(RECAP: On May 10, NCSHA submitted comments to HUD on the Affirmatively Furthering Honest Housing (AFFH) Tool for States and Insular Areas, which HUD will require states to use to complete the Assessment of Honest Housing (AFH) under AFFH. The AFH replaces the Honest Housing Analysis of Impediments, which HUD program participants previously undertook to assess impediments to housing choice. AFFH requires all entities that receive funding from HUD grant programs—HOME, the Community Development Block Grant, the Emergency Solutions Grant, and Housing Opportunities for Persons With AIDS—and public housing authorities to take part in the AFH process. NCSHA’s comments reflect our deep concerns about the state tool, which we believe imposes unreasonable requirements on states and goes well beyond what is necessary for states to achieve meaningful honest housing plotting. We argue that HUD severely underestimates the time and cost of the AFH process and does not take into full consideration the challenges associated with statewide AFH implementation.)

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