 

Some will object to any housing reform effort. Their anticipated objections to changing our 

current system are addressed below. 

Objection: We Need Different Programs for a Massive, Sprawling Nation 

Critics may argue that multiple housing assistance programs are needed in the United States, 

given its tremendous regional and other variations. But the populations served by housing 

assistance programs are actually quite similar across programs. 

A look at the programs’ overlapping recipients supports this conclusion. HUD programs benefit 

people in rural areas, for example, and USDA programs benefit urban residents. Over 2 million 

suburban and rural households rely on HUD programs for housing, while nearly 30 percent of 

households receiving USDA’s Rural Rental Assistance are in suburban and urban areas.103 As 

noted previously, half of LIHTC households get additional federal or state rental assistance 

according to one estimate.104 These populations may be distinct, but they are united in their 

common need for affordable housing. 

Others may claim that housing programs’ differences are so pronounced and extensive that 

“apples to apples” comparisons between programs are impossible. Thus, they reason, one 
 22 

should not even try to compare and streamline them. If even basic comparisons and oversight 

are not possible, this only proves our point: the system is unmanageable and needs reform. 

Ultimately, opposing reform because the housing system has “nuances” or “complexity” strikes 

an almost cynical, “why bother?” tone. Differences in programs or their beneficiaries, even if 

profound, are no reason to keep the status quo. 

As to the efficacy of the programs themselves, numerous programs are not needed. Many 

experts persuasively contend, for instance, that tenant-based vouchers are superior to projectbased rental assistance, public housing, and the LIHTC. HUD’s Housing Choice Voucher program 

is by far the most cost-effective low-income housing program, as Professor Olsen and others 

have found, and it is simpler and performs better than the LIHTC.105 

Objection: Reformers Only Want to Help Their Preferred Causes, Not the Poor 

Another likely objection is that reformers simply want to funnel money away from the poorest 

Americans to their preferred causes. Housing reformers aren’t failing the poor; the current 

system is. Take, for example, the New York City Housing Authority (NYCHA). The Wall Street 

Journal has noted how “[r]ats, roaches, mold and leaks have long abounded at the nation’s 

largest public housing authority with some 174,000 apartments.”106 Such conditions are 

appalling, and sadly not unique to New York City. These living conditions can color one’s entire 

outlook, negatively affect their health, and have far-reaching effects on a person and how they 

interact in society. Successful federal housing programs would not let people live in rodentinfested squalor. That is why this report calls for reform: to better assist those Americans. It is 

not about harming those in need, it is about helping them. 

This report is also about a Rube Goldberg-style bureaucracy that has grown out of control. HUD 

alone administers a whopping 73 housing assistance programs.107 Congress appropriated $258 

billion to those 73 programs just between fiscal years 2014 and 2018.108 

As for NYCHA, nearly 90 percent of its 174,000 apartments lost heat or hot water during the 

winter of 2018-2019.109 The agency’s federal monitor, observing that NYCHA was unlikely to meet 

its own goal of completing lead testing by the end of 2020, estimated that 74,000 apartments will 

ultimately be found to have lead paint.110 And because NYCHA is mostly federally funded, it is not 

just a local issue.111 These housing bureaucracies, at various levels of government, have 

metastasized to the point that they are failing those they should be serving. The above objections 

are unconvincing, and should be rejected. 

A Path Forward for Helping the Neediest 

Congress, the Executive Branch, and others must conduct the necessary work of improving our 

multibillion-dollar housing assistance system. At a minimum, Congress should (1) begin to 

address the already-identified duplication and overlap, and (2) identify which programs 

demonstrate the best performance and cost-effectiveness. Congress should target the highperforming programs first when making any funding decisions. To be successful, this effort will 

require the relevant congressional committees to resolve any jurisdictional issues. 

Congress should also explore ways to expand and incentivize the use of vouchers, which 

enjoyed bipartisan support at the Budget Committee’s housing roundtable. Some say a key 

shortcoming of vouchers is landlords will not accept them. The reasons for refusal are varied, 
 23 

but one study found that three key factors for landlords are financial motivation, perception of 

tenants, and bureaucratic factors.112 To address these issues, Congress should explore the 

desirability and cost-effectiveness of federal source of income protections, as well as ways to 

positively incentivize landlords to accept vouchers, perhaps by providing a bonus for the first 

voucher recipient a landlord accepts. 

Reluctance to disturb the status quo, or citing its complexity to fend off reforms, will only 

perpetuate a flawed system. And ensuring full employment for bureaucrats is surely no reason 

to keep funding redundant federal programs year after year. 

Our dysfunctional housing system does not best serve those in need. We can and should do 

better, both for present and future generations. 
 24 

APPENDIX: GAO’s Inventory of Housing Assistance 

Programs 

Activity or Program Name Administering Agency or Entity

1 Accelerated depreciation on rental housing Internal Revenue Service 

2 Adjustable Rate Mortgages (Section 251) Department of Housing and Urban Development 

3 Affordable Housing Program Federal Home Loan Banks 

4 Agency Mortgage-Backed Securities Purchase Program Federal Reserve System 

5 Assisted-Living Conversion Program Department of Housing and Urban Development 

6 

Capacity Building for Community Development and 

Affordable Housing Department of Housing and Urban Development 

7 Capital gains exclusion on home sales Internal Revenue Service 

8 Choice Neighborhoods Department of Housing and Urban Development 

9 

Community Development Block Grant (CDBG) Section 

108 Loan Guarantee Department of Housing and Urban Development 

10 

Community Development Block Grant (CDBG) Disaster 

Recovery Assistance Department of Housing and Urban Development 

11 

Community Development Block Grant (CDBG) Insular 

Areas Department of Housing and Urban Development 

12 

Community Development Block Grant (CDBG) Section 

107 Department of Housing and Urban Development 

13 

Community Development Block Grants (CDBG) 

Entitlement Department of Housing and Urban Development 

14 

Community Development Block Grants (CDBG) States 

and Small Cities Department of Housing and Urban Development 

15 

Community Development Financial Institutions (CDFI) 

Fund Department of the Treasury 

16 Community Investment Program Federal Home Loan Banks 

17 Community Reinvestment Act (CRA) 

Federal Financial Regulators (Federal Reserve Board, 

Federal Deposit Insurance Corporation, and Office of the 

Comptroller of the Currency) and the Federal Financial 

Institutions Examination Council (FFIEC) 
 25 

Activity or Program Name Administering Agency or Entity

18 

Counseling for Homebuyers, Homeowners, and Tenants 

(Section 106) Department of Housing and Urban Development 

19 Deduction for mortgage insurance premiums Internal Revenue Service 

20 Direct Loans for Certain Disabled Veterans Department of Veterans Affairs 

21 District of Columbia first-time homebuyer tax credit Internal Revenue Service 

22 Dollar Home Sales Department of Housing and Urban Development 

23 Emergency Capital Repairs Program Department of Housing and Urban Development 

24 Energy Efficient Mortgage Insurance Department of Housing and Urban Development 

25 Energy Innovation Fund: Multifamily Energy Pilot Department of Housing and Urban Development 

26 Energy Innovation Fund: Single Family Pilot Department of Housing and Urban Development 

27 Enforcement of the Fair Housing Act (Title VIII) Department of Housing and Urban Development 

28 

Ensure the timely payment of principal and interest on 

insured Farm Credit System debt obligations purchased 

by investors. Farm Credit System Insurance Corporation 

29 Equal Credit Opportunity Act (ECOA) 

Consumer Financial Protection Bureau (CFPB) and Federal 

Financial Regulators (Federal Reserve Board, Federal 

Deposit Insurance Corporation, National Credit Union 

Administration, and Office of the Comptroller of the 

Currency) and the Federal Financial Institutions 

Examination Council (FFIEC) 

30 Exclusion of forgiven mortgage debts Internal Revenue Service 

31 FFIEC Appraisal Subcommittee Federal Financial Institutions Examination Council 

32 Fair Housing Assistance Program (FHAP) Department of Housing and Urban Development 

33 Fair Housing Initiatives Program (FHIP) Department of Housing and Urban Development 

34 Family Unification Program Department of Housing and Urban Development 

35 

Fannie Mae: Purchase mortgage loans and issue 

mortgage-backed securities Fannie Mae 

36 

Federal Guarantees for Financing for Tribal Housing 

Activities (Title VI) Department of Housing and Urban Development 
 26 

Activity or Program Name Administering Agency or Entity

37 Federal Housing Administration (FHA) Short Refinance 

Department of the Treasury and Department of Housing 

and Urban Development 

38 First-time homebuyer tax credit Internal Revenue Service 

39 

Freddie Mac: Purchase mortgage loans and issue 

mortgage-backed securities Freddie Mac 

40 Good Neighbor Next Door Department of Housing and Urban Development 

41 Graduated Payment Mortgage (Section 245(a)) Department of Housing and Urban Development 

42 

Grants to States for Low-income Housing Projects in 

Lieu of Low-income Housing Credits Program (Section 

1602 Program) Department of the Treasury 

43 Green Retrofit Program for Multifamily Housing Department of Housing and Urban Development 

44 Growing Equity Mortgage Insurance (Section 245(a)) Department of Housing and Urban Development 

45 

Guarantee the timely payment of principal and interest 

on mortgage-backed securities backed by governmentguaranteed loans Government National Mortgage Association (Ginnie Mae) 

46 HOME Investment Partnerships Program Department of Housing and Urban Development 

47 HOPE for Homeowners Department of Housing and Urban Development 

48 Healthy Homes Program Department of Housing and Urban Development 

49 Historic preservation tax credit (20 percent) Internal Revenue Service and National Park Service 

50 

Home Equity Conversion Mortgage Program (Section 

255) Department of Housing and Urban Development 

51 Home Mortgage Disclosure Act of 1975 (HMDA) 

Consumer Financial Protection Bureau (CFPB) and Federal 

Financial Regulators (Federal Reserve Board, Federal 

Deposit Insurance Corporation, National Credit Union 

Administration, and Office of the Comptroller of the 

Currency) and the Federal Financial Institutions 

Examination Council (FFIEC) 

52 Homeownership Voucher Assistance Department of Housing and Urban Development 

53 Housing Assistance Council (HAC) Department of Housing and Urban Development 

54 Housing Choice Voucher Program Department of Housing and Urban Development 

55 

Housing Finance Agency Initiative: New Issue Bond 

Program Department of the Treasury 
 27 

Activity or Program Name Administering Agency or Entity

56 

Housing Finance Agency Initiative: Temporary Credit and 

Liquidity Program Department of the Treasury 

57 

Housing Finance Agency Innovation Fund for the Hardest 

Hit Housing Markets (Hardest Hit Fund or HHF) Department of the Treasury 

58 Housing Finance Authority Risk Sharing (Section 542(c)) Department of Housing and Urban Development 

59 Housing Improvement Program (HIP) Department of the Interior 

60 Housing Opportunities for Persons with AIDS (HOPWA) Department of Housing and Urban Development 

61 Housing Trust Fund (HTF) Department of Housing and Urban Development 

62 Increased standard deduction for property taxes Internal Revenue Service 

63 

Indian Community Development Block Grant (ICDBG) 

Program Department of Housing and Urban Development 

64 Indian Housing Block Grant Department of Housing and Urban Development 

65 

Institutions of the Farm Credit System, which include the 

Agricultural Credit Bank and Farm Credit Banks, provide 

financed credit to agricultural and rural communities Farm Credit System 

66 

Insured Mortgages on Hawaiian Home Lands (Section 

247) Department of Housing and Urban Development 

67 Insured Mortgages on Indian Land (Section 248) Department of Housing and Urban Development 

68 Lead Hazard Reduction Demonstration Grants Department of Housing and Urban Development 

69 Lead Hazard Reduction Technical Studies and Support Department of Housing and Urban Development 

70 Lead-Based Paint Hazard Control Grants Department of Housing and Urban Development 

71 Loan Guarantees for Indian Housing (Section 184) Department of Housing and Urban Development 

72 

Loan Guarantees for Native Hawaiian Housing (Section 

184A) Department of Housing and Urban Development 

73 Loss Mitigation Department of Housing and Urban Development 

74 Low-income housing tax credit Internal Revenue Service 

75 Mainstream Vouchers Department of Housing and Urban Development 
 28 

Activity or Program Name Administering Agency or Entity

76 Making Home Affordable (MHA) Department of the Treasury 

77 Manufactured Home Construction and Safety Standards Department of Housing and Urban Development 

78 Manufactured Homes Loan Insurance (Title I) Department of Housing and Urban Development 

79 Mark-to-Market Program Department of Housing and Urban Development 

80 

Mortgage Insurance for Condominium Units (Section 

234(c)) Department of Housing and Urban Development 

81 

Mortgage Insurance for Cooperative Housing (Section 

213) Department of Housing and Urban Development 

82 

Mortgage Insurance for Disaster Victims (Section 

203(h)) Department of Housing and Urban Development 

83 

Mortgage Insurance for Manufactured Home Parks 

(Section 207) Department of Housing and Urban Development 

84 

Mortgage Insurance for Older, Declining Areas (Section 

223(e)) Department of Housing and Urban Development 

85 

Mortgage Insurance for Purchase or Refinancing of 

Existing Multifamily Rental Housing (Sections 

207/223(f)) Department of Housing and Urban Development 

86 

Mortgage Insurance for Rental Housing for the Elderly 

(Section 231) Department of Housing and Urban Development 

87 

Mortgage Insurance for Rental and Cooperative Housing 

(Section 221(d)(3)) Department of Housing and Urban Development 

88 

Mortgage Insurance for Rental and Cooperative Housing 

(Section 221(d)(4)) Department of Housing and Urban Development 

89 

Mortgage Insurance for Single Room Occupancy 

Projects (Section 221(d)) pursuant to Section 223(g) Department of Housing and Urban Development 

90 

Mortgage and Major Home Improvement Loan Insurance 

for Urban Renewal Areas (Section 220) Department of Housing and Urban Development 

91 Mortgage interest deduction Internal Revenue Service 

92 Mortgage subsidy bonds interest exclusion Internal Revenue Service 

93 Mortgage-Backed Securities Purchase Program Department of the Treasury 

94 Moving to Work (MTW) Department of Housing and Urban Development 

95 

Multi-family Housing Revitalization Demonstration 

Program Department of Agriculture 
 29 

Activity or Program Name Administering Agency or Entity

96 Multifamily Operating Loss Loans (Section 223(d)) Department of Housing and Urban Development 

97 Multifamily Property Disposition Department of Housing and Urban Development 

98 

National Farmworker Jobs Program - Housing 

Assistance Department of Labor 

99 Native American Veterans Housing Loan Program Department of Veterans Affairs 

100 Native Hawaiian Housing Block Grant Program (NHHBG) Department of Housing and Urban Development 

101 

Neighborhood Reinvestment Corporation, also known as 

NeighborWorks America Neighborhood Reinvestment Corporation 

102 Neighborhood Stabilization Program Department of Housing and Urban Development 

103 

One-to-Four-Family Home Mortgage Insurance (Section 

203(b)) Department of Housing and Urban Development 

104 Passive rental losses Internal Revenue Service 

105 Project-Based Rental Assistance (Section 8 Contracts) Department of Housing and Urban Development 

106 Project-Based Voucher Program Department of Housing and Urban Development 

107 Property Improvement Loan Insurance (Title I) Department of Housing and Urban Development 

108 Property tax deduction Internal Revenue Service 

109 Provide advances to member institutions Federal Home Loan Banks 

110 Public Housing Capital Fund Department of Housing and Urban Development 

111 Public Housing Homeownership (Section 32) Department of Housing and Urban Development 

112 Public Housing Operating Fund Department of Housing and Urban Development 

113 

Purchase agricultural or rural housing mortgage loans 

and securitize loans into guaranteed securities or 

agricultural mortgage-backed securities Federal Agricultural Mortgage Corporation (Farmer Mac) 

114 

Purchase of Fannie Mae, Freddie Mac and Federal Home 

Loan Bank Debt Federal Reserve System 
 30 

Activity or Program Name Administering Agency or Entity

115 Real Estate Settlement Procedures Act of 1974 (RESPA) 

Consumer Financial Protection Bureau (CFPB) and Federal 

Financial Regulators (Federal Reserve Board, Federal 

Deposit Insurance Corporation, National Credit Union 

Administration, and Office of the Comptroller of the 

Currency) and the Federal Financial Institutions 

Examination Council (FFIEC) 

116 

Regulator and conservator of Fannie Mae and Freddie 

Mac (the enterprises) and the regulator of the Federal 

Home Loan Banks (FHL Banks) Federal Housing Finance Agency 

117 

Regulator and examiner of the banks, associations, and 

related entities of the Farm Credit System, including the 

Federal Agricultural Mortgage Corporation (Farmer 

Mac) Farm Credit Administration 

118 Rehabilitation Loan Insurance (Section 203(k)) Department of Housing and Urban Development 

119 Rent Supplement Program Department of Housing and Urban Development 

120 Rental Housing Assistance Payments (RAP) Department of Housing and Urban Development 

121 Rental housing bonds interest exclusion Internal Revenue Service 

122 

Revitalization of Severely Distressed Public Housing 

(HOPE VI) Department of Housing and Urban Development 

123 

Risk Sharing Program - Qualified Participating Entities 

(Section 542(b)) Department of Housing and Urban Development 

124 Rural Community Development Initiative Grants Department of Agriculture 

125 Section 236 Interest Reduction Payments Department of Housing and Urban Development 

126 Section 502 Mutual Self-Help Housing Loan Program Department of Agriculture 

127 Section 502 Rural Housing Single Family Loans - Direct Department of Agriculture 

128 

Section 502 Rural Housing Single Family Loans - 

Guaranteed Department of Agriculture 

129 

Section 504 Direct Housing Loans and Grants for Natural 

Disasters Department of Agriculture 

130 Section 504 Very Low-income Repair Loans and Grants Department of Agriculture 

131 Section 509(f) Housing Application Packaging Grants Department of Agriculture 

132 

Section 514 and 516 Farm Labor Housing Loan and Grant 

Program Department of Agriculture 
 31 

Activity or Program Name Administering Agency or Entity

133 

Section 515 Multifamily Direct Rural Rental Housing 

Loans Department of Agriculture 

134 Section 521 Rural Rental Assistance Payments Department of Agriculture 

135 

Section 523 Mutual and Self-Help Housing Technical 

Assistance Grants Department of Agriculture 

136 Section 523 Self-Help Housing Department of Agriculture 

137 Section 524 Site Development Department of Agriculture 

138 

Section 525 Technical and Supervisory Assistance 

Grants Department of Agriculture 

139 Section 533 Rural Housing Preservation Grants Department of Agriculture 

140 Section 538 Rural Rental Housing Guaranteed Loans Department of Agriculture 

141 Section 542 Rural Development (RD) Voucher Program Department of Agriculture 

142 Section 8 Moderate Rehabilitation Program Department of Housing and Urban Development 

143 

Secure and Fair Enforcement for Mortgage Licensing Act 

of 2008 (SAFE Act) 

Consumer Financial Protection Bureau (CFPB) and Federal 

Financial Regulators (Federal Reserve Board, Federal 

Deposit Insurance Corporation, National Credit Union 

Administration, and Office of the Comptroller of the 

Currency) and the Federal Financial Institutions 

Examination Council (FFIEC) 

144 Self-Help Homeownership Opportunity Program (SHOP) Department of Housing and Urban Development 

145 Self-Help Housing Property Disposition Department of Housing and Urban Development 

146 Senior Preferred Stock Purchase Agreements Department of the Treasury 

147 

Single Family Cooperative Housing Mortgage Insurance 

(Section 203(n)) Department of Housing and Urban Development 

148 

Single Family Property Disposition Program (Section 

204(g)) Department of Housing and Urban Development 

149 Special Housing Adaptation (SHA) for Disabled Veterans Department of Veterans Affairs 

150 Specially Adapted Housing (SAH) for Disabled Veterans Department of Veterans Affairs 

151 

Supplemental Loans for Multifamily Projects (Section 

241) Department of Housing and Urban Development 
 32 

Activity or Program Name Administering Agency or Entity

152 

Supportive Housing for Persons with Disabilities 

(Section 811) Department of Housing and Urban Development 

153 Supportive Housing for the Elderly (Section 202) Department of Housing and Urban Development 

154 Sustainable Communities Initiative Department of Housing and Urban Development 

155 Tax Credit Assistance Program (TCAP) Department of Housing and Urban Development 

156 Temporary Residence Adaptation (TRA) Department of Veterans Affairs 

157 Truth in Lending Act (TILA) 

Consumer Financial Protection Bureau (CFPB) and Federal 

Financial Regulators (Federal Reserve Board, Federal 

Deposit Insurance Corporation, National Credit Union 

Administration, and Office of the Comptroller of the 

Currency) and the Federal Financial Institutions 

Examination Council (FFIEC) 

158 Veterans Administration Home Loan Guaranty Department of Veterans Affairs 

159 Veterans Housing Manufactured Home Loans Department of Veterans Affairs 

160 Veterans housing bonds interest exclusion Internal Revenue Service 

Source: U.S. Gov’t Accountability Office, Housing Assistance: An Inventory of Fiscal Year 2010 Programs, Tax Expenditures, and Other Activities 

(GAO-12-555SP, August 16, 2012), an E-supplement to GAO-12-554, Table of Contents, https://www.gao.gov/special.pubs/gao-12-

555sp/housing_programs.csv (last visited Oct. 1, 2020).
 33 

1

 The U.S. Department of Housing and Urban Development, Housing in the Seventies: A Report of the National 

Housing Policy Review, 22 (Nov. 1974) [hereinafter, “1974 HUD Report”]. 

2

 Office of Mgmt. & Budget, Historical Tables, Fiscal Year 2021, Table 5.6—Budget Authority for Discretionary 

Programs: 1976–2025, https://www.whitehouse.gov/omb/historical-tables/ (last visited Oct. 8, 2020); Office of 

Mgmt. & Budget, Analytical Perspectives, Fiscal Year 2021, 260, Table 18–2, Estimated Future Cost of Outstanding 

Federal Credit Programs, https://www.whitehouse.gov/wp-content/uploads/2020/02/ap_18_credit_fy21.pdf (last 

visited Oct. 8, 2020). 

3

 U.S. Gov’t Accountability Office, GAO-12-554, Housing Assistance: Opportunities Exist to Increase Collaboration 

and Consider Consolidation, 6-7 (Aug. 16, 2012) [hereinafter, “2012 GAO Report”]. 

4 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) (written submission of Daniel Garcia-Diaz, U.S. Gov’t Accountability Office, “Summary of GAO Work 

on Housing Program Consolidation Issues”), 1 and 6, 

https://www.budget.senate.gov/imo/media/doc/SBC%20Housing%20Roundtable%20Submission%20(unlocked).pd

f. For GAO’s list of these 160 programs, please see the Appendix to this report. 

5 See 2012 GAO Report, 3-4; S. Comm. on the Budget, S. Prt. 114-31, Tax Expenditures: Compendium of Background 

Material on Individual Provisions, 356 (Dec. 2016), https://www.govinfo.gov/content/pkg/CPRT114SPRT24030/pdf/CPRT-114SPRT24030.pdf. 

6

 Maggie McCarty, Libby Perl, and Katie Jones, Cong. Research Serv., RL34591, Overview of Federal Housing 

Assistance Programs and Policy, 1-2 (Mar. 27, 2019) [hereinafter, “CRS Report RL34591”]. See also GAO 2012 report, 

3-4. 

7

 CRS Report RL34591, 2. 

8

Id. 

9

Id. at 3. 

10 Id. at 3-4. 

11 Id. at 4. See also Office of Inspector General, U.S. Department of Housing and Urban Development, 2019-OE-0004, 

Overview of HUD’s Housing Assistance Programs, 1 (Mar. 31, 2020) (“Throughout the 1960s, Congress approved 

legislation that encouraged the private sector to develop affordable housing through subsidy programs”). 

12 U.S. Department of Housing and Urban Development, Key HUD Statutes, 

https://www.hud.gov/hudprograms/keystatutes (last visited Oct. 1, 2020); CRS Report RL34591, 4. 

13 U.S. Department of Housing and Urban Development, Key HUD Statutes, 

https://www.hud.gov/hudprograms/keystatutes (last visited Oct. 1, 2020). 

14 Id. 

15 CRS Report RL34591, 6 and 17. 

16 U.S. Department of Housing and Urban Development, Review of Stewart B. McKinney Homeless Assistance 

Programs Administered by HUD (Jan. 1, 1995), 

https://www.huduser.gov/portal/publications/homeless/mckinney.html last visited Oct. 1, 2020). 

17 CRS Report RL34591, 7. 

18 Id. at 19. 

19 CRS Report RL34591, Summary and 9. 

20 Id. at 9. 

21 Id.

22 Edgar O. Olsen, Reforming Housing Assistance, Cato Institute, Regulation, 26 (Summer 2015), 

https://www.cato.org/sites/cato.org/files/serials/files/regulation/2015/6/regulation-v38n2-4.pdf. 

23 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) (written statement of Ed Olsen, “The Cost of Complexity in Low-Income Housing Assistance”) 1, 

https://www.budget.senate.gov/imo/media/doc/Olsen%20testimony.pdf. 

24 See CRS Report RL34591, Summary; 2012 GAO Report, 2 and Figure 1. 

25 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) https://www.budget.senate.gov/senate-budget-committee-roundtable-to-examine-federalhousing-assistance-programs- (last visited Oct. 8, 2020). 

26 See id. 

27 2012 GAO Report, 12-13. 
 34 

28 Id. at 59.

29 Office of Mgmt. & Budget, Delivering Government Solutions in the 21st Century: Reform Plan and Reorganization 

Recommendations, 35-36 (June 21, 2018). 

30 See id.; U.S. Gov’t Accountability Office, GAO-16-801, Home Mortgage Guarantees: Issues to Consider in Evaluating 

Opportunities to Consolidate Two Overlapping Single-Family Programs, 15 (Sept. 29, 2016) [hereinafter “2016 GAO 

Report”]. 

31 2012 GAO Report, 17. 

32 Id. 

33 2016 GAO Report, Figure 10 and 30-32. 

34 Id. at 11. 

35 2012 GAO Report, 20. 

36 Id. at 21. 

37 2016 GAO Report, 15. 

38 Id. 

39 Office of Mgmt. & Budget, Delivering Government Solutions in the 21st Century: Reform Plan and Reorganization 

Recommendations, 35-36 (June 21, 2018). 

40 Calculated using publicly available Home Mortgage Disclosure Act data (spreadsheet on file with Comm. staff). 

41 2012 GAO Report, 40. 

42 Id. at 61. 

43 Id. at 46. 

44 Office of Mgmt. & Budget, Delivering Government Solutions in the 21st Century: Reform Plan and Reorganization 

Recommendations, 35-36 (June 21, 2018). 

45 Id.

46 2012 GAO Report, 64. The Agriculture Improvement Act of 2018 (P.L. 115-334), enacted about six months after OMB 

released its 2018 plan, granted USDA access to the U.S. Department of Health and Human Services’ New Hires 

database for purposes of verifying the incomes of individuals participating in RHS's housing programs. But the 

extent to which USDA has used this authority is unclear. 

47 U.S. Department of Housing and Urban Development, Fiscal Year 2021 Congressional Justifications, Overview of 

Rental Assistance Programs, 1, 

https://www.hud.gov/sites/dfiles/CFO/documents/5_FY21CJ_OverviewofRentalAssistancePrograms.pdf. Rental 

Assistance, as defined by HUD, includes Moving to Work, Tenant-Based Rental Assistance, the Public Housing Fund, 

Project-Based Rental Assistance, Housing for the Elderly, Housing for Persons with Disabilities, and Other Assisted 

Housing. 

48 U.S. Department of Housing and Urban Development, HUD’s Public Housing Program, 

https://www.hud.gov/topics/rental_assistance/phprog (last visited Oct. 1, 2020). 

49 Id. 

50 Maggie McCarty, Cong. Research Serv., R41654, Introduction to Public Housing, Summary (Feb. 13. 2014). 

51 U.S. Department of Housing and Urban Development, Housing Choice Vouchers Fact Sheet, 

https://www.hud.gov/program_offices/public_indian_housing/programs/hcv/about/fact_sheet (last visited Oct. 1, 

2020). 

52 Maggie McCarty, Cong. Research Serv., RL32284, An Overview of the Section 8 Housing Programs: Housing 

Choice Vouchers and Project-Based Rental Assistance, Summary (Feb. 7. 2014). 

53 Libby Perl and Maggie McCarty, Cong. Research Serv., R42734, Income Eligibility and Rent in HUD Rental 

Assistance Programs: Frequently Asked Questions, 2 (Mar. 28, 2017). 

54 U.S. Department of Housing and Urban Development, Assisted Housing: National and Local, 

https://www.huduser.gov/portal/datasets/assthsg.html (last visited June 2, 2020). 

55 U.S. Department of Housing and Urban Development, Characteristics of HUD-Assisted Renters and Their Units in 

2017, ES-3, ES-5, 15-16, 27-29 (March 2020), https://www.huduser.gov/portal/sites/default/files/pdf/HUDAssisted-Renters-2017.pdf. 

56 U.S. Department of Housing and Urban Development, Programs of HUD, 57, 59 (2020), 

hud.gov/sites/dfiles/Main/documents/HUDPrograms2020.pdf. 
 35 

57 U.S. Department of Housing and Urban Development, Characteristics of HUD-Assisted Renters and Their Units in 

2017, 11-12, 14 (March 2020), https://www.huduser.gov/portal/sites/default/files/pdf/HUD-Assisted-Renters2017.pdf. 

58 Id. at 14. 

59 Robert Collinson, Ingrid Gould Ellen, Jens Ludwig, Low-Income Housing Policy, Working Paper 21071, 7 (Apr. 2015), 

https://www.nber.org/papers/w21071.pdf. 

60 Alexander von Hoffman, History Lessons for Today’s Housing Policy: The Political Processes of Making LowIncome Housing Policy, 42, Joint Center for Housing Studies, Harvard University (Aug. 2012), 

https://www.jchs.harvard.edu/sites/default/files/w12-5_von_hoffman.pdf. 

61 See Charles J. Orlebeke, The Evolution of Low-Income Housing Policy, 1949 to 1999, Housing Policy Debate (Vol. 11, 

Iss. 2), 492 (2000), http://www.michaelcarliner.com/files/Orlebeke-HPD-2000-Evolution-of-LI-HousingPolicy.pdf. 

62 John M. Quigley, A Decent Home: Housing Policy in Perspective, Brookings-Wharton Papers on Urban Affairs: 

2000, 74-75 (2000), https://urbanpolicy.berkeley.edu/pdf/Q_BW00PB.pdf. See also 1974 HUD Report, 6 (“Public 

housing originated in 1937 as an effort to clear slums as much as to increase employment and assist the poor”). 

63 See Robert Collinson, Ingrid Gould Ellen, Jens Ludwig, Low-Income Housing Policy, Working Paper 21071, 23 (Apr. 

2015), https://www.nber.org/papers/w21071.pdf. 

64 1974 HUD report, at 23. 

65 Alexander von Hoffman, History Lessons for Today’s Housing Policy: The Political Processes of Making LowIncome Housing Policy, 47-50, Joint Center for Housing Studies, Harvard University (Aug. 2012), 

https://www.jchs.harvard.edu/sites/default/files/w12-5_von_hoffman.pdf. 

66 See generally Stephen Malpezzi, Low-income Housing Programs That Work: Part I, Blog Re (Jan. 14, 2018), 

https://rutgersrealestate.com/blog-re/affordable-housing-are-vouchers-the-answer/ (last visited Oct. 1, 2020); 

Reducing Poverty by Reforming Housing Policy, Edgar O. Olsen, A Safety Net That Works: Improving Federal 

Programs for Low-Income Americans (2017), https://www.aei.org/wp-content/uploads/2017/02/A-Safety-NetThat-Works.pdf.; John C. Weicher, Housing Policy at a Crossroads: The Why, Who, and How of Assistance Programs 

(Dec. 16, 2012); John M. Quigley, A Decent Home: Housing Policy in Perspective (2000), 

https://urbanpolicy.berkeley.edu/pdf/Q_BW00PB.pdf. 

67 U.S. Department of Housing and Urban Development, Fiscal Year 2020 Congressional Justification, 1-10 and 1-11 

(fiscal year 2019 outlays), 

https://www.hud.gov/sites/dfiles/CFO/documents/2020HUDCongressionalJustifications4-2-19.pdf. 

68 See generally Louis Winnick, The Triumph of Housing Allowance Programs: How a Fundamental Policy Conflict 

Was Resolved, Cityscape: A Journal of Policy Development and Research (Vol. 1, No. 3) (Sept. 1995), 

https://www.huduser.gov/periodicals/cityscpe/vol1num3/winnick.pdf; John C. Weicher, Privatizing Subsidized 

Housing, 43 (1997), https://www.aei.org/wp-content/uploads/2017/02/Privatizing-Subsidized-Housing-text.pdf; 

Edgar Olsen, Getting More from Low-Income Housing Assistance, Discussion Paper No. 2008-13, Sept. 2008, 21, 

https://www.brookings.edu/wp-content/uploads/2016/06/0923_housing_olsen.pdf. 

69 Robert Collinson, Ingrid Gould Ellen, Jens Ludwig, Low-Income Housing Policy, Working Paper 21071, 1 (Apr. 2015), 

https://www.nber.org/papers/w21071.pdf. 

70 Henry G. Cisneros, Legacy for a Reinvented HUD: Charting a New Course in Changing and Demanding Times, 

Cityscape: A Journal of Policy Development and Research (Vol. 1, No. 3) 145, 148 (Sept. 1995), 

https://www.huduser.gov/Periodicals/CITYSCPE/VOL1NUM3/cisneros.pdf. 

71 Katie Jones, Cong. Research Serv., R40781, The Housing Trust Fund: Background and Issues, Summary (May 24, 

2016). 

72 Id. at Summary, 6, 10. 

73 Id. at 1. 

74 Federal Housing Finance Agency, FHFA Authorizes Payments to Housing Trust Fund and Capital Magnet Fund, 

News Release (Feb. 27, 2020), https://www.fhfa.gov/Media/PublicAffairs/Pages/FHFA-Authorizes-Payments-toHousing-Trust-Fund-and-Capital-Magnet-Fund_2272020.aspx. 

75 Sarah Saadian, National Housing Trust Fund: Funding, 2020 Advocates’ Guide: An Educational Primer on Federal 

Programs and Resources Related to Affordable Housing and Community Development, National Low Income 

Housing Coalition, 3-12 (2020). 
 36 

76 Katie Jones, Cong. Research Serv., R40118, An Overview of the HOME Investment Partnerships Program, 

Summary (Sept. 11, 2014). 

77 Id.

78 U.S. Department of Housing and Urban Development, Programs of HUD, 23 (2020), 

hud.gov/sites/dfiles/Main/documents/HUDPrograms2020.pdf. 

79 Katie Jones, Cong. Research Serv., R40118, An Overview of the HOME Investment Partnerships Program, 3-4 

(Sept. 11, 2014). 

80 Id. at Summary. 

81 Alyse N. Minter and Maggie McCarty, Cong. Research Serv., R46247, Department of Housing and Urban 

Development (HUD): FY2021 Budget Request Fact Sheet (Feb. 11, 2020). 

82 Office of Mgmt. & Budget, Major Savings and Reforms, Fiscal Year 2021, 50 (2020), 

https://www.whitehouse.gov/wp-content/uploads/2020/02/msar_fy21.pdf. 

83 U.S. Department of Housing and Urban Development, The HOME Program: HOME Investment Partnerships, 

https://www.hud.gov/hudprograms/home-program (last visited Oct. 1, 2020); U.S. Department of Housing and 

Urban Development, Housing Trust Fund, https://www.hud.gov/hudprograms/housing-trust (last visited Oct. 1, 

2020). 

84 Katie Jones, Cong. Research Serv., R40781, The Housing Trust Fund: Background and Issues, 13 (May 24, 2016). 

85 U.S. Department of Housing and Urban Development, Housing Trust Fund, 75 Fed. Reg. 66978, 66979 and 66986 

(Oct. 29, 2010), https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-27069.pdf. 

86 Tax Policy Center, T18-0170 - Tax Benefit of the Itemized Deduction for Home Mortgage Interest, Baseline: Current 

Law, Distribution of Federal Tax Change by Expanded Cash Income Level, 2018, 

https://www.taxpolicycenter.org/model-estimates/individual-income-tax-expenditures-october-2018/t18-0170-

tax-benefit-itemized (last visited Oct. 1, 2020). 

87 Mark P. Keightley, Cong. Research Service, RS22389, An Introduction to the Low-Income Housing Tax Credit, 1 

(Jan. 15, 2020). 

88 Tax Policy Center, What is the Low-Income Housing Tax Credit and How Does It Work?, Tax Policy Center Briefing 

Book, https://www.taxpolicycenter.org/briefing-book/what-low-income-housing-tax-credit-and-how-does-itwork (last visited Oct. 1, 2020); Mark P. Keightley, Cong. Research Service, RS22389, An Introduction to the LowIncome Housing Tax Credit, 3-6 (Jan. 15, 2020). 

89 U.S. Department of Housing and Urban Development, Office of Policy Development and Research, Understanding 

Whom the LIHTC Serves: Data on Tenants in LIHTC Units as of December 31, 2015, 18, 

https://www.huduser.gov/portal/sites/default/files/pdf/LIHTC-TenantReport-2015.pdf. 

90 2012 GAO Report, 9. 

91 Mark P. Keightley, Cong. Research Serv., R41596, The Mortgage Interest and Property Tax Deductions: Analysis and 

Options, 6 (Mar. 18, 2014). 

92 Tax Policy Center, T18-0166 - Tax Benefit of the Itemized Deduction for Property Taxes, Baseline: Current Law, 

Distribution of Federal Tax Change by Expanded Cash Income Level, 2018, https://www.taxpolicycenter.org/modelestimates/individual-income-tax-expenditures-october-2018/t18-0166-tax-benefit-itemized (last visited Oct. 1, 

2020). 

93 S. Comm. on the Budget, S. Prt. 114-31, Tax Expenditures: Compendium of Background Material on Individual 

Provisions, 427-429 (Dec. 2016), https://www.govinfo.gov/content/pkg/CPRT-114SPRT24030/pdf/CPRT114SPRT24030.pdf. 

94 See also David A. Weisbach, Tax Expenditures, Principal-Agent Problems, and Redundancy, 84 Wash. U. L. Rev. 

1823, 1836, 1850 (2006), 

https://chicagounbound.uchicago.edu/cgi/viewcontent.cgi?article=3031&context=journal_articles. 

95 See generally id. 

96 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) (written statement of Ed Olsen, “The Cost of Complexity in Low-Income Housing Assistance”) 3, 

https://www.budget.senate.gov/imo/media/doc/Olsen%20testimony.pdf. 

97 Alicia Mazzara, Federal Rental Assistance Provides Affordable Homes for Vulnerable People in All Types of 

Communities, Center on Budget and Policy Priorities, 5-6 (Nov. 9, 2017), 

https://www.cbpp.org/sites/default/files/atoms/files/11-9-17hous.pdf. 
 37 

98 Corianne Payton Scally, Amanda Gold, Carl Hedman, Matt Gerken, Nicole DuBois, The Low-Income Housing Tax 

Credit: Past Achievements, Future Challenges, Urban Institute, 6 (July 2018), 

https://www.urban.org/sites/default/files/publication/98761/lithc_past_achievements_future_challenges_final_0.

pdf. 

99 Written Reponses to Questions for the Record from Chairman Michael B. Enzi, Professor Edgar Olsen, Senate 

Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. (Sept. 24, 

2020) 2 (on file with the Comm.). 

100 U.S. Department of Housing and Urban Development, Mission, https://www.hud.gov/about/mission (last visited 

Oct. 1, 2020). 

101 See U.S. Department of Housing and Urban Development, The 2019 Annual Homeless Assessment Report (AHAR) 

to Congress, Part 1: Point-In-Time Estimates of Homelessness, 1 (Jan. 2020), 

https://files.hudexchange.info/resources/documents/2019-AHAR-Part-1.pdf. 

102 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) (written statement of Ed Olsen, “The Cost of Complexity in Low-Income Housing Assistance”) 1, 

https://www.budget.senate.gov/imo/media/doc/Olsen%20testimony.pdf. 

103 Alicia Mazzara, Federal Rental Assistance Provides Affordable Homes for Vulnerable People in All Types of 

Communities, Center on Budget and Policy Priorities, 1 (Nov. 9, 2017), 

https://www.cbpp.org/sites/default/files/atoms/files/11-9-17hous.pdf. 

104 Id. at 5-6. 

105 Senate Budget Committee Housing Roundtable: Examining Federal Housing Assistance Programs, 116th Cong. 

(Sept. 16, 2020) (written statement of Ed Olsen, “The Cost of Complexity in Low-Income Housing Assistance”) 7, 

https://www.budget.senate.gov/imo/media/doc/Olsen%20testimony.pdf. See also James E. Wallace, Susan 

Philipson Bloom, William L. Holshouser, Shirley Mansfield, and Daniel H. Weinberg. Participation and Benefits in the 

Urban Section 8 Program: New Construction and Existing Housing, Vols. 1 & 2 (1981), Abt Associates Inc., 

https://virginia.app.box.com/s/7w5zmypmh44ljg5z6jbja0qaod4pswax (last visited Oct. 8, 2020); Stephen K. Mayo, 

Shirley Mansfield, David Warner, and Richard Zwetchkenbaum, Housing Allowances and Other Rental Assistance 

Programs-A Comparison Based on the Housing Allowance Demand Experiment, Part 2: Costs and Efficiency (1980), 

Abt Associates Inc., https://virginia.app.box.com/s/y9l5b19wnfxay0v167tr3xuzrpdwz77d (last visited Oct. 8, 2020). 

106 The Editorial Board, New York’s Public Housing Misery, The Wall Street Journal (July 26, 2019) 

https://www.wsj.com/articles/new-yorks-public-housing-misery-11564182422. 

107 Office of Inspector General, U.S. Department of Housing and Urban Development, 2019-OE-0004, Overview of 

HUD’s Housing Assistance Programs, 4 (Mar. 31, 2020). HUD has another 21 housing assistance programs that are 

“inactive,” meaning they “have not received appropriations for new commitments or grants in 5 years or received 

appropriations only for the renewal of existing grants or commitments.” Id. at Executive Summary. 

108 Id. at Executive Summary. 

109 Nolan Hicks, Nearly 90 Percent of NYCHA Apartments Lost Heat, Hot Water During Winter, New York Post (Aug. 11, 

2019), https://nypost.com/2019/08/11/nearly-90-percent-of-nycha-apartments-lost-heat-hot-water-duringwinter/. .

110 Bart M. Schwartz, Monitor’s Third Quarterly Report for the New York City Housing Authority, October-December 

2019, 29 (Feb. 4, 2020), https://nychamonitor.com/wp-content/uploads/2020/02/NYCHA-Monitor-Third-QuarterlyReport-2.4.20.pdf. 

111 See New York City Housing Authority (NYCHA), Fiscal 2021 Preliminary Budget Fact Sheet, 

https://council.nyc.gov/budget/wp-content/uploads/sites/54/2020/04/NYCHA-Fact-Sheet.pdf (last visited Oct. 1, 

2020). 

112 Philip Garboden, Eva Rosen, Meredith Greif, Stefanie DeLuca, Kathryn Edin, Urban Landlords and the Housing 

Choice Voucher Program: A Research Report, U.S. Department of Housing and Urban Development, iv-v (May 2018), 

https://www.huduser.gov/portal/sites/default/files/pdf/Urban-Landlords-HCV-Program.pdf.