By: Avery Holzworth, Policy and Advocacy Intern
On October 13th, the Partnership submitted public comment on proposed federal changes to the Community Reinvestment Act (CRA), the American Community Survey (ACS), and the Department of Housing and Urban Development (HUD) Notice of Research related to Continuum of Care (CoC) homelessness prevention activities. These proposed federal policy changes would threaten the integrity of statewide housing data, disincentivize financial institutions from investing in housing, and divert key resources away from supportive housing systems. Together, they would limit housing stakeholders’ capacity to analyze and respond to the state’s housing needs, while negatively impacting housing creation and stability across Connecticut.
Below are summaries of the Partnership’s submitted comments to federal stakeholders, highlighting the proposed changes and potential impacts on housing policy in Connecticut.
New Community Reinvestment Act (CRA) Rules Could Threaten Housing Investment in Connecticut
The Community Reinvestment Act (CRA) was enacted in 1977 to address historic disinvestment in low- and moderate-income (LMI) communities.[1] The act requires financial institutions to lend, invest, and provide services to LMI residents and their communities. For this reason, the CRA has been instrumental in supporting the Partnership’s mission by providing capital to underserved communities. Under the existing CRA, financial institutions are categorized as small, intermediate, or large banks, based on total assets. These categorizations determine requirements for issuing community development loans and investing in underserved communities under the CRA. Proposed changes to the CRA significantly reduce obligations for Connecticut banks and limit investment in housing creation and preservation.
The CRA has played an integral role in procuring investment in housing development across the nation and in the state of Connecticut. In fact, every year the majority (80%) of equity investments in Low Income Housing Tax Credit developments come from banks with CRA requirements.[2] The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have proposed changing asset classifications that determine community lending requirements under the CRA. The current proposal would reclassify banks between $1.649 billion and $10 billion as intermediate banks, rather than large banks. Under these proposed changes, more than 1,500 banks (36% of all banks nationwide) would lose their incentive to invest in housing development and remediation.[3] This is of particular salience in Connecticut where the housing credit is responsible for a funding a majority of new affordable development.
The Partnership expressed strong opposition to proposed changes to the CRA given the threat they pose to housing investment in Connecticut. In particular, we are concerned that without incentives to do so, financial institutions will no longer provide support for increasing housing supply and affordability in low-moderate income communities, withdraw from providing operating support to non-profits, and reduce critical reporting that allows for the government and advocates to understand how investment is impacting communities. These proposed changes are contrary to the spirit of the CRA to encourage equitable community investment in historically underserved communities. Read more about these proposed changes here.
American Community Survey (ACS) Changes Would Worsen Statewide Housing Data
At the Partnership, we heavily rely on Census Bureau data, including the American Community Survey (ACS) estimates and decennial census data, to identify community needs and make effective policy recommendations. Access to reliable demographic and housing data is critical for the Partnership and other equity-based organizations to understand community challenges and needs. The proposed changes to census data collection could threaten the integrity of this data and prevent the efficient allocation of funds from the Department of Housing and Urban Development (HUD).[4]
The Partnership is particularly concerned by the proposed change to the definition of an individual’s “usual residence,” which may create reporting challenges for people with nontraditional or unstable housing situations. The proposed changes to demographic questions would limit the Partnership’s ability to reliably identify disparities in housing access and affordability. By removing questions related to race, ethnicity, and citizenship, the census data will no longer provide insight into how housing conditions and experiences have changed among different groups over time. It is critical in many policy areas beyond housing, such as public health and transportation, to have access to reliable data on community trends. Previous tests conducted by the Census Bureau demonstrated that the inclusion of citizenship-related questions may limit self-response due to fears of deportation, further undermining the accuracy of census data.[5]
Unreliable census data impacts nonprofits and public agencies across all disciplines. The Partnership is concerned that in addition to threatening the integrity of demographic data and limiting data availability, the acceptance of the proposed changes may set a precedent for further changes to the census. Read more about proposed changes to the Census here.
Proposed HUD Continuum of Care (CoC) Changes Would Weaken Connecticut’s Response to Homelessness
The Partnership also submitted a response to HUD’s Notice of Research to express concerns about proposed changes to eligible Continuum of Care (CoC) services which respond to and prevent homelessness. The HUD proposal would reallocate resources from permanent supportive housing and rapid rehousing programs towards transitional housing and supportive-services only approaches. Permanent supportive housing provides housing stability coupled with services, such as healthcare and mental health support, that meet individuals’ needs. In 2022, Connecticut’s supportive housing programs reached 5,642 households that included more than 1,000 (19%) children and 2,800 (nearly 50%) adults over 55.[6] Proposed changes to divert resources away from these programs would negatively impact vulnerable Connecticut residents who rely on them for both housing and additional services.
The proposed changes to CoC activities contradict policy research and will limit the effectiveness of homelessness prevention and response programs. Research finds that Housing First programs are highly successful because they combine supportive services with supportive housing. An NIH-published 2021 systematic review of twenty-six different homelessness response programs concluded that “Housing First” programs outperformed “Treatment First” programs.[7]
The Partnership’s response to HUD’s Notice of Research explains how reduced federal support for permanent supportive housing and rapid rehousing will negatively impact Connecticut’s ability to maintain essential services and address homelessness. Supportive housing facilities in Connecticut primarily serve children, the elderly, disabled individuals, and women-headed households and have high occupancy rates, demonstrating a strong demand for services. Although transitional housing and supportive services play an important role in homelessness prevention and reduction, they should play a complementary role to supportive housing programs. For more information on the importance of supportive housing services in Connecticut, check out our recent publication, Homes that Heal: The State of Supportive Housing in Connecticut.
Key Takeaways
The proposed federal policy changes outlined above would undermine housing data, investment, and outcomes for households across Connecticut. The Community Reinvestment Act (CRA) has helped make financial institutions key partners in addressing the state’s housing shortage by incentivizing investment in housing creation and preservation. By reducing reporting requirements and changing bank classifications, the proposal jeopardizes a major source of housing capital. Additionally, the proposed changes to the American Community Survey (ACS) and eligible Continuum of Care (CoC) activities would compromise the reliability of housing data and divert resources from the state’s supportive services network. Collectively, these changes would weaken Connecticut’s ability to make data-informed decisions, direct resources effectively, and meet the housing needs of its most vulnerable residents.
[1] Federal Deposit Insurance Corporation, “Community Reinvestment Act (CRA),” FDIC Banker Resource Center, last updated January 29, 2024, https://www.fdic.gov/banker-resource-center/community-reinvestment-act-cra.
[2] CohnReznick, 2025 Affordable Housing Credit Study Report, accessed October 28, 2026, https://creditstudy.cohnreznick.com/credit-study.
[3] National Association of Affordable Housing Lenders, “NAAHL Cautions Against Changes to CRA That Would Reduce Affordable Housing and Community Development Outcomes,” August 3, 2026, https://naahl.org/news/naahl-statement-on-proposed-cra-rule.
[4] Andrew Reamer, Counting for Dollars 2020: The Role of the Decennial Census in the Geographic Distribution of Federal Funds (Washington, DC: George Washington Institute of Public Policy, April 29, 2020), https://gwipp.gwu.edu/counting-dollars-2020-role-decennial-census-geographic-distribution-federal-funds.
[5] U.S. Census Bureau, 2019 Census Test Report (Washington, DC: U.S. Department of Commerce, January 3, 2020), https://www.census.gov/programs-surveys/decennial-census/decade/2020/planning-management/plan/testing-activities/2019-census-test/2019-census-test-report.html.
[6] CT CAN Data, “Supportive Housing [Legacy Dashboard],” accessed October 28, 2026, Supportive Housing [LEGACY DASHBOARD] – CT CAN Data.
[7] Peng, Y., Hahn, R., Finne, R., et. al. “Permanent Supportive Housing With Housing First to Reduce Homelessness and Promote Health among Homeless Populations with Disability: A Community Guide Systematic Review.” Journal of Public Health Management Practice. 2020 Sep-Oct; 26(5):404–411. doi: 10.1097/PHH.0000000000001219