Three months since Governor Eric Holcomb declared a public health emergency due to the coronavirus pandemic, Hoosiers are still waiting for a coordinated statewide housing stability policy response that aligns available federal, state, and local/philanthropic resources and provides emergency rental assistance. This blog post collects the analysis and recommendations that Prosperity Indiana and members of the Hoosier Housing Needs Coalition have offered to Indiana’s state and federal policymakers and other partners to date.
A common theme of our analysis and advocacy is the importance for state policymakers to use the time available during the eviction moratorium to create a coordinated policy response and clearly communicate procedures and expectations to renter families, landlords, and community service providers and stakeholders alike. Because many of the resources available for emergency rental assistance to date come through the CARES Act but are allocated through existing programs at the state and local levels with differing eligibility requirements, it’s essential that state leadership provides the role of Housing Stability Lead to coordinate these resources to ensure they reach the hardest hit populations and communities. And because data has emerged showing that low-income renters, women, and Hoosiers of color have been most affected by the pandemic, by loss of jobs and income, and by housing insecurity, it’s all the more urgent that a state Housing Security Lead takes responsibility that these Hoosiers aren’t further endangered at this critical time. In addition, it is clear that not enough federal resources or guidance has been received to fill the need statewide. Congress will need to provide additional resources, and the federal administration must expedite authorization and guidance so that no Hoosier is evicted or made homeless due to the pandemic.
Updating Indiana’s COVID-19 Housing Response (April 3, 2020) “[J]ust as the state has adopted an approach of #INthistogether to successfully weather the long-term impact of the crisis, Indiana must also use the policy tools at its disposal to craft a longer-term housing security response that keeps Hoosier families secure over the months to come.”
Prosperity Indiana Joins Housing Providers and Advocates Calling on Senator Young to Champion Emergency Rental Assistance for Indiana (April 21, 2020) “While it will take Hoosiers #INthistogether to address the state’s response, Congress must come through to meet Indiana’s short term emergency rental assistance needs.”
New Hoosier Housing Needs Coalition urges actions to ensure housing stability response to COVID-19 (May 1, 2020) “In order to prevent a sudden wave of evictions and the damaging health and social disruptions that follow for affected families, Indiana policymakers must plan ahead to create an emergency short-term rental assistance program and communicate steps to be taken. It will take each level of Indiana’s elected leaders, working hand-in-hand with community leaders and advocates, to achieve these steps.”
Indiana extends evictions pause through June 4, but what’s happening in your community? (May 5, 2020) “Indiana’s pause on evictions has been extended through June 4, and that means the state has one more month to create and implement a COVID-19 housing security policy response to ensure no Hoosier is evicted or becomes homeless due to the pandemic.”
Prosperity Indiana comments on 2020 amendment to 2019 OCRA Annual Action Plan (May 9, 2020) “[Our comments] demonstrate our concern about the missed opportunity of not employing allowed uses of Community Development Block Grant (CDBG) resources for emergency rental assistance as part of a recommended state COVID-19 housing stability plan.”
Indiana extends eviction pause again through July 1. The clock's now ticking for emergency rent assistance! (May 21, 2020) “[T]he state is now officially on the clock to have an emergency rental assistance program up and running so that no Hoosier becomes evicted or homeless due to the COVID-19 pandemic.
Prosperity Indiana comments on State of Indiana 2019 Annual Action Plan ESG-CV HOPWA-CV Amendments (May 22, 2019) “Prosperity Indiana especially appreciates that the draft plan includes funding that would create a structure for emergency rental assistance to be delivered statewide to Hoosier renters most in need.”
Prosperity Indiana comments 2020 amendment to 2019 CDBG Long Term Annual Action Plan (June 3, 2020) “[W]e ask you to reconsider the opportunity to use part of the CDBG resources covered by this amended Long-Term Phase of the COVID-19 Response Program to align with the long-term needs for housing security, including emergency rental assistance, in response to the pandemic.”
Short Term Emergency Rental Assistance White Paper for INHP (May 29, 2020) “This white paper examines the pros and cons of several types of STERA [Short Term Emergency Rental Assistance] programs, including those delivered at the federal, state, municipal, and/or private philanthropic levels. Using examples of existing or proposed programs, the paper walks the reader through the features of STERA programs and the benefits or drawbacks of key decisions that go into program design, including implications for program outcomes.”
Housing and Rental Assistance Among Hoosiers’ Top Unmet COVID-19 Needs (June 2, 2020) “Without coordinated action this month by state policymakers to enact a working rental assistance program and support from Indiana’s Congressional delegation to fund it, many Hoosier families remain at risk of eviction and homelessness when the state’s eviction moratorium expires June 30.”
Hoosier Housing Needs Coalition: Indiana not making enough progress to avoid an eviction crisis when moratorium ends June 30 (June 10, 2020) “Without a clearly communicated comprehensive statewide COVID-19 policy response in place, ending the eviction moratorium would inflict even more harm on the most disadvantaged Hoosiers, undoing all of the strides made by the state’s COVID-19 response to date.”
Hoosier Housing Needs Coalition Virtual Press Conference (June 10, 2020) ““Being evicted come July 1 will only further escalate the division, the trauma, and violence within our communities,” said Dee Ross, CEO & Founder of The Ross Foundation and Founder, Indianapolis Tenants Rights Union. “Tenant screening companies will judge them more harshly in conducting future background checks due to having an eviction filed against them, forever impacting their ability to secure safe and affordable housing,” said Amy Nelson, Executive Director, Fair Housing Center of Central Indiana.
Results of Entitlement Cities Survey on using CARES Act funds for emergency rental assistance (June 16, 2020) “Indiana needs statewide rent assistance, and CARES funds allocated to entitlement cities can be part of that if coordinated. Through a survey of cities conducted from late May through mid-June, here’s what we know to date about use of CARES Act resources by Indiana’s cities for emergency rental assistance.”
Recommendations for an Indiana Statewide Emergency Rental Assistance program using Coronavirus Relief Funds (June 16, 2020) “With an understanding that the full CRF allocation to Indiana may not be available for rent assistance, here are suggested guidelines for how a statewide rent assistance program could prioritize Hoosiers most in need.”
The Hoosier Housing Needs Coalition is sounding the alarm that not enough progress has been made by state and federal policymakers for renters affected by COVID-19 to avoid falling off an ‘eviction cliff’ when Governor Holcomb’s moratorium ends June 30.
Even while protesters are marching for racial equality in communities across the state, the pandemic is disproportionately harming and killing Hoosiers of color, and unemployment is impacting low-income renters, women, and Hoosiers of color most. Without a clearly communicated comprehensive statewide COVID-19 policy response in place, ending the eviction moratorium would inflict even more harm on the most disadvantaged Hoosiers, undoing all of the strides made by the state’s COVID-19 response to date.
Prosperity Indiana Executive Director Jessica Love said, “To be clear, we do not want to be in the position to ask for another extension of the eviction pause. We know landlords are hurting alongside renters right now. So, we had hoped that state and local governments would use the most recent extension period to proactively establish a coordinated and comprehensive plan to address this mounting crisis. But unfortunately, we are again approaching the moratorium deadline, without a clear path forward for the growing number of families getting behind on rent.”
With over a quarter million Hoosier renter families affected by the pandemic needing emergency rental assistance when temporary stimulus measures expire, the Coalition urges Governor Holcomb to take immediate steps to prevent upending the state’s economic recovery with a wave of evicted Hoosiers. Until emergency rental assistance is available across the state, Governor Holcomb must extend the eviction moratorium for Hoosiers affected by the pandemic, while considering comprehensive measures to respond to this looming aspect of the crisis.
Since the COVID-19 public health emergency began, housing advocates have urged Governor Holcomb to enact a plan and pledge that no Hoosier is evicted or made homeless due to the pandemic. In early May, the new Hoosier Housing Needs Coalition issued a set of recommendations based on best practices from states across the country, asking that the Governor appoint a Housing Stability Lead to coordinate available federal, state, and private/philanthropic resources to ensure that the hardest-hit communities and populations are assisted. And while promising ideas have been proposed at the state agency level and several cities have begun moving forward with rental assistance plans, based on what’s been presented publicly, these early efforts will fall far short of the need, and additional measures are now necessary to stem the potentially devastating housing impact statewide.
Housing and rental assistance are now among Hoosiers’ top unmet COVID-19 needs, with low-income renters and Hoosiers of color at increased risk. New data from Indiana 211 finds that, despite the eviction pause, housing is now the network’s top request for referrals and unmet needs, ahead of utilities, food/meals, and health care. Unlike before the pandemic, when most requests for rent assistance came from individuals unable to work, requests now come primarily from Hoosiers who are unemployed and looking for work. The pandemic has hit housing providers hard as well, with rent delinquency rates increasing above 20% and now coming mostly from market rate housing in the $20,000-$30,000 income range most typical of the state’s renters. This aligns with state unemployment data finding that Hoosiers who have been most likely to lose their jobs and income – working in accommodation and food services, retail, health care and social assistance – are primarily held by low-income renters, women, and people of color.
In addition, brand-new U.S. Census data finds that Black Hoosiers were nearly three times as likely to not have been able to pay May rent on time as white Hoosiers. And while 31% of white Hoosiers report having little or no confidence in being able to pay their June rent, that proportion increases to 41% for Black and 72% of Latino Hoosiers. Ending the eviction moratorium without an equitable housing security plan in place will further disproportionately harm these Hoosiers of color in a time of unparalleled turmoil and peril.
But Hoosiers can't be expected to pay the rent with assistance that hasn't shown up. Indiana has paid less than half (45.5%) of the 630,383 total initial unemployment claims over March and April. Estimates show that up to 400,000 additional Hoosiers may have been unemployed due to the pandemic but couldn’t get through the state’s unemployment system. And while the State has received over $70.4 million in allocations from the CARES Act that could be used for emergency rental assistance (including $32 million in Emergency Solutions Grants and $38.4 million in Community Development Block Grants), in addition to $2.6 billion from the Coronavirus Relief Fund, to date only $7.6 million has been earmarked thus far by the State for emergency rental assistance. And while some cities, like Evansville, Fort Wayne, and Indianapolis, are moving forward with using their respective CARES Act resources for rent assistance, and various churches and nonprofits are assisting families with support they have secured, these individual efforts cannot meet the need of the 258,782 Hoosier families that the National Low Income Housing Coalition estimates will need assistance just this summer. In fact, that number declines only to 186,069 – with unemployment rates that the Congressional Budget Office expects to remain above 10% – through June 2021. Meanwhile, residents of communities where emergency rental assistance has not been announced are awaiting relief with no clear understanding of what might be provided, when evictions filings are set to start back in a mere three weeks. But Indiana’s local and state resources can’t do it alone – Congress must pass the ‘Emergency Rental Assistance and Rental Market Stabilization Act’ to adequately fund any statewide program that Indiana builds.
“Any state or city COVID-19 rental assistance program needs to include directly-impacted people and Black- and Brown-led organizations in their planning and delivery to make sure the vulnerable communities who most need assistance actually receive the funds. These need to include organizations with the right capacity and people to do outreach and walk door-to-door to ensure Black and Brown people aren’t just jumping through hoops but have direct access to the help they need. Otherwise there are a lot of vulnerable communities all throughout Indiana who will be forgotten yet again, and left without the right resources,” said Derris Ross, CEO and Founder of the Ross Foundation and the Indianapolis Tenants’ Union.
“It is imperative that the state be a leader in addressing the critical renter needs approaching. If rental assistance will not be ready for those in need to access, there must be an announced plan to help those at risk of homelessness to navigate these troubling times and assist in working with at-need landlords. Our Hoosier renters are already seeing the increased harms due to their vulnerability. For example, the FHCCI has received increased allegations of sexual harassment for at-risk renters unable to pay rent by bad acting landlords,” stated Amy Nelson of the Fair Housing Center of Central Indiana.
“Both the state and local county health departments have provided significant resources for those experiencing homelessness to reduce emergency shelter numbers in response to the public health crisis, with shelter populations reduced to allow for adherence to public health guidelines. Our crisis response system cannot handle an influx of new households experiencing homelessness because of the looming eviction crisis. If there is not a statewide effort to address this, our homeless response system will once again be overburdened and all of the work done to keep people safe and healthy will be undermined. Housing is healthcare and we have to keep people in housing and out of the shelter system!” said Dr. Chelsea Haring-Cozzi, Executive Director of Coalition for Homelessness Intervention & Prevention (CHIP).
"As the economic impact of COVID-19 unfolds, the Neighborhood Christian Legal Clinic is concerned that more and more of our low-income neighbors and communities of color will slip into greater economic distress. We anticipate a “tsunami of foreclosures and evictions" that is reminiscent of the Great Recession a decade ago. A statewide plan is needed to provide hope for the vulnerable and the marginalized, who will disproportionally suffer housing insecurity," said Amy Horton, Executive Director of the Neighborhood Christian Legal Clinic.
“What we would love to see, in the end, is that no additional Hoosiers become homeless as a result of COVID-19. What we need to see, now, is a coordinated plan with strategies outlined to achieve that goal. We want to see Indiana move from the relief phase to true recovery and resiliency. But if thousands across the state become homeless next month, when families need to be focused on the future and gearing up for things like a new school year, it will absolutely throw Indiana’s pandemic recovery into reverse,” said Prosperity Indiana’s Jessica Love.
Three months into the state’s COVID-19 response, Indiana can’t risk backsliding on its ‘Back on Track’ recovery plan by families forced to drag their belongings to the curb and potentially contracting coronavirus in homeless shelters. At a bare minimum, the following should be implemented:
About the Hoosier Housing Needs Coalition:
Hoosier Housing Needs Coalition (HHNC) was formed by members of Indiana’s housing security advocacy community in April 2020 to support advocacy and education related to housing and homelessness prevention in response to the COVID-19 pandemic. Staffed by Prosperity Indiana through advocacy and coalition building grants from the National Low Income Housing Coalition and the Central Indiana Community Foundation, HHNC convenes partners from across Indiana to advocate for immediate, medium- and long-term housing stability policy solutions and conduct education and research to achieve federal, state, and local policies for an equitable response and recovery to the pandemic and beyond.
The HHNC Steering Committee is comprised of members from AARP Indiana, the Coalition for Homelessness Intervention & Prevention (CHIP), Fair Housing Center of Central Indiana, Family Promise of Greater Indianapolis, Indiana Coalition Against Domestic Violence, Indiana Institute for Working Families – INCAA, Prosperity Indiana, and The Ross Foundation.
Housing security is emerging as Indiana’s top need during the ongoing pandemic, with data supporting that COVID-19 income loss as the main cause. And while Governor Holcomb’s eviction and foreclosure moratorium has been essential for Hoosiers economically affected by COVID-19, it has also obscured the mounting need for housing assistance throughout the pandemic and the community’s recovery period to follow. Without coordinated action this month by state policymakers to enact a working rental assistance program and support from Indiana’s Congressional delegation to fund it, many Hoosier families remain at risk of eviction and homelessness when the state’s eviction moratorium expires June 30.
Data from the Indiana 211 Partnership show that despite the eviction pause, 22,354 Hoosiers have contacted 211 seeking housing services, with a one-week maximum of 2,707 requests over that time. Housing requests are up 22% since before the declared public health emergency. Requests for rent payment assistance, 11, 253 total since the COVID-19 public health emergency, have come in at a rate nearly three times any other housing assistance type, including for homeless shelters or mortgage assistance. Throughout May, housing was the 211 network’s top need for both referrals and unmet needs, ahead of utilities, food/meals, and health care. And while the majority of housing requests come from Indiana’s largest cities, they come from all regions of the state and from urban, suburban, and rural counties alike. Analysis by Indiana 211 found that, consistent with pre-emergency data, single females were the most common household composition reporting housing needs. However, the most common reported employment status since the declared public health emergency is now ‘unemployed and looking for work’. Indiana 211 reports “[t]his is not consistent with pre-public health emergency data, where unable to work/disabled was the primary reported status.” COVID-19 related lack of income is now fueling the need for housing assistance.
The burden of lost jobs and income during the pandemic are largely falling on low-income Hoosier renter households, but the assistance provided to date is not being directed to them. Since Governor Holcomb declared a public health emergency on March 6, Hoosiers have filed 698,492 initial unemployment claims. However, national estimates find that for every 10 successful filings, three to four people tried to apply but could not get through, and two more found the system too difficult to attempt to apply, meaning there are up to 419,094 more Hoosiers who have lost jobs and income but have not been successfully assisted with state or federal pandemic unemployment assistance. In addition, of the over quarter-million Hoosiers with continued unemployment claims, the largest industries affected include accommodation and food services, retail, health care and social assistance, administrative support and waste management, the kinds of jobs held by low-income renters, women, and Hoosiers of color. And while help has been made available to Indiana homeowners to avoid foreclosure through the Hardest Hit Fund, so far the state’s guidance for Hoosier renters on June 1 still relied on advising tenants to ask landlords to set up payment plans or consult local charities and churches for assistance to avoid eviction.
COVID-19’s increasing impact on housing has also been hurting Indiana’s housing providers, as evidenced by collections data that declined sharply from April to May. The Indiana Apartment Association reported that members only collected 79% of rent on-time in May, down from 94% in April, with a delinquency rate jumping from 6% in April to 21% in May. In response, 95% of IAA member properties are waiving late fees, 46% are creating payment plans, 9% are discounting rent paid on time, and 5% are deferring rent. IAA finds that the highest percentage of May delinquency comes from market rate/conventional properties (compared to low-income tax credit program or student housing). The income category most likely to be delinquent is not the lowest ($0-$20,000), but between $20,000-$30,000 for 20% of renters who were delinquent in May. This is the range of the average Indiana renter’s wage and provides further evidence that Hoosiers whose jobs are most likely to be affected by COVID-19 are also those least likely to be able to afford rent.
And while the eviction moratorium masks the true need, estimates from the National Low Income Housing Coalition find that 267,832 renter households have been affected by the pandemic in Indiana. But because only 9,051 of those households are served by HUD-subsidized housing, 258,782 low-income Hoosier renter households will need emergency rental assistance by September 2020, two months after the eviction moratorium is lifted and pandemic unemployment insurance ends. Using Congressional Budget Office estimates of an unemployment rate that stays above 10% through July 2021, over 186,000 Hoosier households will likely continue to need rent assistance through next summer. The cost to keep these affected Hoosier renters housed is nearly $98M per month and $1.6B total, but that pales in comparison to the devastating personal, economic, and public health costs of Indiana’s policymakers allowing nearly a quarter of a million Hoosier families to risk being evicted or becoming homeless.
The economic effects of COVID-19 will not disappear overnight. A new nationwide poll from Opportunity Starts At Home finds “over half (54%) of all people express concern that they will lose their housing if they don’t get additional assistance to help cover the costs – and this concern is more acute among lower-income households and people of color (61% of households making below $40,000 say this is a concern; and 72% of African Americans and 76% of Latinos say this is a concern, compared to 43% of whites).” In addition, among all Americans, 93% believe the Congress should take major action to “provide emergency rental assistance for people who are struggling to afford the rent and are at serious risk of eviction as a result of the coronavirus outbreak”.
Simply put: to address Hoosiers’ urgent need for housing stability before the eviction pause expires on June 30, Indiana’s state policymakers must implement a COVID-19 housing stability plan and Indiana’s Congressional delegation must provide adequate resources to ensure no Hoosier is evicted or made homeless due to the pandemic.
Indiana’s pause on evictions, foreclosures, and utility shutoffs has been extended again, with an end date now set for July 1. That means the state is now officially on the clock to have an emergency rental assistance program up and running so that no Hoosier becomes evicted or homeless due to the COVID-19 pandemic.
Governor Eric Holcomb’s Executive Order 20-28, announced on May 21, extends the moratorium on evictions and foreclosures for residential real estate or property, whether rental or otherwise, until July 1, along with a pause on utility shutoffs. The moratorium had previously been extended to match the public health emergency, which was set to expire June 4.
An exception the Executive Order makes is that starting May 22, landlords may file for 'emergency' evictions. Since the Executive Order now makes it clear that filing claims for emergency possession are allowed, landlords can only do that for one reason -- if the tenant commits waste. In other words, the tenant needs to have actually caused, or is causing, actual damage to the physical structure of the rental property. The Executive Order makes it clear that nonpayment of rent is not 'waste' and is not an eligible reason for eviction until July 1.
Under current state guidance, renters who are still having issues with their landlords should first consult IHCDA’s Coronavirus Eviction & Foreclosure Prevention Guide which provides a FAQ section and encourages renters to seek a payment plan with landlords. Renters should also consult a summary of their rights as a tenant from Indiana Legal Services, Inc. and may also file a complaint with the Attorney General’s office to report potentially unlawful evictions.
The expiration date for the moratorium means that evictions for nonpayment of rent will be allowed starting July 1. This means the clock is now ticking for Indiana to have a plan for emergency rental assistance up and running before the end of June. The state and many of its cities has begun to receive millions of dollars in funds from the CARES Act that can be used for housing security, including emergency rental assistance and homelessness prevention.
Earlier this month, Prosperity Indiana and partners from the Hoosier Housing Needs Coalition offered recommendations for a coordinated Indiana COVID-19 housing security plan that includes urging the state to appoint a Housing Stability Lead to ensure that resources are distributed equitably to Indiana's hardest hit populations and communities. We are also calling on Indiana's Congressional delegation to support #RentReliefNow in the next coronavirus relief package to provide the necessary funding for 258,782 low-income Hoosier renters who will need rental assistance in the wake of the pandemic.
Please reach out to email@example.com to join our efforts!
Indiana’s pause on evictions has been extended through June 4, and that means the state has one more month to create and implement a COVID-19 housing security policy response to ensure no Hoosier is evicted or becomes homeless due to the pandemic.
Governor Eric Holcomb’s Executive Order 20-25 announced on May 1 extended the eviction/foreclosure moratorium on residential real estate or property, whether rental or otherwise, until June 4. In Section 1 of Executive Order 20-06 (the initial ‘eviction pause’) the Governor issued a moratorium on the initiation of eviction or foreclosure actions “…for the duration of the state of emergency. In Section 1 of the new Executive Order 20-25 the Governor extended the public health disaster emergency to June 4. which is 30 days beyond the most recent expiration date of May 5.
The extended pause on evictions is good news because Indiana doesn’t yet have a policy response for when the moratorium is finally lifted. An estimated surge of 43,800 low-income Hoosier renter households will need emergency housing assistance due to the pandemic. Indiana’s federal, state, and community leaders must pledge that those families aren’t evicted or made homeless.
That’s where you come in. Prosperity Indiana and a group of housing security advocates have formed the Hoosier Housing Needs Coalition and released a set of policy recommendations, but we need to hear your voice. Please reach out to firstname.lastname@example.org and let us know:
With your help, we will work to make sure Indiana delivers an equitable housing security policy related to COVID-19 response and recovery.
While Indiana has reopened the Hardest Hit Fund for homeowners in response to the COVID-19 pandemic, assistance for Hoosier renters who are also hit hard during the crisis remains unclear under current state guidance. Prosperity Indiana understands that there are lots of moving parts, and that the state doesn’t yet have the direction it needs from HUD regarding implementation of CARES Act funding Indiana will receive. But we also haven’t yet heard a commitment from the Governor that Indiana intends to do whatever it can to support renters and ensure no Hoosier is evicted or becomes homeless due to the COVID-19 crisis.
For those reasons, Prosperity Indiana and several key housing stability advocates have formed the Hoosier Housing Needs Coalition with a steering committee that is first focusing its efforts on making recommendations regarding critical short-term emergency rental assistance and homelessness prevention. We invite members to join the coalition’s efforts by reaching out to email@example.com to receive updates and find out additional ways to get involved.
Here is the press release sent by the Hoosier Housing Needs Coalition on May 1 urging that Indiana create an #INthistogether housing stability response to the COVID-19 crisis:
FOR IMMEDIATE RELEASE:
May 1, 2020
Contact: Andrew Bradley, Policy Director, Prosperity Indiana
firstname.lastname@example.org, 317-222-1221 x403
New Hoosier Housing Needs Coalition urges actions to ensure housing stability response to COVID-19
INDIANAPOLIS – Rent is due May 1 across Indiana, but hundreds of thousands of Hoosiers impacted by the COVID-19 pandemic won’t be able to pay, leaving them open to eviction and threatening their long-term housing stability. The newly-formed Hoosier Housing Needs Coalition is issuing policy recommendations to avoid a tsunami of evictions and homelessness in the wake of the COVID-19 pandemic. Formed to advocate for housing stability policy solutions for an equitable response and recovery to the pandemic, the Coalition is urging immediate action ahead of the expiration of Indiana’s moratorium of evictions, which is set to expire on May 5.
Housing stability is a major, unaddressed need in the face of the pandemic. Over half a million Hoosiers have filed for unemployment since Governor Holcomb issued a pause on evictions on March 19th. While this pause was a critical and welcomed step, the state has not yet confronted the economic impact on Hoosier renters. And while the economic fallout is felt across the state and cuts across all demographics, Hoosiers of color and those working in occupations including manufacturing, retail, accommodation and food services, and health care and social assistance are more likely to have been furloughed, have hours reduced, or been medically impacted by the COVID-19 pandemic.1,2 While more on-the ground data is needed, estimates from the National Low Income Housing Coalition find that Indiana will see a surge of 43,800 newly low-income renters as a result of COVID-19, and a total of 205,837 low-income Hoosier renter households who will need short-term emergency rental assistance in the wake of the pandemic.3
Mitigating steps: While a pause on evictions was necessary, it specifically did not relieve any portion of rent or other lease obligations. And while federal coronavirus response has included limited additional unemployment and one-time stimulus payments, this is not enough for the many thousands of Hoosier renter households whose incomes have declined and who will be subject to eviction if the pause is suddenly lifted.
For these reasons, the Hoosier Housing Needs Coalition calls on Indiana’s policymakers at the state, federal, and local levels to commit to an #INthistogether housing security response that ensures no Hoosier is evicted or becomes homeless due to the COVID-19 crisis. In order to prevent a sudden wave of evictions and the damaging health and social disruptions that follow for affected families, Indiana policymakers must plan ahead to create an emergency short-term rental assistance program and communicate steps to be taken. It will take each level of Indiana’s elected leaders, working hand-in-hand with community leaders and advocates, to achieve these steps:
First, Indiana must create certainty for Hoosier renters and landlords with updated deadlines and information:
While the eviction pause is still in place, Indiana must enact a housing stability plan to keep Hoosiers in their homes, prevent homelessness, and keep rental properties viable:
Keeping Indiana’s responsible housing providers and rental property investments viable is critical for long-term housing security for all Hoosiers. An Indiana COVID-19 housing security plan should incorporate features to support owners/operators, including:
Indiana’s Congressional delegation must also contribute fully to the #INthistogether housing security response by championing emergency rental assistance in future federal coronavirus response legislation.
“Local, state, and federal officials must take immediate action to keep the thousands of Hoosier children and their families who are on the brink of homelessness due to the COVID- 19 crisis from being evicted and to help families who are homeless get housing,” said Mike Chapuran, Executive Director of Family Promise of Greater Indianapolis.
“Prior to the COVID-19 pandemic, Indiana was already facing an extreme housing crisis. The lack of housing affordability, reports of housing discrimination, documented incidents of substandard housing, and the number of our cities in reports of highest evicting cities, had our Hoosier renters already struggling to secure safe homes for them and their families,” stated Amy Nelson, Executive Director of the Fair Housing Center of Central Indiana. “Now more than ever, we need our public officials identify this housing crisis as an emergency need and take the steps necessary to assist those most at risk of housing loss,” Nelson said.
“Once again, Indiana is topping terrible charts when it comes to evictions. According to Eviction Lab’s new COVID-19 Housing Policy Scorecard, Indiana is ranked near the bottom for its state level response, which has only included a moratorium on evictions for the duration of the state’s stay at home order thus far. But to be clear, our concerns are not about rankings. Our concerns are about the people impacted by the lack of policies and programs to support renters in this state,” said Jessica Love, Executive Director of Prosperity Indiana.
“And if we don’t do more to get ahead of the coming compounding crisis, Hoosiers – regardless of whether they’re going back to work – may soon have no home to return to at night. We can, and we must do better. So, we’re offering our assistance in thinking through a better response and making recommendations that are meant to reverse the trajectory for Hoosiers struggling the most right now,” Love said.
The founding steering committee for the Hoosier Housing Needs Coalition includes: AARP Indiana, the Coalition for Homelessness Intervention & Prevention (CHIP), Fair Housing Center of Central Indiana, Family Promise of Greater Indianapolis, Indiana Coalition Against Domestic Violence, Indiana Institute for Working Families – INCAA, Prosperity Indiana, and The Ross Foundation. Prosperity Indiana staffs its coalition activities through grants from the National Low Income Housing Coalition and the Central Indiana Community Foundation.
Hoosiers and organizations who are interested in joining the Hoosier Housing Needs Coalition are encouraged to contact the coalition by email at email@example.com.
1‘Demographic Distributions’ via https://www.coronavirus.in.gov/
2‘Weekly Unemployment Claims’ via http://www.stats.indiana.edu/claims/industry-visualization.asp
About Hoosier Housing Needs Coalition
Hoosier Housing Needs Coalition (HHNC) was formed by members of Indiana’s housing security advocacy community in April 2020 to support advocacy and education related to housing and homelessness prevention in response to the COVID-19 pandemic. Staffed by Prosperity Indiana through grants from the National Low Income Housing Coalition and the Central Indiana Community Foundation, HHNC works to convene partners from across Indiana to advocate for immediate and long-term housing stability policy solutions and conduct education and research to achieve federal, state, and local policies for an equitable response and recovery to the pandemic and beyond.
Today a group of 17 Hoosier housing providers and housing security advocates joined Prosperity Indiana in sending a letter to Senator Todd Young, asking him to urge the Senate to include $100 billion in emergency rental assistance in the next coronavirus response stimulus bill. This request for the Senator’s leadership around this widespread national concern would address the estimated housing assistance need for more than 200,000 of Indiana’s lowest income renter households affected by the crisis.
The COVID-19 outbreak is expected to continue to cause great financial harm to businesses, workers, and communities in Indiana for the foreseeable future. Since the passage of the CARES Act, an additional 245,194 Hoosiers have filed for unemployment, at a rate more than 4000% higher than a year before. Estimates show that Indiana may lose over 400,000 total jobs due to the pandemic and reach an unemployment rate of 15 percent by July. Nearly a third of tenants did not pay rent in the first week of April, according to national estimates. These indicators are a clear sign that additional government action will be needed to ensure people remain in their homes rather than overwhelm the homeless system.
Estimates from the National Low Income Housing Coalition find that 205,837 extremely low-income and very low-income Hoosier renter households will need to be assisted with short-term rental assistance, as a result of the COVID-19 pandemic and economic after-effects. With an average cost of $6,494 per affected household, Indiana’s total annual cost of meeting unmet rental assistance needs will be $1.34 billion. While it will take Hoosiers #INthistogether to address the state’s response, Congress must come through to meet Indiana’s short term emergency rental assistance needs.
This is why an estimated $100 billion in emergency rental assistance is needed to avoid a financial cliff for renters – once eviction moratoria are lifted and back-rent is owed – and ensure the continued viability of our country’s essential affordable housing infrastructure. This direct rental assistance could ultimately prevent the current public health and economic crisis from morphing into a broad-scale financial market collapse like we saw in 2008.
Senator Young needs to hear from you regarding the reasons housing security is essential for Hoosiers throughout the pandemic. Click here to add your name to the letter calling on Senator Young to champion emergency rental assistance for Hoosiers.
Today, Prosperity Indiana submitted a letter on behalf of our network opposing the federal government’s proposed CRA rule change, and offering recommendations to instead strengthen our communities. In our letter, Prosperity Indiana made the following arguments opposing the CRA rule change:
Prosperity Indiana appreciates the opportunity to comment regarding the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) proposed regulations regarding the Community Reinvestment Act (CRA). Since 1996, banks have issued almost $2 trillion in loans and investments in low- and moderate-income communities, ensuring more individuals have the opportunity prosper and become homeowners, more businesses receive loans to grow and thrive, and more community development organizations can expand their work to revitalize neighborhoods. CRA is a critical tool to address equity in lending, access to credit, and investments in underserved communities.
Prosperity Indiana is a network of nearly 200 organizations and individuals committed to advancing community economic development statewide. The focus of our efforts is to ensure everyone can enjoy equal economic and social opportunities and live in thriving communities. In carrying out this work, we know how critical CRA is to ensuring that areas and/or projects that would not otherwise receive investment can secure critical capital from banks through loans and investments for affordable housing and economic development. These investments and credit services spark neighborhood revitalization and help more Hoosiers achieve and maintain economic success.
The timing of the closing of this comment period comes at an especially unfortunate time, as Indiana is under a public health emergency under the COVID-19 pandemic, which has caused Prosperity Indiana and most of our member organizations to dramatically alter our business operations. Like many of our community economic development members we serve, Prosperity Indiana has been called upon to shift much of our focus to immediate needs brought about by the pandemic. Many of those members and their partners across Indiana who are on the front lines of serving their communities do not have the time or resources needed to provide comments to these proposed CRA rule changes in the middle of the pandemic. We therefore ask that you give additional consideration to the comments of the organizations who represent those addressing those hardest hit during this pandemic.
With that in mind, we have strong concerns about how the proposed substantial revisions to the CRA’s regulations do not all appear to align with the intent of the Act. And while the CRA was established to address a legacy of redlining and divestment in low- and moderate-income (LMI) communities, the proposed changes raise concerns about how it will affect CRA’s charge to affirmatively meet the community needs for credit and services in LMI communities. Prosperity Indiana has identified core issues of critical concern in the NPR, which would result in diluting benefits for LMI communities and lead to exacerbating banking deserts for these communities. Prosperity Indiana has categorized the damaging impacts of the NPR into three key areas: what counts, how it counts, and where it counts.
What counts: By broadening what bank activities count as CRA-qualifying and diluting the focus of bank activities on LMI consumers and communities, the changes would weaken the ability of the CRA to specifically target services to those LMI communities. Deleting ‘economic development’ & ‘revitalization/stabilization’ of LMI communities from the definition of community development would take emphasis away from rehabilitating communities impacted by the legacy of redlining and ensuring stability of those who would fall prey to it if regulations are weakened. Introducing a ‘non-exhaustive’ list of eligible activities that includes a definition of ‘infrastructure’ for activities that are not clearly limited to LMI communities (such as roads and even sports stadiums) would further lessen the impact of targeted investment. In addition, no longer considering key bank services (such as deposit accounts) as qualified activities could lead to proliferation of check-cashing, payday lending and other subprime services and further drive banking deserts if the NPR is finalized. And by counting financial education for all income levels and widening the definition of community development services to include all volunteer activities, the NPR would reduce the CRA’s intended focus and impact on LMI communities.
Where it counts: Because the NPR limits consideration of bank branches more than under the current CRA service test, it would introduce uncertain effects for banks and the communities, non-profits, and individuals they serve in Indiana. And while assessment areas are updated in ways that aim to account for the proliferation of internet-based banks, there is much that is left vague or unknown about how the new regulations would assign deposits collected via the internet to branches. The NPR also notes that there is an allowance for credit for qualifying activities conducted outside of bank assessment areas. We continue to have concerns about how these changes will impact investment in small non-profits in Indiana.
How it counts: The proposal dramatically and irresponsibly expands what activities would be eligible for CRA credit. CRA serves Indiana’s communities by driving resources – we otherwise could not access – to places where they are needed. These resources address the financial and community development needs identified and prioritized by local communities. Switching to a “non-exhaustive list” of eligible activities – to include infrastructure, transportation, and even sports stadiums – removes Indiana’s community voices from determining our own needs.
Under this NPR, retail lending analysis would count for much less under the new proposed exams, which could exacerbate banking deserts. Potential impacts of a ‘one ratio test’ include a reduction in valuing retail branches in LMI communities and the potential to encourage an over-reliance on the largest and easiest deals at the expense of small-dollar business and home mortgage lending in LMI communities and a reduction in partnerships with small non-profits who make significant local impact in LMI communities. The regulations would also result in the lack of differentiation for asset classes, meaning state or regional banks are being compared to the largest banks on performance.
This single-ratio approach completely disregards whether the community development and financial needs of an area are being served by the bank or its investments. And as a result, the nearly 200 organizations that make up Prosperity Indiana’s membership, that have served our neighborhoods for years, and whose experience and expertise is seriously considered as part of the current CRA examination process, will be rendered voiceless. We would no longer be able to identify and prioritize our needs. Nor would our members and partners be taken as seriously by examiners when bank actors behave inappropriately in our community.
The single ratio is a deeply flawed concept. This was made clear during previous public comment periods. Yet it still remains part of this proposed rule. Please listen to our members from across Indiana during this period. The single ratio must be discarded.
Further, the rule proposes that a bank must meet investment benchmarks in only a “significant portion” of its assessment areas in order to receive a satisfactory or outstanding rating. The rule suggests that a “significant portion” be defined as something more than 50 percent.
That approach would legalize and encourage redlining! Communities like those that our members represent across the entire state of Indiana will be in the areas that are left behind. Permitting such behavior would bring us back to an era where financial institutions had the option to draw red lines around—and deny financial services to—poor neighborhoods and all neighborhoods of color. Except this time, it’s worse because we understand, yet choose to ignore, history.
The OCC and FDIC acting without the participation of the Federal Reserve risks producing three separate sets of CRA regulations. That makes everyone’s job more complicated, less transparent, and results in confusion. And in the end, Indiana’s communities will lose.
The problems of the single ratio, the overly broad definitions of CRA-eligible investments, the gutting of communities’ voices, the speedy rule-making process, the credibility gap created by the Federal Reserve’s absence, and the lack of good faith and outreach from the OCC that drove this reckless proposal make it beyond repair.
Because the CRA was originally enacted to end redlining, the primary goal of CRA modernization should continue to prioritize the problem CRA was intended to fix. Above all, it is critical for any CRA modernization to preserve the original intent of the CRA. But unfortunately, by damaging what counts in the CRA, where it counts, and how it counts, this proposal prioritizes policy compliance over impact and outcomes for the LMI families and communities that Prosperity Indiana and its members serve. On behalf of the low- and moderate-income people and places Prosperity Indiana serves, we ask that you please discard this proposal and start again. But if this rule does move forward, please keep our recommendations for Indiana’s communities at the forefront of the final rules.
Updating Indiana’s COVID-19 Housing Response
FOR IMMEDIATE RELEASE
April 3, 2020
Contact: Jessica Love, Executive Director, firstname.lastname@example.org, 317-222-1221 x402
Andrew Bradley, Policy Director, email@example.com, 317-222-1221 x403
In less than a month since Governor Eric Holcomb issued Executive Order 20-02, declaring a Public Health Emergency for Coronavirus disease on March 6, 2020, the world around us has drastically changed. This includes how the state has responded to the pandemic’s effects on housing, landlord-tenant relations, and evictions and foreclosure. And just as the state has adopted an approach of #INthistogether to successfully weather the long-term impact of the crisis, Indiana must also use the policy tools at its disposal to craft a longer-term housing security response that keeps Hoosier families secure over the months to come.
Following the original declaration of Public Health Emergency, Governor Holcomb became one of the first state leaders to help keep residents secure at home by issuing a Temporary Prohibition on Eviction and Foreclosures through Executive Order 20-06 on March 19. Combined with the Governor’s veto of the eviction bill SEA 148, these executive actions helped relay a sense of calm and stability for the more than two million Hoosiers who rent – over 30 percent of the state’s population. However, the pause in evictions is currently limited both in time – tied to the Public Health Emergency and set to expire with that emergency order by April 6 unless extended – and in scope. The scope limitation results from the order saying no provision “shall be construed as relieving any individual of their obligations to pay rent” or other obligations under a tenancy or mortgage.
But just as Governor Holcomb is expected to extend the duration of the original public health emergency to reflect the ongoing timeline of the pandemic, so too should he adjust Indiana’s housing response and executive orders to reflect the evolving facts on the ground, aligned with policy tools at his disposal. Here are several ways Governor Holcomb can ensure that the COVID-19 pandemic doesn’t create a housing and eviction crisis before the economic effects of the emergency subside.
Now is the time for Indiana to take active steps to ensure that the tens of thousands of Hoosiers whose employment has been affected by the COVID-19 pandemic do not see the economic fallout continue to snowball into the loss of stable housing. Clear, decisive steps to utilize available resources to keep Hoosiers in their homes and their heads above water could make the difference in getting Indiana past this crisis in the long run.
About Indiana Association for Community Economic Development D/B/A Prosperity Indiana
Prosperity Indiana is a statewide membership organization for the individuals and organizations strengthening Hoosier communities. Prosperity Indiana builds a better future for our communities by providing advocacy, leveraging resources, and engaging an empowered network of members to create inclusive opportunities that build assets and improve lives. Since its founding in 1986, Prosperity Indiana has grown to approximately 200 members from the public, private, and nonprofit sectors.
March 25, 2020
Contact: Jessica Love, Executive Director
firstname.lastname@example.org, 317-222-1221 x402
Andrew Bradley, Policy Director
Housing Advocates Thank Governor Holcomb for Protecting Hoosier Renters with Veto of SEA 148
INDIANAPOLIS – Prosperity Indiana thanks Governor Holcomb for listening to our call to ensure housing stability remains a long-term priority in the Hoosier state with his veto of SEA 148. During this time, when the state’s economic and housing future faces uncertainty in the length and severity of the COVID-19 pandemic, Hoosier renters will not have to additionally worry about the “dangerous, unvetted language” in this legislation or the prospect of new forms of eviction and retaliation that the act could have brought.
Prosperity Indiana Executive Director Jessica Love said, “We applaud Governor Holcomb for his leadership in stopping this sweeping legislation, during what became an unusually difficult season for our state. We anticipate and look forward to working with impacted parties – those in support of and opposing SEA 148 – next session. By then, we should have a better grasp on what housing stability looks like for the foreseeable future for Hoosiers in the aftermath of COVID-19. After we survive this pandemic, I think we’ll all have a greater appreciation for safe and stable housing.”
Before its veto, SEA 148 would have expanded the remedy for emergency possession to include cases where the tenant is not at fault and limited tenants’ protections from retaliation by landlords, among other measures. And while the Governor’s executive order temporarily pauses evictions and foreclosures during the state of emergency, once lifted, SEA 148 would have exposed the more than two million Hoosiers who rent – over 30 percent of the state’s population – to weakened protections from bad-actor landlords. In addition, it would have nullified positive protections from cities and local governments.
By vetoing SEA 148, Governor Holcomb prevents this bill from undermining his administration’s efforts to date to address the social determinants of health, which specifically includes stable housing. The bill also would have undercut the results of existing state efforts to increase access to recovery housing and workforce housing, as well as IHCDA programs, including the Housing First model and Permanent Supportive Housing Institute and the Landlord Mitigation Reserve Program and Reserve Fund.
Now freed from the exacerbated threat of SEA 148, Indiana can commit state resources and work with statewide partners to help estimate the number of Hoosiers who will be have their housing impacted by the COVID-19 crisis, measure the shortfall of resources and services they face, and begin to work with community-based organizations and service providers on mitigation efforts.
Love said, “In addition to showing our appreciation to the Governor, we thank the hundreds of Prosperity Indiana members and other statewide organizations and individuals who called and wrote to voice their opposition to this legislation. While their voices were shut out of the democratic process for this bill, their advocacy and calls upon the Governor helped him grasp just how many Hoosiers were counting on his leadership on this issue at this critical moment. Prosperity Indiana and our members stand ready to assist the state in addressing the needs of the more than two million Hoosier renters, as this public health crisis continues to unfold.”