The Spring Street Brief

NH&RA has launched a new project impact collection form to document real-world BABA (Build America, Buy America Act) compliance challenges affecting HUD-assisted affordable housing deals. The effort is part of active advocacy meetings with HUD and the Made In America Office (MIAO) within OMB, targeting faster waiver processing and broader compliance relief for the LIHTC and affordable housing development community. Key Takeaways: NH&RA is actively meeting with HUD and the Made In America Office (MIAO) within OMB to accelerate BABA waiver processing.

Show Notes

NH&RA has launched a new project impact collection form to document real-world BABA (Build America, Buy America Act) compliance challenges affecting HUD-assisted affordable housing deals. The effort is part of active advocacy meetings with HUD and the Made In America Office (MIAO) within OMB, targeting faster waiver processing and broader compliance relief for the LIHTC and affordable housing development community.

Key Takeaways:

  • NH&RA is actively meeting with HUD and the Made In America Office (MIAO) within OMB to accelerate BABA waiver processing.
  • BABA requirements apply to projects using federal assistance, directly impacting deals that layer LIHTC equity with FHA loans, HOME funds, or CDBG dollars.
  • The new NH&RA form is designed to build a project-specific evidence database to support advocacy with both Congress and the Administration.
  • Slow waiver processing has been cited as a primary source of deal friction — cost increases, procurement delays, and project restructurings are documented outcomes.
  • Submissions from developers, syndicators, lenders, and HFAs are all being solicited — the database's strength depends on volume and specificity of responses.
  • The advocacy window with the current Administration is active — timely submissions directly strengthen the negotiating position for systemic relief.

BABA compliance has become one of the most operationally disruptive federal requirements for HUD-assisted affordable housing deals. NH&RA's database-building effort is a direct response — turning scattered project-level pain points into a structured policy argument. If your organization has navigated a BABA waiver, absorbed a material cost premium, or restructured a deal around compliance requirements, submitting that experience to NH&RA now is the highest-leverage action you can take. Visit NH&RA's website to access the form directly.

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