Presented to Illinois NAHRO August 13, 2015 Jennifer Novak Chan, Secretary, Illinois NAHRO

 States, small CDBG grantees (<=$500k), and all PHAs (qualified and non-qualified) submissions are delayed until their appropriate Assessment Tools are approved by OMB, and announced by HUD as available.  Sustainable Communities grantees also not required to submit AFH in first stage.  PHAs, either alone or collaborating, submit their AFHs every 5 years.

 “Geographic Area” MAY be a jurisdiction, region, state, CBSA, or another applicable area, depending on the area served by the program participant.  Regionally collaborating participants need not be contiguous, may cross state boundaries, but should be in same CBSA (HUD will allow exceptions)

 “Determinants” are now “Contributing Factors”  Prioritize contributing factors; give highest priority to factors that limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights compliance.

 HUD will review participants’ assessments, prioritization, and goal setting.  Program participants have latitude to prioritize their goals and strategies.  Preservation activities such as RAD or Choice Neighborhoods may be part of such strategy.

 Remove barriers that prevent people from accessing housing in areas of opportunity;  Develop affordable housing in areas of opportunity;  Effect housing mobility programs*;  Effect concerted housing preservation and community revitalization efforts*

*Where any such actions are designed to achieve fair housing outcomes such as reducing disproportionate housing needs; transforming R/ECAPs by addressing effects of segregation coupled with poverty; increasing integration; and increasing access to opportunity such as high-performing schools, transportation and jobs.

 “In areas with a history of segregation, if a program participant has the ability to create opportunities outside of the segregated, low- income areas but declines to do so in favor of place-based strategies, there could be a legitimate claim that HUD and its program participants were acting to preclude a choice of neighborhoods to historically segregated groups”  Avoid displacement of existing residents in areas experiencing renewed economic growth, housing price appreciation, or disinvestment in existing low-income neighborhoods