NAA's 2025 Federal Advocacy Outlook

Not only did 2024 continue the previous year’s trend of increased attention on housing affordability from federal, state and local policymakers, it surpassed it. Housing issues, specifically the need for greater supply, even occupies significant space on the radar of the two presidential candidates. While a first in presidential politics, it is not surprising given public opinion polling, which shows large majorities of voters with significant concerns about the cost of housing.   

The National Apartment Association (NAA) engaged in these debates from the beginning and as the 118th Congress wraps up, there is much to celebrate. What follows is an update on our efforts in Congress and the Administration. Read more about NAA’s policy priorities at naahq.org/policy-issues.

NAA’s Congressional Advocacy  

Building on our success in 2023, NAA successfully built bipartisan, bicameral support for sustainable policy solutions that address the historic undersupply of housing and that protect the nation’s rental housing infrastructure for future generations of renters. All three of our proactive pieces of legislation are bicameral and bipartisan, a significant accomplishment in a noisy political environment.  

• The Respect State Housing Laws Act clarifies that the federal CARES Act preeviction notice requirement ended when the CARES Act eviction moratorium expired in 2020. We must eliminate any ambiguity that allows this point to remain a contested issue in courts today. This bill passed successfully out of the House Financial Services Committee and was included, at NAA’s urging, in the House-passed HUD appropriations bill.  
• The YIMBY Act, reintroduced in both the House and Senate, would incentivize local communities to remove barriers to apartment development. The legislation passed unanimously and on a bipartisan basis out of the House Financial Services Committee and has the support of both parties’ leadership for a floor vote in the House prior to the end of the year.  
• The Choice in Affordable Housing Act, also reintroduced in both chambers of Congress, would enact needed common-sense reforms to the Section 8 Housing Choice Voucher (HCV) program. This legislation has slowly built strong support in the Senate and remains well positioned for inclusion in a broader housing package.  

Finally, NAA worked with Congressional offices to raise important federal regulatory issues, including Biden Administration priorities from the Federal Housing Finance Agency (FHFA), Department of Housing and Urban Development (HUD) and United States Postal Service (USPS).

NAA’s Federal Regulatory Advocacy  

In 2024, Biden Administration activities touched all aspects of owning, managing and developing rental housing nationally. NAA was ready at every turn to respond to relevant federal regulatory activity and proactively insert the industry’s perspective in national policy conversations.   

• Filing Beneficial Ownership Information – The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) previously announced new “beneficial ownership information” reporting requirements. This requires business owners to disclose information about individuals who directly or indirectly own or maintain substantial control over a reporting company, or an individual that directly or indirectly owns more than 25% of the ownership interests of the reporting company. These new filing requirements are expected to have a significant impact on independent rental owners. Learn more by searching “BOI” at naahq.org.  
• Landlord-Tenant Requirements for Fannie/Freddie Properties – FHFA continues to engage with stakeholders as the agency considers federalizing landlord-tenant requirements for Enterprise-backed multifamily housing i.e., properties backed by Fannie Mae and Freddie Mac (the Enterprises). FHFA and the Enterprises already announced that a 30-day notice of rent increase, 30-day notice of lease expiration and a five-day grace period from late fees will be required for new loan applications beginning in February 2025. While this measured approach was welcome news, the Agency continues to evaluate whether to adopt more onerous requirements, such as rent control, just cause eviction limitations that effectively eliminate housing providers’ right to nonrenewal and mandating “source of income” like those intended to require housing providers to accept Section 8 Housing Choice Vouchers. NAA looks forward to continuing the conversation with regulators to elevate the industry’s perspective on these issues.  
• Enhanced Standards to Address Lead Paint Hazards – The Environmental Protection Agency (EPA) has issued its final rule dramatically altering how dust hazards from lead-based paint are defined and remediated in covered rental housing. The final rule reduces the level of lead dust considered hazardous to “any reportable level as analyzed by any laboratory recognized by EPA’s National Lead Laboratory Accreditation Program” and substantially reduces the threshold for clearance post-abatement, increasing operational uncertainty for housing providers and confusion among renters and their families about potential lead hazards in their homes. NAA worked closely with the National Multifamily Housing Council and its coalition partners in our advocacy efforts to uplift the industry’s concerns with the manner in which the EPA proposed to achieve further reduction of lead dust levels and the associated unintended health impacts on renters and their families.  
• Mail Delivery Impacted at Rental Communities – NAA continues its work on the student housing reclassification issue that resulted in leasing staff being required to deliver mail to residents. Now a new issue is on the horizon. As a continuation of Project Safe Delivery, USPS announced replacement of physical keys to electronic systems to reduce safety risks to letter carriers and their liability for fraud. NAA is elevating industry concerns about implementation delays of replacement keys that have led to negative repercussions, similar to the student housing issue.  
• NSPIRE Inspections – HUD extended the compliance deadline for assisted housing providers that are now subject to NSPIRE inspections, moving the deadline for housing benefiting from the Section 8 Housing Choice Voucher program from Oct. 1, 2024, to Oct. 1, 2025. Much like the widely attended education session at the 2024 Apartmentalize conference, NAA will continue to work with HUD and industry leaders on both in-person and virtual opportunities to help members understand their new compliance responsibilities.   

This year, NAA’s Executive Committee (pictured above) and volunteer leaders met with federal regulators and reinforced the industry’s perspective on important regulatory issues related to the Section 8 Housing Choice Voucher program, borrower responsibilities for Enterprise-backed housing and insurance.

What We’re Monitoring  

NAA continues to monitor several developments in the policy space as we enter 2025, including:  

• President Biden’s federal rent control proposal   
• The Federal Trade Commission’s so-called “Junk Fees” Rule 
• The Federal Communication Commission’s proposal to ban broadband bulk billing   
• HUD’s criminal screening rule for assisted housing   
• The Occupational Safety and Health Administration’s proposed national heat safety standards for employers  

Beyond these actions, tax reform will be the cornerstone focus on Capitol Hill in 2025. As always, NAA will continue its federal advocacy efforts to ensure the industry’s voice is heard and represented in these federal policy debates and utilize every opportunity to protect the industry from bad federal policy.

Amplifying Your Voice

As always, your participation in all of these efforts has never been more important than it is today. There are many options for how you can contribute. To learn more, contact Seth Turner, Senior Manager of Grassroots Advocacy & Stakeholder Engagement, at sturner@naahq.org.  

Greg Brown is SVP, Government Affairs, and Nicole Upano is AVP, Housing Policy and Regulatory Affairs, for NAA.