Q & A | Nation HTF ELI Limits Don't Match Section 8 ELI. Why?

Question from a Blog Reader

"I was told that the national HTF uses the Extremely Low Income (ELI) limits in effect for other HUD programs. So I was surprised when I checked the ELI limit for my HTF units and they do not match the ELI that I have to use for my Section 8 properties income targeting rules. In fact, I noticed that the HTF limits are actually higher than my 50% very low limits! Am I seeing this correctly?"

Answer

Summary: The 30%/ELI limits are calculated differently for the HTF than other HUD programs. It is important for owner/agents of properties with the HTF and also other programs to carefully implement the correct ELI limits.

While the ELI calculation starts at 30% of AMI for an area, they are also adjusted by the local poverty rate for both Section 8 and the HTF. However, the adjustment for the poverty level differs for HTF and other HUD programs. To understand this difference, key provisions are summarized below.  

HUD Section 8 and other programs covered by the Housing Act of 1937 that use the Extremely Low-Income limits (EI) may be summarized as follows.

• Very low-income families are defined as families whose incomes do not exceed 50 percent of the median family income for the area.
• Extremely Low-Income Families are very low income families whose incomes do not exceed the greater of 30 percent of the median family income for the area or the federal poverty guidelines as published by the Department of Health and Human Services. The Extremely Low-Income Limits based on poverty guidelines are capped by the Very Low-Income Limit. 

[Summarized from the statutory basis for HUD's income limit policies in Attachment 2 of Section 3 of the U.S. Housing Act of 1937, as amended].

The National HTF program limits are designed for the benefit of extremely low-income families or families with incomes at or below the poverty line (whichever is greater).

[24 CFR § 93.250 (a)]

Note that the HTF rules do not cap it at the 50% very low limits but the Section 8 limits do. Depending on income and poverty levels in an area, the HTF limits may exceed the 30% AND the 50% limits.   

---

Want HTF training? Check out on the "Upcoming Live Virtual Schedule" HERE for great training on the National HTF and HOME. OHFA is sponsoring virtual sessions for both programs this year. The sessions, although sponsored by a specific state, cover the federal programs. 

---