NCSHA Comments to HUD on First Fair Housing Assessment Tool for States and Insular Areas

While we support the goals articulated by the U.S. Department of Housing and Urban Development’s (HUD) AFFH regulations, we are deeply concerned that the state tool, which states must use to conduct the Assessment of Fair Housing (AFH) under AFFH, imposes unreasonable requirements on states that go well beyond what is necessary to achieve meaningful fair housing planning. We urge HUD to revise the tool in a manner responsive to our recommendations below.