This paper addresses a crucial, pressing question in affordable housing finance: how to determine whether BABA applies to a specific project when federal funds were originally awarded at one time, committed to a project later, or recycled as program income after repayment. It focuses principally on HUD CPD programs, especially HOME, and distinguishes clearly between federal obligation, local project commitment, and program income.
Modernizing Davis-Bacon Residential Construction Classifications: Why the Four-Story Rule Should Be Reexamined
Today’s affordable housing landscape looks very different than it did when the Davis-Bacon residential construction classification was