I am writing in support 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 and in expanding housing opportunity.

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 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.  

I am currently taking a graduate course on Housing Policy. One of the reoccurring themes throughout my studies is that there are housing policies and rules which are accepted without any consideration over the origin of the policy or rule—and whether or not the rule should be updated or changed. The 30% rule that is blanketly used as an indicator to determine housing affordability has its origins in policies created during the Depression Era. Initially, the rule of thumb was 20-25% of one’s income should go towards housing. It would later be increased to 30% in the late 1960s after extensive lobbying by certain organizations. Arguably, this is an indicator that is outdated and out of touch with present-day circumstances. When such policies like this are created, usually the most vulnerable stakeholders—low to moderate income families and people of color—are excluded from the policymaking discussions and decisions that likely will have a disparate impact on their lives. Low-to-moderate income households have been adversely impacted by the 30% rule.

With that stated, it is clear that some changes need to occur to ensure that tenants and households receiving rental assistance and/or vouchers are not excluded from freely participating in the housing market because of the source of their income. This guidance is an important step towards 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 this guidance such as drafted.