Saturday, April 7, 2012

Reinventing the 312 Home Improvement Loan Program

Over the last thirty years the community development field has moved away from its early focus on helping homeowners maintain and improve their properties towards the development of new affordable housing. Fueled by the resources of the Low Income Housing Tax Credit Program (LIHTC) and a confident economy, and in flight from lead remediation requirements for housing rehab, non-profits as well as for profit developers and local governments began to shift towards the promotion of new construction - both rental and homeownership - and away from housing rehab aimed at assisting individual owners.

The time has come to shift back.

Hundreds of thousands of foreclosed properties, declining property values and the loss of home equity, the absence of conventional credit, the need to make older houses energy efficient, opportunities to stimulate the local small construction trades and building supply markets - all of these factors demand that we look again at housing rehabilitation as an important policy option.

We need tools to promote the repair and rehabilitation of our older housing stock. Historically, the federal government played a leadership role in promoting home rehab and we need the Federal government to play this role again. A key role government can play is to authorize a significant amount of funding for the Section 312 Loan Program. We need to revisit this old tool and reinvent it making it relevant to the current situation.

The 312 Loan Program was authorized in the Housing Act of 1964. It provided loans from the Federal government through local municipal governments to home owners and landlords at 3% for a twenty year term. The per unit rehab cost allowed was $27,000, which in the 1970s and 1980s was a significant amount of money. It was used often in Urban Renewal Conservation Areas to assist homeowners in improving their properties and where it had a fairly major impact. It also served as a key component in the Federally Assisted Code Enforcement Program (FACE) to help owners bring their properties into code compliance. And it was the source of financing in the Urban Homesteading Program where vacant properties owned by the Federal government where auctioned off for a dollar.

The 312 Loan Program had some issues. It was cumbersome and time consuming for borrowers. It took a long time to get loans approved and people often deferred work while waiting for approval. People who were savvy enough to use architects, i.e. people of higher incomes, were often the most successful in securing funds. As local governments began to use Community Development Block Grant (CDBG) funds to support housing rehab, 312 became diminished as a tool and fewer funds were allocated to it. While the 312 Loan Program currently exists in the HUD menu of programs, it has no money allocated for it.

This needs to change.

Today we are confronted with a situation that demands a significant response. We as a nation want to overcome the effects of the foreclosure crisis and return more properties to productive use. We want to increase the energy efficiency of residential properties, and we want to stimulate the economy. These efforts are hampered by the absence of capital, but they are also hampered by an anti-government investment ethos on Capitol Hill. Why should government do what the private sector can do? Why bother funding an obscure program, the kind of "legacy program" that HUD in its strategic plan wants to shift its focus from?

Here are ten reasons:

1. It is a stimulus that everyday people in cities and inner ring suburbs can see and understand. While earlier stimulus efforts have created results that people can see, a national home improvement loan program can benefit thousands of citizens directly.

2. It promotes confidence. When someone sees their neighbor down the street put on a new roof or rebuild their porch it makes them feel more confident about the future of the neighborhood and it may lead them to seek to make repairs on their own. We need to put this dynamic in place.

3. It's simple. Unlike several of the initiatives being developed by HUD that are marching down the same sad path of prior Federal interventions in cities, it is simple and understandable. It helps people and not just developers. It's not social engineering and it doesn't have a lot of moving parts. It can effectively be described in thirty seconds.

4. It's a loan and not a grant. People paid on their 312 loans. Money invested in a national home improvement loan program will get substantially returned.

5. It has a multiplier effect. It creates jobs in the construction industry as well as in the building supply and manufacturing sectors of the economy.

6. The process can be improved. We know more than we did in the 1970s about how to bring products to consumers. With new technologies around developing the scope of work, loan origination and servicing software - and the potential for outsourcing these functions-all are potential ways this program can be more accessible and user friendly. We also know more about marketing and how to effectively promote such a program.

7. A delivery system exists to get this money out. We have a host of institutions like NeighborWorks America organizations, community development corporations, Community Development Financial Institutions, as well as delivery systems that still exist in local governments that can be organized to help citizens access these resources. We also have financial institutions that have been a delivery system for tax-exempt housing bonds that also could be part of a delivery system.

8. It can generate revenue for this delivery system. Charging loan origination and rehab service fees can generate revenue for cities and other providers.

9. It can promote widespread energy conservation. Borrowers could be required to have an energy audit and make changes based on the audit findings. Borrowers who choose to install solar heat could receive an interest rate benefit for their whole project.

10. It is more "shovel ready" than many stimulus efforts. Large public works projects require significant planning. Home improvement projects require planning and bidding out jobs but this process is usually less complex.

A national home improvement loan program based on the 312 Loan Program is not a panacea for urban ills. It is not an anti-poverty program - it is a home improvement program that can benefit low-income as well as other income homeowners - and as such can have a larger constituency.

Can't the private market do this? Sure, but it isn't. Capital is not flowing like it once did. Lenders aren't doing much in the way of home improvement lending and both supply of capital and demand for such capital is down. Equity lines that financed home improvement in the last several decades have dissipated, Demand needs to be stimulated. Providing an attractively priced loan product that is marketed well can stimulate that demand.

So how much would this cost? An initial allocation of $2.5 billion would potentially generate 50,000 loans with an average loan size of $50,000. Fees charged to borrowers for rehab services and origination could produce $100,000,000 - $125,000,000 in revenues throughout the delivery chain. $20,000 in materials purchases on a $50,000 rehab job could provide $1 billion in materials purchases for 50,000 projects, along with various sales tax revenues those purchases generate. This kind of volume would provide work for thousands of contractors, laborers, architects, building suppliers, and manufacturers of building supplies. It would also provide an interest rate return for the Federal Treasury.

For a redesigned 312 Loan Program to be effective in today's environment it would need a few changes. First, change the name. 312 means nothing to anyone outside government. The name does not encourage one to borrow money. Second, raise the interest rate to 5%, but retain the ability to finance projects at 3% if they meet certain criteria, like the installation of solar energy or the rehab of a foreclosed property. Third, raise the per unit amounts to $57,000 per unit, and $75,000 for the rehab of a vacant property. Fourth, make the loan available in cities and older suburbs with no qualifying income requirements, so that people would not have to be low-income to borrow the funds.

This is a conservative program. It is about conserving what we have - our rich and diverse housing stock - by promoting maintenance and improvement. It is easy to understand. It supports rank and file homeowners and not just developers. It engages all homeowners and is not limited to low income borrowers. While driven by the Federal government it allows for partnerships with local banks and non-profits with consumer lending capacity. It has the potential to stimulate local economies and lessen the cost burdens on municipal governments. But most of all it is a loan and not a grant program. It will return money to the Treasury.

Innovation is not only inventing new things. When we look ahead for change sometimes we ignore what worked in the past. We assume that just because something was done once, its shelf life has expired and can't be done again. Reinvention is also innovation. Repositioning old products to make sense in a new situation can be just as innovative as inventing complex new programs that look good on paper but don't deliver. Let's get real. Let's keep things simple. Let's reinvent 312.

Michael Schubert is the Principal of Community Development Strategies, a consulting firm that focuses on building organizational capacity for planning, implementing, and evaluating neighborhood revitalization strategies. For the last twenty years Michael has worked with municipal and state governments, foundations, and non-profits to improve neighborhoods. He can be reached at mfscds@aol.com


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