Determining When Build America, Buy America (BABA) Applies to a HUD Housing Project

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.