Recently, the federal 21st Century ROAD to Housing Act officially became law. The legislation offers many ideas and solutions to bring down housing costs, but buried in it is something particularly novel: the Whole Home Repair Act (Section 202). This provision creates a pilot loan program specifically targeting small-building owners who provide naturally occurring affordable housing, known as NOAH — meaning, homes that are affordable without government subsidy.
While the provision is small and has shortcomings, it still feels like a debutante ball for small-rental-building owners, a universe that is generally overlooked by the federal government. Created for owners with fewer than 10 properties, the loans would fund critical upgrades and common-area repairs that would keep these buildings in good condition for renters. Also encouraging: Community Development Financial Institutions like mine are named as eligible administrators of the program.
The downside, however, is the provision that it is an unfunded pilot that sunsets in 2031, giving little time to demonstrate meaningful impact. And the way it achieves affordability, including through rent increase caps and three-year tenant protections, may cause the very landlords it was designed to help to opt out.
As it considers the success of this pilot program, Congress should take note of an Illinois policy that has helped preserve and expand affordability statewide. Five years ago, on July 29, 2021, Gov. JB Pritzker signed the Illinois Affordable Housing Omnibus (HB2621). Enacted in Cook County as the Affordable Housing Special Assessment Program (AHSAP), the legislation created a tax incentive program to both preserve existing homes and add new affordable ones.
It works by lowering the assessed value of a property if that property includes a required proportion of affordable units and has undergone a required amount of rehab, resulting in lower property taxes for owners. Keep at least 15% of units affordable, and that’s a 25% assessment reduction; keep at least 35% affordable, and that’s a 35% decrease. Those breaks are backed with up to a 30-year commitment. New developments in the least affordable communities can also qualify for a separate tax relief tier.
Take one of our borrowers, Carolyn Sood, who owns and operates 250 apartment units across four buildings in South Shore and Hyde Park. Since she and her husband first started their business in 2007, rising insurance and maintenance costs have put pressure on their bottom line. This pressure pushes many small landlords to raise rents, but the county program gave Sood a way to absorb those costs without passing them on to tenants. In South Shore, where she was already charging affordable rents, the program simply recognized what she was doing. In Hyde Park, it gave her the financial cushion to keep 20% of her units below market rate.
Since the program formally launched
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in tax year 2022, 1,195 projects across Cook County have joined the county program — representing 2,454 individual properties. Behind these numbers are thousands of homes preserved or made newly affordable for the families who need them most. One of the reasons the program has been successful is that it offers long-term certainty and isn’t burdensome to smaller owners without a back office. Property owners who qualify commit to 10-year terms with renewal options stretching up to 30 years — giving small landlords the stable, predictable relief they need to plan ahead and maintain their buildings.While federal policy typically focuses on new construction or subsidized housing, NOAH owners are the backbone of our affordable housing ecosystem, accounting for 75% of affordable homes nationwide. Preserving an affordable home costs a fraction of building a new one. NOAH owners are already doing the hard work of keeping that housing in good condition, often in communities that need it most.
Illinois proved five years ago that smart, low-barrier government support can make that work sustainable. Washington should build on the ideas of the Whole Home Repair Act with the long-term funding and commitment to match. Because if small-building owners can’t make the numbers work to keep rents affordable, no amount of new construction will fill the gap they leave behind.
Maggie Cassidy is director of The Preservation Compact, a policy collaborative housed at Community Investment Corp.
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