Washington Recap: November 2025
NAAHL, in partnership with the Center for Affordable Housing Lending, is pleased to provide this monthly recap of the top federal policy developments in affordable housing and community development. NAAHL Members receive breaking policy updates and additional policy resources directly; however, any partner can sign up for NAAHL alerts and the monthly Washington Recap here.
NAAHL CONVENES HOUSING AND COMMUNITY DEVELOPMENT LEADERS FOR CONFERENCE AND 35TH ANNIVERSARY CELEBRATION
On November 5, over 200 housing and community development practitioners, policymakers, and partners gathered in Washington, DC for NAAHL/CAHL’s 2025 Policy & Practice Conference, Unlocking Housing Supply, Unlocking Economic Opportunity. Former Acting Comptroller of the Currency Rodney E. Hood opened the day reflecting on the importance of investing in communities. The conference hosted four panels on topics related to CDFI and bank partnerships, the community development tax landscape, America’s housing finance system, and legislative updates from key Senate staffers working to advance bipartisan housing legislation.
Representative Kim, who recently co-led a bicameral letter with Senator Crapo and 105 Republicans expressing support for the CDFI Fund and its staff, spoke to attendees about how important strong partnerships are for supporting our communities’ housing and economic needs.
To close out the day, NAAHL President & CEO Sarah Brundage moderated a fireside chat on optimizing public private partnerships in an evolving sector.
If you missed it, you can watch the recorded portions of the conference.
With this conference, NAAHL also celebrated 35 years of advocacy and partnership.
FEDERAL GOVERNMENT REOPENED
After 43 days, the longest government shutdown in U.S. history, the federal government re-opened on November 12. The funding bill contained full year appropriations for three of the 12 appropriation bills: Agriculture, Military Construction-Veterans Affairs, and Legislative Branch. All other agencies and programs, including the Department of Housing and Urban Development (HUD) and the CDFI Fund, received funding based on Fiscal Year (FY) 2025 levels through January 30, 2026, giving Congress more time to negotiate funding for these agencies for the rest of FY 2026.
The bill also reinstated all federal employees who received termination notices as part of a Reduction in Force (RIF) during the shutdown, including the full staff of the CDFI Fund and hundreds of HUD employees. The bill instructed that the employees that received RIF notices during the shutdown should be returned to their employment status as of September 30, 2025. They are entitled to backpay for the full period of the shutdown and considered to have been employed during that full period. In addition, the legislation prohibits any additional RIFs of federal employees through January 30.
Congress has until January 30 to pass the remaining nine Appropriations bills. If they do not pass full year appropriations for the remaining bills or otherwise extending their funding beyond the January 30 date, the government will go into a partial shutdown, affecting any agency that has not received full FY 2026 funding. See more details below on the state of appropriations.
CONGRESS
FY 2026 Appropriations
Congress is now working to pass funding for agencies and programs that only received short-term funding in the November 12 bill before that funding expires on January 30. That includes HUD, which is funded through the Transportation, Housing and Urban Development, and Related Agencies (THUD) appropriations bill, and the CDFI Fund, which is funded through the Financial Services and General Government (FSGG) appropriations bill. One option is to pass another package of a few of the nine remaining appropriations – a “minibus” – to advance funding bills that have agreement, while Congress continues to work on the more contentious appropriations bills ahead of the January 30 deadline.
HUD Funding. The House and Senate Appropriations Committees have each passed their own THUD bills, and Congressional leaders have indicated that this bill could advance in the next package of funding bills. Both the House and Senate THUD bills provided funding that exceeded the President’s FY 2026 request for HUD, and Senate funding levels were higher than the House funding levels for several key programs, including the HOME Investment Partnerships Program and PRO Housing grants, neither of which were funded in the House bill. An appropriations bill could also address concerns about a recent HUD grant announcement that would redirect funds through Continuum of Care grants from permanent supportive housing towards transitional housing. See “Continuum of Care (CoC) Funding” below for more details.
CDFI Funding. On November 24, Senate Republicans released FSGG appropriations text, which included $324 million in funding for the CDFI Fund, the same as the FY 2025 funding level. In September, the House Appropriations Committee advanced its FSGG funding bill, which provided $276.6 million for the CDFI Fund. Senate and House appropriators will need to reconcile the differences, but both funding levels are notable in contrast with the President’s budget request of $133 million.
This funding has a less clear path into the next minibus, as the Senate has not held a markup of the bill. This does not prevent a bill from being included in a possible agreement, but other bills that are farther along in the process may be more likely to move first.
NAAHL’s comparison of FY 2025 and FY 2026 funding levels for key housing and community development programs is available here.
National Defense Authorization Act (NDAA)
Congress is closing in on a final vote on NDAA, which authorizes defense and military activities and funding. On October 9, the Senate passed its version of NDAA, which included two bipartisan housing and community development amendments, the ROAD to Housing Act and a package of CDFI provisions. These amendments would help to expand and preserve housing supply, reduce barriers to housing development, and support additional investment in housing and other community needs. More information on the housing and community development provisions included by the Senate can be found here.
Among the provisions in the Senate’s NDAA amendments is the Community Investment and Prosperity Act, sponsored by Banking Committee Chairman Tim Scott (R-SC) and Senators Blunt Rochester (D-DE), Bernie Moreno (R-OH), and Andy Kim (D-NJ), which would allow banks to increase their public welfare investments, including equity investments in Low-Income Housing Tax Credits (LIHTC) and New Markets Tax Credits. On November 5, Representatives Mike Lawler (R-NY), Joyce Beatty (D-OH), and Young Kim (R-CA) introduced a House version of the bill.
The House passed its own version of NDAA in September which did not include the Senate’s housing and community development amendments. Reporting has indicated that House Financial Services Committee Chairman French Hill has concerns about including the full ROAD to Housing Act in the final NDAA, which Senate and House leaders are currently negotiating.
The CDFI amendment included in the Senate NDAA, let by Senators Daines (R-MT) and Warner (D-VA), would help CDFIs support housing and community development needs in the communities they serve through improvements to the CDFI Bond Guarantee program, an expanded secondary market for CDFI loans, and authorization of a program to help CDFIs provide access to affordable mortgages for Native families in rural areas. It is reported that Chairman Hill is also withholding the final support needed to include this popular amendment in the final NDAA.
To be included in the final NDAA bill, any provision must be agreed to by the chair and ranking member of the relevant House and Senate committees – often referred to as the “four corners.” Whether provisions are included can also be affected by broader negotiations on NDAA as both chambers work through their priorities.
Meanwhile, Housing & Insurance Subcommittee Chairman Flood has also floated the possibility that his bipartisan HOME Reform Act of 2025 could be included in the NDAA discussion. Chairman Flood and Ranking Member Cleaver introduced this legislation at the end of October which streamlines regulations in HUD’s HOME Investment Partnerships Program (HOME) to increase housing supply and lower costs.
NAAHL has called on the House and Senate leadership to include bipartisan housing and community development provisions in the final NDAA, which must be passed by both chambers to be signed into law. The final bill is expected to be voted on in early December and is considered a “must pass” piece of legislation. NAAHL will continue to monitor negotiations and passage of this legislation.
Upcoming House Hearing and Markup
This month, the House Financial Services Committee announced that on December 3 it will hold a hearing on “Building Capacity: Reducing Government Roadblocks to Housing Supply.” The Committee also scheduled a markup for December 16 and 17. The measures that will be considered will be released at a future date, but Housing & Insurance Subcommittee Chairman Mike Flood has indicated that he wants to have a markup of bipartisan housing legislation during December. This comes after Chairman Flood initially planned for an October housing markup that was canceled due to the House being out of session during the shutdown.
ADMINISTRATION
CDFI Fund
As part of the funding legislation signed by President Trump on November 12 to end the federal government shutdown, more than 4,000 RIFs issued during the shutdown were rescinded, including all CDFI Fund staff. Press report that all 81 CDFI Fund employees who received RIFs in October were officially reinstated on November 17, and the government funding legislation prohibits additional RIFs through January 30, 2026. While the RIF threat has subsided for now, timing for the release of funds administered by the CDFI Fund remains unclear. Prior to the shutdown, the CDFI Fund released supplemental Notices of Funds Availability (NOFA) for FY 2025 CDFI Program and Native American CDFI Assistance Program awards, but timing for awards remains uncertain. And while approximately $410 million is available in Treasury accounts, the Office of Management and Budget (OMB) has not formally released the funds needed to support Capital Magnet Fund (CMF) operations, including staff salaries, issuance of a NOFA, and eventual grant awards.
HUD
HUD Staff: The November 12 government funding legislation also rescinded RIFs for more than 440 HUD employees, including staff in the Office of Housing, Community Planning and Development, and the Office of Fair Housing and Equal Opportunity. Like the CDFI Fund, further RIFs of HUD staff are prohibited through January 30, 2026.
CoC Funding: On November 14, HUD released a Notice of Funding Opportunity (NOFO) for the $3.5 billion in CoC funding (see a summary from the National Alliance to End Homelessness here). The majority of this funding traditionally enables CoCs to renew assistance in permanent supportive housing. But the recently-released NOFO caps the amount of funding that can go towards permanent supportive housing at 30% and increases the share of funding for transitional housing. National groups estimate that this change in the breakdown of CoC funding would put more than 170,000 people at risk of homelessness. This policy change could also cause serious problems for permanent supportive housing developments because CoC dollars are often used by developers, owners, and operators of supportive housing to underwrite the operating costs for deeply affordable housing.
On October 28, more than 20 House Republicans sent a letter to HUD Secretary Turner in advance of the NOFO being issued urging HUD to extend for an additional year all existing grants expiring in 2026 under this program. Additionally, 42 Senate Democrats sent their own letter also urging Secretary Turner to renew existing CoC grants for FY 2025, and 19 state attorneys general and 2 governors sued the Administration over the changes in grant conditions. The Urban Institute released a blog highlighting the potential state-by-state impacts of these changes.
Interpretation of Federal Public Benefit: On November 26, HUD issued a notice stating its interpretation of what HUD funds and programs qualify as a “federal public benefit” and are subject to eligibility requirements of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). PRWORA limits eligibility to grant funds and other programs to U.S. citizens and “qualified aliens.” Under the notice, HUD states that grants to states and localities, as well as nongovernmental entities, and their subgrantees, administered through the Office of Community Planning and Development, including Emergency Solutions Grants (ESG), CoC funding, the HOME Investment Partnerships Program, the Housing Trust Fund, Pathways to Removing Obstacles to Housing (PRO Housing), and the Preservation and Reinvestment Initiative for Community Enhancement (PRICE) program, among others, are all subject to the requirement limiting eligibility for funds.
Consumer Financial Protection Bureau (CFPB)
Equal Credit Opportunity Act Regulations: ECOA prohibits lending discrimination based on certain protected classes, including race, color, national origin, sex, marital status, age, receipt of public assistance, or good faith exercise of any rights under the Consumer Credit Protection Act. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) transferred responsibility for ECOA to the CFPB. This month, the CFPB issued two proposed rules to update regulations related to ECOA: the regulation implementing ECOA, and the small business data collection regulation issued pursuant to Section 1071 of Dodd-Frank (Section 1071).
The first proposed rule would amend the existing ECOA regulation to align with recent executive orders, including Executive Order 14281, which states that it is the policy of the U.S. to eliminate the use of disparate impact liability to the maximum degree possible consistent with law. The proposal would provide that ECOA no longer authorizes disparate impact claims, update the standard for establishing that a lender was illegally discouraging credit applicants based on a protected class, and amend the requirements related to Special Purpose Credit Programs (SPCP).
The second proposed rule would update the Bureau’s 1071 regulation finalized in 2023 to remove reporting requirements for certain types of transactions, to require that lenders must originate at least 1,000 covered transactions (compared to a threshold of 100 covered transactions in the 2023 final rule, update the definition of small business to be institutions with gross annual revenue of $1 million or less, and reduce the number of data points that must be reported.
Comments for both proposed rules must be submitted by December 15.
Funding: Dodd-Frank provided that the CFPB could request funds from the combined earnings of the Federal Reserve for its operations. In a 2024 Supreme Court case, the Court upheld this funding mechanism.
In a court filing this month, the CFPB revealed that the Department of Justice’s Office of Legal Counsel had determined that the Bureau could only request and draw funds from the Federal Reserve when the Federal Reserve has profits. The Federal Reserve has not had profits since 2022, leaving the Bureau without access to funding from the Federal Reserve, its source of funding for operations, under the new Office of Legal Counsel opinion. As a result, the government has said that the CFPB is likely to run out of funds early in 2026. While the CFPB could request funding through the appropriations process, it has not done so to date.
FEDERAL HOUSING FINANCE AGENCY (FHFA) & THE GSES
This month, following a social media post from President Trump, FHFA Director Bill Pulte announced that the agency was considering supporting a 50-year mortgage product through Fannie Mae and Freddie Mac to make mortgage payments more affordable. Director Pulte also announced that FHFA was considering changes to make mortgages backed by the Enterprises portable and assumable to help homeowners access and maintain more affordable payments. Some observers raised concerns that these changes could result in higher overall costs for homebuyers, both through greater interest payments over the life of the loan and higher rates demanded by investors, and contribute to rising home prices.
Director Pulte also continued to indicate that the Administration is considering an offering of shares in Fannie Mae and Freddie Mac in the near future and said that he expected that the companies would remain in conservatorship for the time being. However, there remain concerns from some in the private sector about this approach; Fannie Mae and Freddie Mac investor Bill Ackman gave a presentation concluding that the government issuing shares in the companies was not feasible or desirable at the moment.
CONFIRMATIONS AND APPOINTMENTS
Department of Agriculture (USDA)
HEARING HELD: Glen Smith to be Under Secretary for Rural Development.
Department of Housing and Urban Development (HUD)
AWAITING FLOOR CONSIDERATION: Benjamin Hobbs to be Assistant Secretary for Public and Indian Housing.
AWAITING FLOOR CONSIDERATION: Ronald Kurtz to be Assistant Secretary for Community Planning and Development.
AWAITING FLOOR CONSIDERATION: Francis Cassidy to be Assistant Secretary for Housing and Federal Housing Commissioner.
AWAITING FLOOR CONSIDERATION: Joseph Gormley to be President of Ginnie Mae.
Department of the Treasury
AWAITING FLOOR CONSIDERATION: Derek Theurer to be Assistant Secretary for Legislative Affairs.
Consumer Financial Protection Bureau
NOMINATED: Stuart Levenbach to be Director of the Consumer Financial Protection Bureau.
Federal Deposit Insurance Corporation (FDIC)
AWAITING FLOOR CONSIDERATION: Travis Hill to be Chair of the Federal Deposit Insurance Corporation.