Friday, August 24, 2012

HUD's big LIHTC report isn't all good news.

On Wednesday HUD posted the long-awaited Abt Associates report on "What Happens to Low Income Housing Tax Credit Properties at Year 15 and Beyond?"

The question in the title matters because, according to the report, properties subsidized with the Low-Income Housing Tax Credit (LIHTC) "accounted for roughly one-third of all multifamily rental housing constructed between 1987 and 2006." That's 2.2 million housing units, and all were required to charge formula-set "affordable" rents for 15 years.

The report doesn't answer the question as completely as we might hope. The new data is more of a grab bag than a grand unified statement. But it's still a pretty good report that adds new data to the many past estimates on this subject.

The data in there generally cheers the subsidized housing industry. HUD spokesman Brian Sullivan, reaching for certainty, tweeted, "New #HUD study finds #affordablehousing remains affordable 15 years > Low-Income Housing Tax Credits."

But this bit, from the opening summary, states the conclusions better: "Most older LIHTC properties are not at risk of becoming unaffordable, the notable exceptions being properties with for-profit owners in favorable market locations."

In those "favorable market locations" -- San Francisco, for example -- really there's not cause for cheering. More like a "meh."

The effort to measure money-pressure in expensive markets produces a paragraph and one-line chart on Page 18 of the report that seems to me as informative as anything in there: it says:
"The most likely properties to have been repositioned as unaffordable, market-rate housing are properties in low-poverty locations. We conducted a survey of the rents of a sample of a properties no longer reporting to an HFA and found that, even for this group of properties that should be at particularly high risk of becoming unaffordable, nearly one-half had rents less than the LIHTC maximum, and another 9 percent had rents only slightly more than LIHTC rents..."
The chart shows 42% of the units exceeding 105% of the formula rent on top of that 9% hovering right at the margin. Really that combined 51% is a lot.

Especially it's a lot because maximum LIHTC rents in expensive towns can be surprisingly high already, and in cheap towns (parts of Arizona, for example), it has been a problem for some time that LIHTC formula rents can actually exceed market rate.

The Novogradac tax credit gurus' Rent and Income Limit Calculator reports that, for a typical ordinary older San Francisco tax credit property (not necessarily every one), the maximum LIHTC rent, for tenants at 60% of median income, would be $1,297 for an efficiency or $1,389 for a one-bedroom, or $1,668 for a two-bedroom. That's compared with HUD-calculated "Fair Market Rents" (problematic estimates of market rate) of respectively $1,238, $1,522 and $1,905. Subsidies at that shallow level are some help in San Francisco, where people in the real-life market pay $2000 for a small unit now without sneezing -- but by themselves the LIHTC limits are really not a huge lot of help.

This is easy to forget because LIHTC financing can be used as a first underlayer of support for heavily subsidized units serving tenants who live on very low fixed incomes. For example, the subsidized property that I know best, a Shelter Plus Care building in my San Francisco neighborhood, combines LIHTC with a heap of other subsidies to provide efficiency apartments for tenants living on Social Security disability or worse, so I would guess that most neighbors there are paying under $400 per month.

But, really, saying that a lot of properties stay within the LIHTC program's formula rents, or that they're effectively required to stay there in many states, isn't really the same as saying lower-income tenants can afford to live there.

The Novogadac take on the report further pulls out the warning that (in their words) "in the worst-case scenario more than a million LIHTC units could leave the affordable housing stock by 2020," but they note the report says it's unlikely to really happen.

We still don't precisely know how many properties stuck to their "affordable" rents past their Year 15 cutoff dates. Nor how many of those formula-set rents  are what normal people would call affordable outside of quotation marks. Nor exactly what proportion of the genuinely low rents are likely to stay that way.

More knowledge than before though. And some of the details are encouraging. Just, not all.

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