Project 2025 Tracker / What’s done, what’s next

Section 3 · The General Welfare

15 Department of Housing and Urban Development

503–516 · Benjamin S. Carson, Sr.

  • 2 done
  • 14 partially done
  • 4 attempted
  • 4 blocked
  • 20 not started
  • 1 already true

Major recommendations (6)

What has happened

The Mandate said

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.”

What happened

Blocked

HUD began the notice and comment the court found missing. Its Notice of Research Justifying Additional Incentives for Certain Activities To Reduce Homelessness proposes, under section 428(d)(2)(C), to incent five activities in future CoC competitions. They are transitional housing with services aimed at employment income and behavioral health; supportive services aimed at employment, healthcare and substance-use and mental-health treatment; "supportive service participation agreements"; drug-free and sober recovery housing; and coordination with law enforcement. It traces the "systematic defunding" of transitional housing since 2013 to Housing First, and says it is published "to reinforce its ability to establish the set-aside". Comments are due 2026-10-13. Rewarding treatment, recovery housing and participation agreements is the "prioritizes mental health and substance abuse issues" half of this Quote, proposed for the program the court just stopped. It is a proposal to cure the procedural defect. The 2026 NOFO remains vacated, so the item stays `blocked`.

The Mandate said

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.”

What happened

Blocked

The FY2026 NOFO was set aside. In State of Washington v. HUD and National Alliance to End Homelessness v. HUD the District of Rhode Island held that HUD's $1.3 billion set-aside for transitional housing and supportive-services-only projects, its "attempt to deemphasize its Housing First approach", was an incentive under 42 U.S.C. 11386b(d)(2)(C). That provision requires public notice and comment, so the court set aside "the 2026 NOFO in its entirety" under 5 U.S.C. 706(2)(D). It refused a permanent injunction, observing that HUD "may attempt to issue yet another NOFO that contains these conditions after undergoing the requisite notice-and-comment process". The court denied HUD a stay pending appeal on 2026-08-13. HUD's emergency stay motions in the First Circuit (Nos. 26-1922 and 26-1923) were fully briefed by 2026-09-04, and the court had not ruled by 2026-09-11. The instrument on which this item's `attempted` rested is stopped by an order in force.

The Mandate said

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.”

What happened

Attempted

HUD published a $4.04 billion FY2026 Continuum of Care NOFO built on "investing in recovery and self-sufficiency", with Secretary Turner saying "the 'housing first' experiment failed Americans by warehousing the vulnerable without results". Awards were announced for December 2026, so nothing had been re-competed on the new terms as of 2026-08-27, and the FY2025 round was still running under the enjoined-in-place FY2024–25 NOFO.

The Mandate said

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.”

What happened

Blocked

The First Circuit denied HUD's motion for a stay pending appeal of the district court's refusal to dissolve the injunctions, holding HUD had not shown the district court overlooked any significant change in law or fact after Congress's 2026 appropriations act. The injunctions stayed in force.

The Mandate said

“Finally, and more fundamentally, Congress could consider a wholesale overhaul of HUD that contemplates devolving many HUD functions to states and localities with any remaining federal functions consolidated to other federal agencies (for example, by transferring loan guarantee programs to SBA; moving Indian housing programs to the Department of the Interior; moving rental assistance, mortgage insurance programs, and GNMA to a redesignated Housing and Home Finance Agency).”

What happened

Attempted

The FY2027 President's Budget renewed the direction without repeating the block-grant proposal by name: it requests $73.5 billion for HUD, a 13 percent cut, and says the Budget "rightsizes the Federal role and eliminates the majority of HUD formula and competitive programs", proposing to abolish CDBG (−$3.3 billion) and HOME (−$1.3 billion) on the reasoning that "State and local governments are better positioned" and that "[l]ocal residents would be put back in control of the housing in their communities". That is elimination rather than transfer of the functions, and it too requires Congress.

Still to come

Executive action 9

  1. 508 Issue an EO making the HUD Secretary a member of CFIUS Notable Not started
  2. 509 Suspend all external research and evaluation grants at PDR Notable Not started
  3. 510 Raise the FHA mortgage insurance premium on loans over 20-year terms Notable Not started
  4. 508 Assign all delegated HUD powers to political appointees immediately Minor Day one Not started
  5. 508 Convert HUD career leadership positions into political appointments Minor Day one Not started
  6. 508 Use SES transfers to install aligned HUD leadership Minor Day one Not started
  7. 509 Reduce the anti-marriage bias in housing assistance programs Minor Not started
  8. 509 End or realign non-data functions of the Office of Policy Development and Research Minor Not started
  9. 510 Move the Real Estate Assessment Center from PIH to the Office of Housing Minor Not started

Blocked in court 4

  1. 509 End Housing First policies at HUD Major Blocked

    Blocked Sep 11, 2026.

  2. 516 End Housing First directives for Continuum of Care grantees Notable Blocked

    Blocked Sep 11, 2026.

  3. 516 Restrict local Housing First policies funded by HUD grants Notable Blocked

    Blocked Sep 11, 2026.

  4. 516 Shift homelessness funding from permanent supportive to transitional housing Notable Blocked

    Blocked Sep 11, 2026.

Needs Congress 11

  1. 512 Transfer HUD loan guarantee programs to the SBA Major Not started
  2. 512 Move Indian housing programs to the Department of the Interior Major Not started
  3. 512 Move rental assistance, mortgage insurance, and GNMA to a Housing and Home Finance Agency Major Not started
  4. 510 Revise FHA's statutory single-family mortgage insurance restriction Notable Not started
  5. 510 Statutorily restrict FHA eligibility to first-time homebuyers Notable Not started
  6. 511 Create tax credits for rural housing renovation and repair Notable Not started
  7. 511 Prioritize mobility vouchers over site-based rental assistance subsidies Notable Not started
  8. 507 Have Congress redelegate authorities diverted to HUD's bureaucracy Minor Not started
  9. 509 Enact legislation removing work and marriage penalties in housing benefits Minor Not started
  10. 510 Move the HECM program back to its own special risk insurance fund Minor Not started
  11. 510 Provide statutory flexibility for shorter-term amortizing mortgage products Minor Not started

All recommendations in this chapter

Every recommendation this chapter is the home of, in printed-page order.

  1. 504 Head every listed HUD office with political appointees Partially done
  2. 507 Have Congress redelegate authorities diverted to HUD's bureaucracy Needs Congress Not started
  3. 508 Assign all delegated HUD powers to political appointees immediately Day one Not started
  4. 508 Convert HUD career leadership positions into political appointments Day one Not started
  5. 508 Use SES transfers to install aligned HUD leadership Day one Not started
  6. 508 Issue an EO making the HUD Secretary a member of CFIUS Not started
  7. 508 Create a HUD task force to reverse Biden progressive-ideology actions Partially done
  8. 508 Review all HUD subregulatory guidance issued outside the APA Partially done
  9. 508 End the Property Appraisal and Valuation Equity (PAVE) policies Day one Partially done
  10. 508 Repeal climate change initiatives and spending in HUD's budget request Partially done
  11. 509 Repeal the Affirmatively Furthering Fair Housing (AFFH) regulation Done
  12. 509 End use of special-purpose credit authorities to further equity Done
  13. 509 Eliminate the new Housing Supply Fund Not started
  14. 509 Align HUD immigration-status rules with DHS Public Charge reforms Partially done
  15. 509 Restrict HUD program eligibility to protect life, health, and self-sufficiency Partially done
  16. 509 Reduce the anti-marriage bias in housing assistance programs Not started
  17. 509 Strengthen work and work-readiness requirements in HUD programs Attempted
  18. 509 Impose maximum term limits for residents in PBRA and TBRA programs Attempted
  19. 509 End Housing First policies at HUD Blocked
  20. 509 Enact legislation removing work and marriage penalties in housing benefits Needs Congress Not started
  21. 509 Suspend all external research and evaluation grants at PDR Not started
  22. 509 End or realign non-data functions of the Office of Policy Development and Research Not started
  23. 510 Raise the FHA mortgage insurance premium on loans over 20-year terms Not started
  24. 510 Revise FHA's statutory single-family mortgage insurance restriction Needs Congress Not started
  25. 510 Move the HECM program back to its own special risk insurance fund Needs Congress Not started
  26. 510 Revise FHA loan limit determinations Needs Congress Partially done
  27. 510 Provide statutory flexibility for shorter-term amortizing mortgage products Needs Congress Not started
  28. 510 Statutorily restrict FHA eligibility to first-time homebuyers Needs Congress Not started
  29. 510 Abandon affirmative obligation authorities in single-family housing programs Needs Congress Partially done
  30. 510 Move the Real Estate Assessment Center from PIH to the Office of Housing Not started
  31. 510 Allow private accreditation for physical housing-standard inspections Needs Congress Partially done
  32. 510 Maintain HUD's requested budget authority for IT modernization Needs Congress Partially done
  33. 511 Legislate state and local flexibility against federal zoning preemption Needs Congress Partially done
  34. 511 Oppose any efforts to weaken single-family zoning Partially done
  35. 511 Create tax credits for rural housing renovation and repair Needs Congress Not started
  36. 511 Prioritize mobility vouchers over site-based rental assistance subsidies Needs Congress Not started
  37. 511 Grant authority for flexible PHA sales of public housing land Needs Congress Attempted
  38. 512 Devolve HUD functions to states and localities in a wholesale overhaul Needs Congress Attempted
  39. 512 Transfer HUD loan guarantee programs to the SBA Needs Congress Not started
  40. 512 Move Indian housing programs to the Department of the Interior Needs Congress Not started
  41. 512 Move rental assistance, mortgage insurance, and GNMA to a Housing and Home Finance Agency Needs Congress Not started
  42. 515 Revise guidance that adds delay and cost to new housing construction Partially done
  43. 516 End Housing First directives for Continuum of Care grantees Needs Congress Blocked
  44. 516 Restrict local Housing First policies funded by HUD grants Blocked
  45. 516 Shift homelessness funding from permanent supportive to transitional housing Blocked

Also cited in this chapter

Recommendations whose home is another chapter but which this chapter repeats.

  1. Bar noncitizens from federally assisted housing Attempted