CCAH attended the October 13 meeting of the Housing Finance and Development Committee (HDFC) and provided public comment on the agency’s initial draft regulations, continuing our efforts to ensure California’s new affordable housing finance framework supports housing production rather than creating additional barriers. You can watch the entire hearing here. To skip to our Executive Director’s comments, please advance the recording to 1:56.51 or click here for a transcript.

In our comments and our initial letter, CCAH acknowledged the tremendous undertaking involved in consolidating multiple housing finance programs under a single structure, while also highlighting areas where we believe improvements are needed. A primary concern is the need for greater process certainty and accountability. We encouraged HDFC to establish clearer timelines and performance standards that provide certainty for applicants and funding partners.

CCAH also raised concerns about provisions that duplicate or conflict with requirements already administered through established programs such as CTCAC and CDLAC. California’s affordable housing delivery system is already highly complex, and we believe HDFC should focus on streamlining processes wherever possible rather than creating additional layers of regulation and underwriting standards.

Transparency and stakeholder engagement were also key themes of our comments. California’s housing finance system has benefited from public meetings, published scoring criteria, stakeholder workgroups, and regular regulatory updates. We encouraged HDFC to build upon those best practices and establish an ongoing process for industry engagement as the agency continues to refine and implement its programs.

In addition, CCAH identified several areas where additional clarity is needed, including sponsor experience requirements, project transfer provisions, affiliate relationships, program definitions, and underwriting requirements. Clear and consistent regulations reduce uncertainty, improve administration, and help avoid unintended consequences.

Finally, we emphasized the importance of structuring programs in a way that maximizes housing production and leverages both public and private investment. Affordable housing development depends on strong public-private partnerships, and regulations should support financially sustainable projects while encouraging continued participation from the nonprofit and private sectors.

CCAH appreciates HDFC’s willingness to engage stakeholders throughout this process and will continue working with the agency as additional drafts are released. We encourage our members to remain engaged and participate in future comment opportunities as these important regulations continue to evolve.