1. Update on VAWA Implementation in LIHTC
Rachel Blake
Associate Director
Regional Housing Legal Services

2. RHLS
Regional Housing Legal Services is a nonprofit law firm whose mission is to create housing and
economic opportunity in under-served communities in Pennsylvania and to effect systemic change for the benefit of  lower-income households statewide.

3. Survey Goals/Method Goal: Method:
gather information about HFA VAWA 2013 implementation efforts
accelerate implementation efforts
Method:
Survey with 10 questions (self-reported, no independent verification)
Distributed to all 50 states; 23 responded
Spring of 2016 staff from American Civil Liberties Union, Mid-Minnesota Legal Aid, National Alliance to End Sexual Violence, National Network to End Domestic Violence, National Housing Law Project, Regional Housing Legal Services, and Sargent Shriver National Center on Poverty Law launched a survey designed to educate HFAs about VAWA 2013 and to gather information about implementation efforts. 23 responses.

4. 2016 Survey
Education & Training
19 have or plan to educate owners, developers and management agents about VAWA
17 have or plan to educate tenants about VAWA, including 7 that reported having a lease addendum
13 have or plan to offer trainings for owners, developers and management agents about VAWA implementation

5. Monitoring & Compliance
2016 Survey
Monitoring & Compliance
13 reserve the right to bar owners from applying for LIHTC for unresolved non-compliance with VAWA
11 revised compliance monitoring procedures
8 include VAWA in tenant selection plan review
3 report changing their QAPs to encourage VAWA compliance

6. 2016 Survey

7. 2017 Research
2017 Research
Searched all state + DC 2017 QAPs (final version, if available, otherwise draft version) available through novoco.com (on 9/14/17)
Missing: Alaska, Arkansas, California, Maryland, New York, Oklahoma
Searched all state + DC Compliance Manuals available through novoco.com (on 9/14/17)
Missing: New Hampshire, New Mexico, New York, North Carolina, Ohio, Tennessee, Texas, Kentucky, Louisiana, Maine, Virginia, Washington (state), West Virginia

8. 2017 QAPs At least 12 2017 QAPs mention VAWA-related requirements
2017 Research
2017 QAPs
At least QAPs mention VAWA-related requirements
6 require some sort of tenant notice (in the lease, a lease addendum, or notice of rights)
4 states included a basic non-discrimination statement
4 states specifically say that being a victim of domestic violence is not Good Cause for eviction
2 discuss transfer procedures

9. 2017 Research
Compliance Manuals
At least 13 LIHTC Compliance Manuals mention VAWA-related requirements
7 states included a basic non-discrimination statement
6 require some sort of tenant notice (in the lease, a lease addendum, or notice of rights)
5 states specifically say that being a victim of domestic violence is not Good Cause for eviction
3 discuss transfer procedures

10. Lease Language/Addenda
2017 Research
Lease Language/Addenda
At least 13 states (through the QAP or Compliance Manual) suggest or require language in the lease or a lease addendum that addresses VAWA requirements
8 suggest or require the HUD form
5 use or allow custom language or forms

11. 2017 Research – 22 States

12. 2017 Research
Combined Results
Combining survey results with our subsequent research shows:
at least 33 states are taking some steps to implement VAWA 2013 in LIHTC!

13. 2016 Survey & 2017 Research - 33 States

14. Rachel Blake, Esq. rblake@rhls.org
Contact us:
With any questions
To share a QAP or compliance manual we don’t have
To let us know we missed something
To obtain extracts showing the search results (can provide the page from each QAP or compliance manual with the relevant language for comparison purposes)
Rachel Blake, Esq.
(215) x113