Agenda - Council - 09/13/2022 - Laserfiche WebLink

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increase in the sale price of homes.153 Meanwhile, many low-income renters and homeowners are struggling with lost employment and income and are behind on their housing payments.154 Public Comment: Affordable Housing Outside of Low -Income Geographies: A major theme in comments was that affordable housing interventions, especially development of affordable housing, should be allowed outside of QCTs, as concentrating the supply of affordable housing in low-income geographies can have the effect of increasing both concentrated poverty and racial and economic segregation, while locking lower -income households in need of housing support out of high -opportunity neighborhoods with access to employment and amenities. Treasury Response: Affordable Housing Outside Low -Income Geographies: As previously stated, affordable housing is not confined to low-income geographies under the interim final rule. As discussed elsewhere, the interim final rule presumed that QCTs, as well as communities served by Tribal governments, were disproportionately impacted for administrative convenience, but recipients may identify other populations, households, or geographic areas with disparate impacts of COVID-19 and provide affordable housing services to them. For example, under the interim final rule, a city could determine that its low-income residents faced disproportionate impacts of COVID-19 and develop affordable housing targeted to these households. Such a scenario could include, for example, affordable projects in higher -income neighborhoods that would allow residents to live closer to jobs and well-resourced schools. 153 Joint Center For Housing Studies Of Harvard University, The State of the Nation's Housing (June 2021), https://www.j chs.harvard.edu/sites/default/files/reports/files/Harvard_JCHS_State_Nations_Housing_2021.pdf. 154 Davin Reed and Eileen Divringi, Household Rental Debt During COVID-19: Update for 2021, Federal Reserve Bank of Philadelphia (2020), available at: https://www.philadelphiafed.org/community-development/housing-and- neighborhoods/household-rental-debt-during-covid-19-update-for-2021. Further, some research suggests that liquidity may be a more important predictor of default than other factors, including income or equity. See Trading Equity for Liquidity (June 2019), available at https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase- and-co/institute/pdf/institute-trading-equity-for-liquidity.pdf. 104