I work in the “Move to Opportunity” program at Housing Opportunities Made Equal of Virginia.  It is a mobility counseling program, we work to help families who have Housing Choice Vouchers to move to a neighborhood of opportunity.  Since 2014 we have been able to reduce the poverty rate of the neighborhoods our families move from and to by an average of 15% (from neighborhoods averaging 31% poverty rate to neighborhoods averaging 14% poverty rate).

The guidance proposed will help us in our work significantly.  The lack of voucher acceptance has been a huge barrier to our work.  Since the adoption of Source of Funds protections we have noticed that landlords use an unfair requirement of having 2-3 times the rent as earned income, rather than doing that calculation for the amount the renter would owe personally.  This interpretation by landlords needs to be corrected.

Some legal sources of funds, such as the Housing Choice Voucher program, are administered by third-party entities who directly pay a portion of the tenant’s rent to the housing provider. 

These third-party payments are guaranteed and present less risk to a housing provider than other sources of income, such as employment income, which are not guaranteed. Furthermore, because the these sources of income are guaranteed, the relevant factor for a housing provider’s risk assessment is the tenant’s portion of the rent, and not the total rent.  

HOME’s clients with HCVs are actively facing barriers to housing access, frustrating HOME’s mission and programs. Housing providers are enacting facially neutral policies resulting in the automatic disqualification of our Mobility clients. These facially neutral policies typically take the form of an income qualification, as noted in the various examples across the guidance document…. 

It is also vital to view this guidance within the context of Virginia’s current housing landscape: 

• Virginia’s cities have some of the highest eviction rates in the country 
• Public housing authorities are redeveloping their traditional public housing communities with plans to issue more HCVs in lieu of replacing subsidized housing units 
• 46.1% of Virginia renter households are rent-cost-burdened 
• Disparities in the Virginia’s housing market continue to widen along racial lines. 73% of the 41,933 voucher households  in Virginia are Black. Denials on the basis of HCV, whether facially neutral or not, may also violate provisions against race discrimination. 

Thank you for taking up this guidance, this is important clarification that will serve our clients well.  This will ensure ALL Virginians have greater access to the housing opportunities necessary for them to thrive in the Commonwealth.