I am supportive of the guidance as drafted, it is important that those who have rental assistance or housing choice vouchers be able to take that assistance wherever they wish to use it.  To limit where rental assistance or vouchers can be used undermines our public investment in housing assistance.

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.  

This guidance is important for a clear understanding of how source of income protections should work, and represent the legislative intent of the General Assembly.  You will do a great service to the housing community by adopting the as-drafted clear guidance.