In 2016, a coalition comprised of the National Network to End Domestic Violence, the National Alliance to End Sexual Violence, the National Housing Law Project, the American Civil Liberties Union, the Sargent Shriver National Center on Poverty Law, Mid-Minnesota Legal Aid, and Regional Housing Legal Services created and distributed a survey (“Survey”) to better understand how states were implementing VAWA in LIHTC properties. The Survey was designed to assess the way in which state housing finance agencies (“HFAs”), the state agencies responsible for each state’s LIHTC activities, were implementing VAWA.
The Survey uncovered significant variance among HFAs in VAWA implementation. Some HFAs, such as those in Pennsylvania and Illinois, have taken steps to educate housing providers and tenants about the rights of victims and to monitor provider compliance. However, many have failed to act, citing the need for guidance from the Department of Treasury (“Treasury”), which has been silent on the issue. In addition, we have no information about the practices of a significant number of HFAs that did not respond to the Survey.
This Report is designed to provide the reader with:
- an understanding of the provisions of VAWA that apply to LIHTC properties;
- a rationale for HFAs taking action to implement VAWA—even in the absence of Treasury regulations or guidance;
- recommendations for HFAs to implement VAWA in LIHTC, based on what some HFAs have already done; and
- a summary of the Survey findings.