Prosperity Indiana submitted comments regarding the Federal Reserve Board’s (Fed) Advance Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA). We believe the Fed’s approach is a good first step to improve upon the current CRA exam, in contrast to the Office of Comptroller’s final rule. However, we join our state and national partners in calling for more rigor in performance measures in order to ensure that CRA ratings will not be as inflated as they are today. More rigor is key to ensuring that CRA exams leverage more lending, investing and services for communities of color and low- and moderate-income (LMI) 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.

Increased intentionality around meeting the purposes of CRA is critical, in light of the disproportionate impact COVID-19 has had on people on color and LMI households and those that serve them. Prosperity Indiana offers these comments as the cross-sector intermediary for organizations dedicated to community economic development, which means our members are the people and organizations on the front lines fighting COVID-19. Our members and the populations and communities they serve statewide have borne the brunt of the pandemic, resulting in stresses on capacity and finances. Three-quarters of our members report having six months or less cash reserve on hand; and the great majority have been forced to cancel programs or events and experienced disrupted services, even while seeing an increased demand for services and assistance. In May 2020, 82% anticipated a future decrease in revenue, and 94% anticipated a moderate to high impact on their programs, services, and general operation.

And while many of our nearly 200 members are deeply engaged in the community economic development work affected by the CRA and the proposed changes in the ANPR, few have the capacity during the ongoing emergency of COVID-19 to respond to the 99 questions involved. In order for our members to continue to respond, recover, and rebuild from COVID-19, they need a robust CRA that does not hinder services to communities of color and low- and moderate-income communities.

What’s at stake in Indiana?

Every community has a stake in strengthening the CRA, from Indiana’s small towns to growing suburban areas to the core urban areas. This is true from Angola, which saw $130.3 million in mortgages or loans to LMI borrowers or neighborhoods from 2009 through 2018, $0 in business loans to LMI neighborhoods, and $97.2 million in loans to small businesses, to Warsaw with $277 million in mortgages to LMI borrowers or neighborhoods, $36.1 million in business loans to LMI neighborhoods, and $271.4 million in loans to small businesses. And in our state’s largest metro area of Indianapolis-Carmel-Anderson, which itself spans a large city, a wealthy suburb, and a former industrial center now facing challenges, mortgages to LMI borrowers or neighborhoods totaled $14.2 billion from 2009 through 2018, with $3.9 billion in business loans to LMI neighborhoods, and nearly $4 billion in loans to small business. Indiana’s communities from smallest to largest can’t risk a weakening of the CRA that would allow an increase in discrimination in lending.

Strengthening CRA is a critical component of a just recovery

Indiana communities who have been hardest-hit and are still battling the public health, economic, and housing impacts of COVID-19 are the same who carry the scars of redlining. The National Community Reinvestment Coalition (NCRC) recently released a major report finding significant correlations between redlining and susceptibility to COVID, including Evansville, Fort Wayne, Indianapolis, Gary and Lake County, Muncie, South Bend, and Terre Haute. In the 1930s, the Home Owners Loan Corporation (HOLC) commissioned the production of maps that rated neighborhoods based on the risk of lending in them. Working class and minority neighborhoods usually received the riskiest designation of hazardous. The designations subsequently facilitated redlining and discrimination against these neighborhoods, which remain starved of credit and are predominantly lower-income and minority. These neighborhoods also have the highest incidence of health conditions such as asthma, diabetes, kidney disease and stroke, which make residents more susceptible to COVID-19. Life expectancy is almost four years lower in the redlined communities than the neighborhoods not designated as hazardous by HOLC.

In Indiana, the pandemic has disproportionately affected communities of color in additional ways. For example, according to the Federal Reserve Bank of Atlanta’s Unemployment Claims Monitor, Black Hoosiers have filed one in five unemployment insurance claims throughout the pandemic, although they make up only 9.4% of the labor force, according to 2019 data.

While we have not seen state-level data about Indiana’s Black-owned businesses, reports from the experiences of our members throughout the state align with nationwide trends showing a disproportionate impact on these businesses. Since the start of the pandemic, more than 440,000 African American businesses (41%) have been closed nationwide, compared to just 17% of White-owned small businesses. Discrimination in lending contributes significantly to racial disparities in small business survival rates. An NCRC investigation found that African American testers applying for Paycheck Protection Program (PPP) loans for their small businesses during the pandemic were likely to receive less information or encouragement to apply than White testers. We do not need state-level data to confirm the impact, and we cannot afford to see the CRA watered down in the meantime. CRA must be strengthened considerably in order to combat discrimination and help our communities recover from the pandemic.

Read Prosperity Indiana's full comments to the Fed's ANPR on the CRA.

By Laura Berry and Andrew Bradley

On October 13, Indiana reopened its Rental Assistance Portal for the first time since closing on August 26. While the Hoosier Housing Needs Coalition applauds this needed step, the restrictions now attached to the portal funds will likely mean that very few of the nearly quarter million Hoosier households at threat of eviction will be helped. The Coalition renews its calls for Governor Holcomb to create a coordinated COVID-19 Housing Stability Policy Plan and leverage some of over $1 billion in CARES Act funds still sitting on the table to ensure no Hoosier is evicted or made homeless due to the pandemic.

Read the entire blog post here.

Prosperity Indiana has submitted comments to the Indiana Housing & Community Development Authority on proposed use of Emergency Solutions Grant (ESG) Round 2 from the CARES Act. The letter states "[i]n large part, our comments today do not object to the proposed new activities in the amendment, but instead demonstrate our concern about the continuing missed opportunities of the State of Indiana not providing a coordinated COVID-19 housing stability policy response that aligns ESG-CV alongside current and newly-available CARES Act funds."

The comment period coincides with an announcement from the U.S. Department of Housing and Urban Development of new allocations totaling over $27.3M in Community Development Block Grant (CDBG) funds to Indiana and its cities with explicit guidance that "funds can be used to provide temporary financial assistance to meet rental obligations for up to 6 months".

The comments state: "[f]or the proposed ESG plan to make a meaningful impact on the scope of Indiana’s housing stability crisis, the state must act quickly to incorporate both the ESG-CV2 and CDBG-CV3, as well as other remaining CARES Act funds to re-open the Rental Assistance Program well before the end of the CDC’s moratorium."

The comments reiterate calls on the state to provide a coordinated COVID-19 Housing Stability policy response, with a Task Force comprised of landlords, tenants, and experts in the connections between public health and housing; as well as a dashboard on the state's COVID-19 website with data on evictions and outcomes of rental assistance programs.

Read Prosperity Indiana's full comments here.

Dear Hoosier Housing Needs Coalition partners and friends,

We’re happy to write today with information about the new federal CDC eviction moratorium, and to provide an updated flyer from our partners at Prosperity Indiana.

From the National Low Income Housing Coalition:

A federal eviction moratorium issued by the Centers for Disease Control (CDC) takes effect today, September 4, extending vital protections to tens of millions of renters at risk of eviction for nonpayment of rent during the global pandemic.

To be protected, qualified renters facing eviction should immediately provide a signed declaration to their landlords. For more details about the moratorium and a sample declaration that renters can use, read NLIHC’s and NHLP’s Overview of National Eviction Moratorium and our National Eviction Moratorium: FAQ for Renters.

From Prosperity Indiana:

Please share this updated Federal Eviction Moratorium flyer that outlines qualifications and procedures, and provides links to additional resources for renters.

See also Indiana Legal Services, Inc.'s COVID-19: New Federal Eviction Moratorium page

From the Hoosier Housing Needs Coalition:

The new CDC moratorium is an important step for up to 313,000 Hoosier households at risk of eviction and homelessness due to the pandemic, but more needs to be done. Because the moratorium provides no additional rent assistance, it’s critical that Indiana’s Senators Todd Young and Mike Braun champion $100B in rent assistance and homelessness prevention resources in the next coronavirus relief bill to meet Hoosiers’ needs.

The CDC has clearly established that housing is public health, and Indiana’s policymakers must recognize that housing stability needs to be a top priority in 2021. The new moratorium does not eliminate Indiana’s housing stability crisis, but simply delays the waves of evictions that will resume after December 31. To avoid unleashing a built-up tsunami of evictions in the dead of winter, Indiana’s policymakers must act during this moratorium, and should start by considering HHNC’s recommendations for a Housing Stability Policy Plan, including:

• Re-open Indiana’s Rental Assistance Portal with funds and outreach targeted towards the hardest-hit Hoosiers, including low-income renters and Black and brown communities.
• Include a Housing Stability Dashboard on the state’s COVID-19 website to track eviction filings and rent assistance outcomes.
• Governor Holcomb should appoint a Housing Stability Task Force that includes representatives from housing providers, tenants, legal aid, state agencies, and experts in the intersections between public health and housing to advise equitable funding and policy decisions.

Take Action: tell Indiana’s policymakers and Senators to prioritize housing stability now!

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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.

On September 3, Prosperity Indiana submitted comments on behalf of our network opposing the federal Office of the Comptroller of the Currency’s proposal “National Banks and Federal Savings Associations as Lenders” or "Rent-a-Bank Rule", and offering recommendations to instead strengthen our communities.

In our letter, Prosperity Indiana made the following arguments opposing the 'Rent-a-Bank Rule':

• This rule would allow predatory lenders to evade state imposed rate caps by laundering loans through banks, enabling them to charge triple-digit interest rates even when states have already capped interest at much lower levels.
  
• The “Rent-a-Bank” rule would directly harm Hoosiers hardest hit by the COVID-19 pandemic and economic depression, including the 37.9% of Hoosiers without emergency savings.
• During our recently-completed Regional Members, our membership of experienced community economic development professionals consistently emphasized their federal policy priority to take action against unfair lending practices, of which Rent-a-Banks are a prime example, and instead promote a fairer financial market.

As an alternative to this damaging rule, Prosperity Indiana urges the OCC to promote alternatives to predatory lending that help lenders build assets and financial stability to keep wealth growing in our communities, including Community Loan Centers.

Read Prosperity Indiana's Comments on National Banks and Federal Savings Associations as Lenders Docket ID: OCC-2020-0026 RIN 1557-AE97.

INDIANAPOLIS – The Hoosier Housing Needs Coalition is urging Indiana Governor Eric Holcomb to ensure a waitlist and additional resources are made available before closing the state’s COVID-19 Rental Assistance Program Wednesday. More than 200,000 additional Hoosiers are expected to need pandemic-related rental assistance than will be provided through resources that are currently available through state and local government programs. The Coalition also calls on Indiana’s state and federal policymakers to come together to take critical steps to provide protections for renters to prevent the flood of evictions – that started with the end of the state’s moratorium August 14 – from deluging the state.

The Coalition issued an action alert stating concern that closing the rental assistance portal without a waiting list would leave renters in the dark with no way to document their request for assistance if an eviction case is filed against them. It also leaves the state no queue of assistance requests in the case that the program receives additional funds.

“The problem of evictions and housing instability isn’t going to disappear with the premature closure of the state’s rental assistance portal – quite the opposite will occur,” said Jessica Love, Executive Director of Prosperity Indiana. “A waiting list is the least the State of Indiana can do to demonstrate that it hasn’t turned its back on hundreds of thousands of Hoosiers who will continue to need emergency rental assistance as the impacts of the COVID-19 economic downturn continue to ramp up. A waiting list application confirmation could at least show due diligence for the renter attempting to work with their landlord but with limited resources to pay.”

As an example, the Coalition points to the waiting list used by the City of Indianapolis at IndyRent.org (the city’s rental assistance program portal), which will allow the city to contact tenants in the order they appear and invite them to apply once new funds become available. The state could use a similar waiting list to reactivate the state portal as funds are made available from over $1B currently available in CARES Act resources, or from any future coronavirus related funds passed by Congress.

“Working with the City of Indianapolis, I’m optimistic that they have found ways to work with partners on the ground to help make sure the Black and brown residents most impacted by COVID-19 receive rental assistance,” said Derris Ross, CEO/Founder of The Ross Foundation and the Indianapolis Tenants Rights Union. “Indiana needs a more tactical and intentional statewide plan to ensure an equitable housing recovery that reaches all Hoosiers no matter the color of their skin or their ZIP code.”

The Coalition sees the move to close the state’s rental assistance program without a waiting list as inconsistent with the facts on the ground of more than 30,000 applications to the program during its six-week run, compared to the approximately 25,000 households the program will serve (at $2,000 per household) through the $40 million in Coronavirus Relief Funds appropriated by the state. In sharper contrast, estimates indicate that up to 313,000 Hoosier households are at risk of eviction before the end of the year, part of multiple waves of evictions anticipated to last into 2021.

The Coalition reiterates its call for a coordinated statewide Housing Stability policy response to COVID-19, including a Governor-appointed Task Force representing the needs of landlords, tenants, and experts in housing and public health, as well as a Housing Security Dashboard on the state’s coronavirus web site to track eviction data and rent assistance outcomes. The Coalition has also called for a state Court Order to uniformly implement recommendations from the Supreme Court’s Landlord-Tenant taskforce. The Coalition also continues to call on Indiana’s Senators to follow the lead of the House in passing $100B in emergency rental assistance that would meet the estimated need in Indiana and nationwide.

“While the Senate hasn’t yet come through with the resources Indiana needs to serve all COVID-19 impacted renter households, that’s no excuse for the state to shut down its rental assistance program,” said Jessica Fraser, Director of the Indiana Institute for Working Families. “We’ve noticed that Indiana’s Senators have yet to stand up as champions for Hoosiers’ housing stability in negotiations for the next coronavirus package, and we see the impact that’s having here at home. Hopefully the state won’t give up on Hoosier renters before the Senate finishes the job in front of them.”

The Coalition asks Hoosiers to contact their policymakers by responding to the “Don't End Indiana's Emergency Rental Assistance Program!” Action Alert located at Prosperity Indiana’s online Advocacy Action Center. Organizations and individuals who wish to join the Hoosier Housing Needs Coalition and receive updates should also email hoosierhousingneeds@prosperityindiana.org.

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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.

FOR IMMEDIATE RELEASE

August 14, 2020

CONTACT:  Andrew Bradley | (317) 222-1221 x403 | abradley@prosperityindiana.org

Coalition Calls for COVID-19 Housing Stability Dashboard, Court Order for Renter Protections as Governor’s Eviction Moratorium Ends

INDIANAPOLIS – With Indiana’s eviction moratorium ending on August 14, the Hoosier Housing Needs Coalition is calling on Governor Holcomb to include a ‘COVID-19 Housing Stability Dashboard’ on the state’s coronavirus response website to track eviction and rental assistance data. The Coalition also urges the Indiana Supreme Court to strengthen protections for renters facing COVID-19 related evictions in court with an order to uniformly enact recommendations of the Court’s Landlord-Tenant Task Force. These recommendations would help inform the state’s housing stability policies, in the absence of an articulated plan, and in the face of new data finding that up to 720,000 Hoosiers are at risk of eviction without additional protections.

The Coalition believes that neither the data nor the facts on the ground support lifting the moratorium at this point. Although the Coalition applauds state and municipal leaders for establishing emergency rental assistance programs, the amounts allocated to date are not enough to cover the current list of applicants, much less the new estimates of up to 313,000 households at risk of eviction in waves that could last through 2021.

And while the Coalition’s recommendations for the Governor to appoint a Housing Stability Task Force to ensure an adequate and equitable policy response has so far gone unheeded, the data from a COVID-19 Housing Stability Dashboard could inform future policy decisions in order to mitigate the risks of future evictions and homelessness. The dashboard should include the following updated weekly:

• number of applications to state and city Rental Assistance Programs by county, including by housing cost-burdened Census tracts, compared with the number of requests for housing assistance to the Indiana 211 network
• average amount requested by household per county
• number of applications accepted and denied per county and per reason why rejected, including ineligibility or lack of landlord participation
• number of evictions filed and completed per county and by cost-burdened Census tract
• balance remaining in the state COVID-19 Rental Assistance Fund

Eviction data for Indiana is notoriously difficult and expensive to obtain, with the most recent publicly-available information from 2016. And because Indiana is largely relying on partners for outreach about the state rental assistance program, it should arm those partners with up-to-date information about eviction filings and outcomes. The COVID-19 Housing Stability Dashboard should also include information directing people to the existing rental assistance programs throughout the state, as well as link to the Supreme Court's website with advisories and appendices for tenants, landlords and attorneys.

In addition, because the eviction moratorium is being lifted before measures on the Coalition’s Housing Stability Yardstick have been met and the state’s mediation program is not yet operational, the Coalition calls on the Indiana Supreme Court to issue a Court Order to ensure uniform application of the recommendations of the Landlord-Tenant Task Force across the state. A Court Order should elevate the Guidelines for Judges from suggestions to standard practices and be strengthened where needed to reduce unnecessary evictions, prevent homelessness, and safeguard public health, including:

• Determine if the leased property is governed by rules applicable to federally-backed mortgages, or any previous or future COVID-19 related relief or moratorium
• Separate court sessions for back rent versus damage hearings, and contested claims and other matters
• Establish a procedure where the first hearing is simply for information with courts advising both landlord and tenant to complete an application to the applicable public rental assistance program before proceeding to a possession hearing.
• Prioritize cases by oldest eviction cases first, i.e. the cases that were already scheduled when the moratorium was issued. Also consider situations where a party may have already resorted to impermissible self-help measures since tensions may be heightened.
• Deprioritize cases where, after the initial information hearing, the landlord and/or tenant have sought to create a payment plan, and/or have applied for assistance after the first hearing but have not been granted that assistance.

In part, because demographic information, including disaggregated data on racial disparities, is difficult to obtain, the state should consider appointing a Housing Stability Task Force to monitor the disproportionate impact of policies and funding decisions on low-income communities and Black and brown Hoosiers across these areas. 

“The Fair Housing Center of Central Indiana (FHCCI) implores our state to take the steps as outlined by the HHNC. The FHCCI fears the upcoming eviction pandemic and the long-term and sustained impact upon our Hoosier households. In our state, the filing of an eviction, justified or not, will follow Hoosiers around in their housing search for years to come, impacting their ability to find safe and affordable housing options. Indiana already received national attention, pre-COVID-19, on its high eviction rates. More must be done to address and counteract this crisis,” said Amy Nelson, Executive Director, Fair Housing Center of Central Indiana.

“Unfortunately, the end of the moratorium in no way signals that the threat of evictions and homelessness is now gone. Just the opposite. Not only will the coming tsunami of coming evictions have a long-term impact on renters, it will also cause lasting devastation on the communities that have been hit hardest by the pandemic job and income losses. This type of double-whammy is no jackpot. And the Hoosiers whose lives we are gambling with - hoping this problem will go away without additional, sweeping financial and legal interventions and accountability measures in place - are depending on our state’s leaders to do more,” said Jessica Love, Executive Director, Prosperity Indiana.

Organizations and individuals who wish to join the Hoosier Housing Needs Coalition and receive updates should email hoosierhousingneeds@prosperityindiana.org.

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.

By Andrew Bradley

The Hoosier Housing Needs Coalition thanks Governor Holcomb for extending Indiana’s eviction moratorium through August 14, and for his willingness to continue extending the pause and adding resources to the Indiana COVID-19 Rental Assistance Program as demand necessitates. The Coalition encourages Hoosiers in need to apply for assistance while resources are available and urges Indiana’s policymakers to make necessary progress towards housing stability before lifting the moratorium.

Governor Eric Holcomb officially extended the moratorium on residential evictions and foreclosures, which had previously been set to expire July 31, through Executive Order 20-39 until August 14, to align the expiration date with the existing moratorium on utility shutoffs. In the renewed order, landlords, tenants, lending institutions, and property owners are “strongly encouraged to work together to establish reasonable payment plans for past due rent or mortgage payments.” During his press briefing Wednesday announcing the extension, the Governor stated his willingness to add funding to Indiana’s $25 million rent assistance program and that it is too early to say whether the moratorium will be extended again.

Hoosier renters who have lost income due to the pandemic are encouraged to apply at IndianaHousingNow.org for non-Marion County residents, or at IndyRent.org for Marion County residents. While both programs have reached their initial estimated capacity, it is important for renters in need to apply to be added to the wait list and to demonstrate the demand for additional funds for these programs to policymakers. In addition, service providers, congregations, and other community-based organizations should make sure their members and clients are aware of this assistance. IHCDA has provided a Communications Toolkit with resources in English and Spanish, as well as Social Media Posts.

Before Governor Holcomb considers lifting the eviction moratorium, the Coalition urges him to ensure the state has met four measures on our Housing Stability Yardstick, including:

1.) Coordinate rent assistance programs to align all available funding streams. This includes stacking state and local funds and incentivizing philanthropic and private participation.

2.) Ensure equitable access to rental assistance program resources. Target outreach to highest cost burden areas and racial communities most impacted by public health, income and job loss, and housing instability.

3.) Appoint an Indiana Housing Security Task Force to advise on funding, outreach, and outcomes with expertise of landlords, impacted renters, public health and housing experts.

4.) Congress should provide adequate support for #RentReliefNow, with Indiana’s Congressional delegation as champions.

Meeting these measures will help ensure that 258,782 Hoosier renter households affected by the pandemic have the help they need to avoid eviction and potential homelessness. However, lifting the moratorium before meeting these measures would put Indiana at risk of regressing in its COVID-19 Back On Track Plan.

Please share this message with your networks. To join the Hoosier Housing Needs Coalition and receive updates, please contact hoosierhousingneeds@prosperityindiana.org.

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.

By Andrew Bradley, Jessica Fraser, and Michaela Wischmeier

With nearly maxed-out rental assistance programs, Indiana is running out of time to prevent a tsunami of evictions starting August 1, even as COVID-19 resurges through the state. Self-inflicted funding limits and a lack of statewide coordination between state and city rent assistance programs have set Indiana further back on the timeline needed to advance to higher stages of housing stability. In response, the Hoosier Housing Needs Coalition (HHNC) proposes a yardstick to measure the steps necessary to ensure COVID-19 housing stability.

On July 13, the State of Indiana and City of Indianapolis opened their COVID-19 emergency rental assistance programs after weeks of planning. In a little over a week, the state program had received 17,491 applications[1] for a program expected to serve 12,000 households, and the city suspended applications after maxing out the projected capacity of 10,000 households in the first 48 hours. Including the households covered by these two programs, the HHNC estimates that no more than 50,000 households are likely to receive some form of rental assistance from the resources available from various government, faith-based and philanthropic organizations across the state at current capacity.

As a result, over 200,000 Hoosier renter households – of the estimated 258,782 who will need rental assistance before September – will remain subject to eviction and potential homelessness, if Governor Holcomb’s eviction pause expires on July 31 as planned. With Indiana’s early attempts at rent assistance nearly maxed out, thousands of Hoosier renters are at risk of spreading disease and experiencing economic calamity from losing their housing.

To prevent evictions that will cause Indiana to regress in its COVID-19 Back On Track Plan, the Hoosier Housing Needs Coalition has developed a ‘yardstick’ to measure four necessary steps for the state to take before Gov. Holcomb should consider lifting the eviction moratorium. The necessary steps include:

1.) Coordinate rent assistance programs to align all available funding streams. This includes stacking state and local funds and incentivizing philanthropic and private participation.
2.) Ensure equitable access to rental assistance program resources. Target outreach to highest cost burden areas and racial communities most impacted by public health, income and job loss, and housing instability.
3.) Appoint an Indiana Housing Security Task Force to advise on funding, outreach, and outcomes with expertise of landlords, impacted renters, public health and housing experts.
4.) Congress should provide adequate support for #RentReliefNow, with Indiana’s Congressional delegation as champions

The ‘yardstick’ is as follows:

1.) Coordinate rent assistance programs. The current Indiana COVID-19 Rental Assistance Program provides up to $500 a month for up to four months, but families receiving rent assistance from another program are not eligible to apply. This design disincentives cities and private or philanthropic partners considering creating rent assistance programs of their own, as well as prevents ‘stacking’ local and state.

The current state program uses $25M in Coronavirus Relief Funds (of $2.4B) and $7.6M in Emergency Solutions Grant funds (of nearly $32M) allocated to the state from the CARES Act. But it leaves over $38M in Community Development Block Grants allocated to the state on the table, using none for rent assistance despite explicit authorization from HUD. funds together to help make families whole on their housing costs to avoid eviction. 

Before the moratorium is lifted: Statewide coordination is needed to align available funding. The state also has not taken HHNC’s recommendations to date to provide coordination of CARES Act resources that could be used for housing stability across the state and local levels. Over a dozen Indiana cities have committed to using CARES Act resources for rent assistance, but the state has created an ‘either/or’ instead of a ‘both/and’ structure. Worse yet, while the U.S. Treasury explicitly allows CRF funds for rent assistance – and both the state and City of Indianapolis used CRF funds to launch their respective rent assistance programs, the state currently does not include rent assistance on the listof reimbursable CRF expenses for local units of government receiving CRF allocations from the state.

2.) Ensure equitable access to rental assistance program resources. Indiana must ensure that the hardest-hit communities and Hoosiers have been given equitable access to available rent assistance, including through targeted outreach. The HHNC has found that rent assistance is Indiana’s top unmet need even during the eviction moratorium, and that low-income renters and Black and Latino Hoosiers have been most impacted by COVID-19 income loss and housing instability. And while the state has relied on others for outreach, and Indy included community partners for its program that lasted three days,  a coordinated statewide program must include metrics to ensure assistance is properly targeted to low-income renters and Hoosiers of color.

Before the moratorium is lifted: Rent assistance must reach the top cost-burdened Hoosiers and where Black and Latino households live.

Across Indiana, 40.4% of white renter households are cost-burdened by housing, meaning they “pay more than 30 percent of their income for housing” and “may have difficulty affording necessities such as food, clothing, transportation, and medical care.”[2] However, 44.5% of Indiana’s Latino households and 51.4% of Black households are cost-burdened.[3] In addition to Marion County, the counties with the highest rates of cost-burdened people of color include Delaware, Vigo, Johnson, Tippecanoe, Brown, Monroe, Allen, Lake, Clark, and Hendricks. For Indiana’s COVID-19 housing stability policy response to be a success, assistance must proportionally reach the most cost-burdened renters and the Black and Latino communities most impacted by the pandemic. 

To assist with targeting outreach for Indiana and Marion County’s rent assistance programs, the Hoosier Housing Needs Coalition has used Census data to identify top housing cost-burdened Census tracts and areas with high proportions of Black and Latino households in the state. A larger database of these Census tracts can be found here. 

While Indiana has housing cost burden across the entire state, Census data shows that the top 20 most cost-burdened communities in the state [excluding Marion County] have over two-thirds of their population allocating more than 30% of their income for rent each month. At 81%, Delaware County has the most cost-burdened census tract in the state. Geographically, these census tracts are spread across all parts of the state and include rural, suburban, and urban areas. 

High proportions of Black households live in cost-burdened census tracts in many Indiana counties, including Lake, Marion, St. Joseph, Delaware, LaPorte, and Allen. In addition, large percentages of Latino households also live in cost-burdened Census tracts in many Indiana counties, including Lake, Noble, St. Joseph, Marion, Clinton, and Elkhart.

Similar to statewide trends, the top 20 cost-burdened census tracts in Marion County all have cost-burden rates of 65% or higher. Marion County has higher rates of racial diversity in its most cost-burdened census tracts, in comparison to the state as a whole. The majority of Marion County’s 20 most cost-burdened tracts have a Black population of 25% or higher, and slightly fewer than half have a Latino population above 10%.

3.) Appoint an Indiana Housing Security Task Force to advise on funding, outreach, and outcomes with expertise of landlords, impacted renters, public health and housing experts. Indiana’s ability to coordinate resources across funding sources could be significantly improved through a task force that includes elected officials, housing advocates, people of color and other Hoosiers most impacted by COVID-19 housing instability. While a COVID-19 task force already exists, the ‘Economic Relief and Recovery Team’ – appointed by the governor to plan, administer and account for federal relief funds the state of Indiana receives from the CARES Act – does not reflect this level of diversity and has not made housing stability a priority.

Before the eviction moratorium is lifted: Indiana should take up the HHNC’s recommendation for Governor Holcomb to create an Indiana Housing Stability Task Force

to represent renters, housing providers and investors, and experts in the connections between housing and public health in the decisions about Indiana’s COVID-19 housing policy response. This task force would help ensure that the hardest-hit communities are served as outlined above. Ideally, a representative of the Housing Stability Task Force would serve on the Economic Relief and Recovery Team on any housing-related decisions from this point forward.

4.)   Congress should provide adequate support for #RentReliefNow, with Indiana’s Congressional delegation as champions. Indiana and Indianapolis have made progress in constructing pipelines for emergency rental assistance. And while each program could be expanded somewhat with existing CARES Act resources, the combined capacity is nowhere near the existing need for over a quarter of a million Hoosier households.

Before the eviction moratorium is lifted: Resources significant enough to provide the rent assistance needed for all ‘severely cost burdened’ (paying over 50% on housing) Hoosier renters to ensure housing stability must be appropriated. Congress must come through with #RentReliefNow, and Indiana’s Congressional delegation should be out front as champions for the hundreds of thousands of Hoosiers relying on them. We urge Indiana’s Senators and Representatives to join HHNC to support $100 billion in emergency rental assistance to help low-income renters avoid evictions and homelessness; a national, uniform moratorium on evictions; $11.5 billion to help local communities address the pressing health and safety needs of people experiencing homelessness; and at least $13 billion in additional funding for HUD and USDA housing programs to ensure housing stability during and after the pandemic, including funds for 100,000 new Housing Choice Vouchers. 

“With such limited resources in Indiana’s rental assistance programs, it is incumbent upon the State and the cities that are running these programs to target their outreach efforts in the most impacted communities,” said Indiana Institute for Working Families Director Jessica Fraser. “Otherwise, these programs run the risk of widening disparity and not solving it.”

Jessica Love, Executive Director of Prosperity Indiana, said, “The last thing Indiana needs is for Hoosier families to be evicted and thrown out on the street or couch-surfing during a resurgent pandemic and exacerbating the surge we’re already seeing in COVID-19 cases. We can no longer afford to delay the policy decision to have a COVID-19 Housing Stability Plan in place.”

Andrew Bradley is Policy Director and Michaela Wischmeier is AmeriCorps Member-Fellow for Prosperity Indiana. Jessica Fraser is Director of the Indiana Institute for Working Families.

[1] Indiana has received 17,491 applications to its COVID-19 Rental Assistance Program as of July 21 according to IHCDA.

[2] Definition of cost burdened renter from https://www.huduser.gov/portal/pdredge/pdr_edge_featd_article_092214.html

[3] Source: authors’ calculations of ACS 1-Year Estimates - Public Use Microdata Sample 2018 https://data.census.gov/mdat

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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.

To afford a modest, two-bedroom apartment at fair market rent in Indiana, full-time workers need to earn $16.32 per hour. This is Indiana’s 2020 Housing Wage, revealed in a national report released today. The report, Out of Reach, was jointly released by Prosperity Indiana, a statewide community development network, and the National Low Income Housing Coalition (NLIHC), a research and advocacy organization dedicated solely to achieving affordable and decent homes for the lowest income people.

Indiana’s 2020 Housing Wage of $16.32 per hour is up from $16.03 in 2019 and is now sixth-highest among the 12 Midwest states, above the regional median of $16.30. The report also finds that the current median renter wage in Indiana of $14.44 per hour is sixth-highest in the Midwest, a penny above the regional median of $14.43. This would indicate that the cost of living in Indiana, compared to Midwestern peers, is not particularly low.

“Data shows that the typical renter income is insufficient to afford rental housing in 80 of Indiana’s 92 counties — and in all 92 for low-income renters — and that’s before the economic and income disruptions caused by COVID-19,” said Jessica Love, Prosperity Indiana’s Executive Director. “This pandemic has certainly highlighted the very harsh reality of living at the edge of housing stability – often just one paycheck away from homelessness – and the impact it can have on the health and well-being of us all. As a result, we must consider the housing affordability issue that so many Hoosier renters experience and begin to proactively address it as a community-level concern.”

This year, the Out of Reach report is released during a time when the coronavirus has clearly illustrated that housing is healthcare. The mandate to “stay at home” was echoed by top officials across the country. However, having a stable place to stay was out of reach for millions of people before the pandemic. Prior to the pandemic, more than 7.7 million extremely low-income renters were spending more than half of their limited incomes on housing costs, sacrificing other necessities to do so. The compounding of high job losses and the lack of access to proper healthcare and resources considerably depleted already limited resources and access. In the past few months alone, millions of households have dealt with a decline in wages through layoffs, furloughs, or decreased work hours and many will struggle to afford their rents. There are no states, metropolitan areas, or ZIP codes in the country where renters can afford a home at Fair Market without spending more than 30% of their income on housing costs. The severe shortage of affordable and available rental homes is still prevalent.

Indiana’s minimum wage has remained at the federal floor of $7.25 an hour without an increase since 2009, not keeping pace with the high cost of rental housing. In no state, even those where the minimum wage has been set above the federal standard, can a minimum wage renter working a 40-hour work week afford a modest two-bedroom rental unit at the average fair market rent. Working at the minimum wage of $7.25 in Indiana, a wage earner must have 1.8 full-time jobs or work 73 hours per week to afford a modest one-bedroom apartment (up from 71 hours in 2019).  To afford a two-bedroom apartment at fair market rent, that Hoosier must have 2.3 full-time jobs or work 90 hours per week (up from 88 hours in 2019).

The typical renter in Indiana pre-COVID-19 earns $14.44, which is $1.88 less than the hourly wage needed to afford a modest unit. The economic downturn spurred by the coronavirus has further increased the risk of housing instability for millions of low-wage renters at a time when stable housing is vital.

“Housing is a basic human need, but millions of people in America can’t afford a safe, stable home,” said Diane Yentel, NLIHC president and CEO. “The harm and trauma of this enduring challenge is laid bare during COVID-19, when millions of people in America risk losing their homes during a pandemic. The lack of affordable homes for the lowest-income people is one of our country’s most urgent and solvable challenges, during and after COVID-19; we lack only the political courage to fund the solutions at the scale necessary. It’s time for Congress to act.”

For additional information, visit: https://reports.nlihc.org/oor/indiana

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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.