The latest iterations of the Treasury Department’s guidance for the $46.55 billion funding allocated for rental assistance via 2021’s Consolidated Appropriations Act (ERA 1) and American Rescue Plan Act (ERA 2) provide for states or localities to introduce additional criteria to prioritize the distribution of rent relief funds. For instance, localities may choose to prioritize landlords most financially impacted by rent non-payment, often small landlords who are less likely to have the resources to manage lost rental revenues. This brief explores and compares the ways in which four jurisdictions—New Orleans, Louisiana; Washington, DC; San Mateo County, California; and the State of Missouri—created or tailored emergency rental assistance programs to provide access or assistance specifically to small landlords. In addition, we review the lessons learned from their experiences developing and administering these programs.
The programs detailed here were launched in 2020 using CARES Act funding and therefore reflect actual experiences and learnings from standing up and administering assistance to small landlords during the COVID-19 pandemic. With the significant additional funding that localities have received via ERA 1 and ERA 2, there may be an opportunity to launch larger-scale programs that prioritize small landlords, building on the lessons learned from earlier programs detailed here.
Why does this matter? Landlords with only a few units under ownership may be particularly vulnerable to losing their property, or not having enough funds to properly maintain buildings, if even a limited number of tenants are unable to pay their rent. Therefore, prioritizing these landlords for assistance can act as a bulwark for tenants who would otherwise be at heightened risk of housing insecurity. Additionally, assistance targeted to small landlords can help to mitigate the fallout from the COVID-19 crisis on landlords of color, who, per research by the Urban Institute, are disproportionately vulnerable to COVID’s economic consequences. Urban’s analysis shows that Black and Hispanic landlords are less likely to have financial resources to manage rental revenue losses, as they have, on average, lower incomes, fewer properties under ownership, and are more likely to have a mortgage rather than own the property outright.
What can assistance to small landlords look like? The four programs that we reviewed varied in size, structure, amount of assistance provided, etc. Three out of four required that rental arrears be fully discharged as a condition of award. However, programs typically did not provide the full amount of rental arrears, requiring landlords to accept a percentage of the total rent amount owed and agree to forego the remaining amount. In addition, programs generally required additional concessions, including, e.g., commitments not to evict for a period of time and forgiveness of late payments and fees (see COVID-19 Emergency Rental Assistance: Analysis of a National Survey of Programs).
Below is a series of tables that compare and contrast these programs, as well as a more in-depth description of each program’s structure and features.
The four programs that we reviewed were administered at the city, county, and state levels:
|Program name||City/State||Jurisdiction||Administering agency||Program information|
|Housing Stabilization Grant||Washington, DC||City||Department of Housing and Community Development||DC Housing Resources, Program announcement|
|Emergency Rental Arrears Program||Missouri||State||Missouri Housing Development Commission||ERAP Program Overview|
|Small Residential Property Owner Assistance Program||San Mateo County, CA||County||County Community Fund||Program Overview|
|Small Landlord Emergency Grant Program||New Orleans, LA||City||Mayor’s Office of Community Development||Program press release|
Funding and structure
These small landlord assistance programs were primarily financed through federal COVID-19 relief funds, often flexible CARES Act dollars, with program budgets ranging from $1.5-2.25 million. All programs limited the maximum amount of rent relief available per eligible unit and the amount an individual landlord may receive in total. Several programs further limited the number of months for which landlords were able to receive assistance.
|Program name||Funding amount||Funding source||Maximum funding per unit||Maximum funding per landlord||Expected reach|
|Housing Stabilization Grant, Washington, DC||$2mm*||CARES||$2,000 or 80% rent/unit/month for up to 8 months (Apr-Nov)||$320,000 ($2000/unit x 20 units x 8 months)||500+ unit/ months|
|Emergency Rental Arrears Program, Missouri||$2.25mm target**||CARES (ESG-CV)||$9,390 or 6 months’ rent||$93,900 (max per unit amount x 10 units)||1,400+ unit/months|
|Small Residential Property Owner Assistance Program, San Mateo County||$2mm||CARES||$6,000 or 80% of 5 months rent (Apr-Aug)||$60,000 (max per unit amount x 10 units)||1,650+ unit/months|
|Small Landlord Emergency Grant Program, New Orleans||$1.5mm||Not specified||$15,000||$15,000 total||100 landlords, 500-700 households|
* $1 million in Housing Stabilization Grant funds was initially allocated specifically for small landlords (up to 20 units). The program was expanded with an additional $2 million due to strong response. A separate funding tranche of $9 million was allocated to providers of income-restricted affordable housing.
**Missouri indicated that it would seek to provide 15% of a total $15 mm emergency funding to small landlords.
Program eligibility and documentation
Eligibility: The criteria localities used to determine whether a recipient qualified as a “small landlord” ranged from eight units to 20 units (variously specified as total units under ownership or total units owned in the jurisdiction). San Mateo County initially included a 10-unit ownership cap for landlords to be eligible, and required that participating landlords earn over 50% of income from rental properties. However, in response to slow takeup, San Mateo eliminated its ownership cap weeks after program launch, amending its program to offer assistance for a maximum of 10 units per landlord.
Documentation: Administrators also noted that application/documentation requirements posed challenges for some landlords. They stressed the importance of technical assistance and extensive follow-up by program teams and partners, particularly to make sure that applicants who were close to successful application completion were able to provide or correct any information needed to finalize their applications.
Outreach: While administrators of these programs generally did not conduct significant outreach, they noted that trade associations were helpful in spreading word-of-mouth, helping landlords to understand program eligibility and how to navigate application and documentation requirements. Program administrators seeking to target small landlords may wish to proactively connect with such organizations (as well as real estate companies, property managers, community organizations, etc.) to raise awareness.
|Program + jurisdiction||Tenant eligibility / requirements||Landlord size limits||Other landlord/ eligibility requirements and prioritization criteria||Documentation requirements||Outreach examples|
|Housing Stabilization Grant, Washington, DC||—||20 units||Units not in DC affordable housing portfolio [assisted via separate funding tranche]||Business license,completed W-9, 2019 Schedule E (federal tax statement), 2019 Form D-30 (DC tax statement),2020 rent roll, proof of ownership, Clean Hands certification of compliance with DC Office of Taxation and Revenue||Mayoral announcement; word-of-mouth through trade associations|
|Emergency Rental Arrears Program, Missouri||50% AMI, MO residency, COVID hardship, notice of past due rent or eviction||10 units||—||Landlord information (incl. EIN/SS #, federal tax classification, W-9); tenant information (incl. HMIS intake, income certification, and consent); lease, itemized past-due rent statement, minimum habitability and lead-based paint certification||Radio ads and outreach to non-profits; word-of-mouth through trade associations, real estate companies, and property managers|
|Small Residential Property Owner Assistance Program, San Mateo County|
|Assistance for up to 10 units (no cap on units owned).*||Landlord residency and units leased in the County; prioritization for units based on their location within priority zip codes with high poverty and COVID-19 rates, and based on the ratio of rental loss to the property owner’s income.*||2018-2019 tax returns; completed W-9; and for each unit seeking grant funds: property address, most recent property tax statement, proof of ownership, proof of current unit tenancy, 2020 rent roll/YTD 2020 bank statements||Multilingual communications via County and localities’ social media pages and communications; coordination with trade associations|
|Small Landlord Emergency Grant Program, New Orleans||—||8 units||Units leased in New Orleans; non-short term rentals||Documentation of hardship, extent of lost revenue, inability to make mortgage payments||City communications; trade associations|
* San Mateo’s program originally required that landlords have 10 or fewer units, that they earn over 50% of income from rental properties, that they earned gross rental income of <$400,000 in 2018 and 2019, and that units must be rented at or below Fair Market Rate to receive assistance. The former requirement was amended to enable landlords to receive assistance on up to 10 units, with no cap on units under ownership. The latter requirements were eliminated, although the program planned to continue to consider income and rental price as priorities in grant making decisions if the program approached its allocation.
Arrears and concessions
Programs generally required landlords to forgive some portion of past-due rent and/or related fees and penalties. Most programs required landlords to commit to not evicting tenants for whose units they receive rental assistance funds for a set period of time after receiving assistance. Only San Mateo did not require that arrears be forgiven in full with the receipt of assistance, mandating only that $7,500 worth of back rent be forgiven with the receipt of $6,000 assistance (the per-unit maximum award).
|Program + jurisdiction||Arrears discharged in full?||Additional concessions|
|Housing Stabilization Grant, Washington, DC||Yes. DC paid 80% of rent (up to $2,000/mo) and required recipients to forego the remaining 20%.||Forgiveness of fees/penalties/interest accrued 4/1/2020-11/30/2020.|
|Emergency Rental Arrears Program, Missouri||Yes. MO paid up to $9,390 in assistance and required any and all outstanding rent above the assistance amount to be waived for the months that assistance was provided.||Waiver of fees/penalties accrued for late rent or non-payment on or before date of program application; non-eviction guarantee for 120 days from program application.|
|Small Residential Property Owner Assistance Program, San Mateo County||No. The County provided 80% or up to $6,000 of back rent owed; landlords were required to forgive only up to $7,500/unit.||—|
|Small Landlord Emergency Grant Program, New Orleans||Yes. New Orleans provided up to $15,000 in assistance and required that, with award receipt, landlords could not seek rent repayment for the months that mortgage assistance was provided.||Through Jan 2021: Non-eviction; units that become vacant must be rented within 30 days to a tenant making up to 80% AMI.|
Housing Stabilization Grant, Washington, DC
Program Funding and Structure: Washington, DC launched its $10 million Housing Stabilization Grant program to assist affordable and small landlords in the District using CARES Act funds. The funds were allocated in two tranches: an initial $1 million to owners of 20 or fewer units in DC, and the remainder of funds allocated to providers of income-restricted affordable housing projects that are financed by the Housing Production Trust Fund, LIHTC, or other local/federal affordable housing funds. The funding tranches were separately administered by the Department of Housing and Community Development and by DC’s Housing Finance Agency, respectively.
Due to high demand for the small landlord program following its launch, program funding was expanded to $2 million, assisting a total of 220 landlords who owned 310 units. 75% of property owners applying to the program only requested assistance for one tenant.
Program Outreach: The Housing Stabilization Grant program was launched with an announcement from Mayor Bowser. Program outreach was relatively limited, but saw strong interest and word-of-mouth information sharing from a small landlord association in DC, which held a webinar to share information about the program, and conducted outreach to other associations to spread the word.
Arrears and Concessions: The grants cover rent arrears accrued from April 1 through November 30, 2020, with the District paying 80% of the rent value (up to $2,000/unit/month). Awardees were required to forgo the remaining 20%. A program administrator noted that only five landlords were not willing to accept the 80/20 requirement, fewer than other programs have encountered. As a condition of assistance, awardees were required to forgive all arrears, including fees, penalties, and interest, accrued from April 1 through November 30, 2020.
Eligibility and Documentation Requirements: Requirements included applicant’s certification that they do not have any outstanding payments due to DC’s Office of Taxation and Revenue (OTR) (called a “Clean Hands” certification). A program administrator noted that there were gaps in landlords’ familiarity with standard landlord documentation and tax requirements. In order to receive assistance, approximately ⅓ of applicants needed to become compliant, including through handling outstanding OTR payments/tax requirements, getting a business license, etc. Unlike some other small landlord assistance programs, DC did not require that the landlords seeking relief be DC residents themselves, although a program administrator noted that most applicants did live in the greater DC area.
Lessons Learned: As noted above, administrators found that there were challenges in ensuring that owner applicants were in basic compliance with DC regulations for landlords, and that they could provide tenancy and rent information in a thorough and standard fashion that enabled application processing. DC found success in providing applicants with a rental ledger template that helped standardize application submissions and reporting. A program administrator noted that this increased uptake and simplified back-end administration. The City also used the program as an educational opportunity, making sure that landlords that they communicated with were aware of, e.g., rental income reporting requirements.
DC also experienced challenges in verifying the number of units that a landlord owned in DC, to ensure that they qualified as a small landlord under the program’s requirements. This verification effort was difficult as the use of LLCs make it challenging to ascertain which properties share ownership.
Emergency Rental Arrears Program, State of Missouri
Program Funding and Structure: Missouri’s Emergency Rental Arrears Program (ERAP) allocated 15% of its $15 million ESG-CV funds to provide assistance to landlords who own 10 or fewer units. Program administrators report that, as of late March, approximately 40% of assistance had been awarded to small landlords, far exceeding the program’s initial target.
Program Outreach: Because large urban areas were eligible to receive direct CARES Act funding allocations, Missouri’s state-wide program targeted its outreach to the state’s rural communities. The state ran radio ads in non-urban areas and conducted outreach to inform non-profits statewide about the program. Beyond their formal outreach strategies, they found that real estate companies, property managers, and realtors associations were getting out information about the program themselves.
Arrears and Concessions: The program provided landlords with a one-time reimbursement of up to six months (a maximum of $9,390) in rental arrears per qualifying unit. Participating landlords were required to waive any outstanding rent, late fees, or other penalties incurred by or the tenant for non-payment or late rent payments on or before the application submission date. Landlords also were required to sign a guarantee of non-eviction for 120 days from that date.
Eligibility and Documentation Requirements: Applications were required to be completed and submitted by landlords in collaboration with their tenant. The program required that tenants earn up to 50% of AMI and provide a notice of past due rent or eviction (required for ESG-CV funds), and demonstrate residency and COVID hardship. To participate, landlords needed to sign a guarantee of non-eviction of the tenant listed in the application for non-payment of rent for 120 days from the date of the rental arrears application submission. By accepting rental assistance, landlords were expected to waive all outstanding rent, late fees, and other penalties incurred by the tenant incurred on or before the date the application was submitted.
Lessons Learned: Program administrators noted that many landlords initially had difficulty with completing applications and providing all required documentation. However, they found that larger landlords generally became more efficient as they filed numerous applications, while small landlords did not have the opportunity to benefit from greater familiarization. In general, assistance efforts targeted to small landlords may require more ongoing support from program teams than a non-targeted landlord assistance program would.
In addition, small landlord applicants were less likely to have formalized leases that met requirements and included all required information; proof of arrears was similarly more difficult for smaller landlords to provide. Furthermore, state program administrators also noted that some small landlords were hesitant to share their W-9s, one documentation requirement of the program.
To ease these challenges, Missouri worked with a staffing agency which provided assistance to small landlords to “cure” applications that had been deemed incomplete/ineligible on initial review. Originally, the program planned to only offer a single cure attempt to applicants to reduce the administrative burden, but found that, in many cases, issues remained after the first cure attempt .The staffing agency has undertaken follow-up outreach and support to further assist landlords in finalizing their applications.
Sources: NLIHC, ERAP Program Overview, MHDC News Post, Application Checklist, Missouri Housing Development Commission announces new rental assistance program (news article), discussion with program administrators
Small Property Owner Assistance Program, San Mateo County, California
Program Funding and Structure: San Mateo County set up a $2 million grant program, the Small Property Owner Assistance Program, using CARES Act funds. Initially, the program offered assistance to San Mateo-resident owners of 10 or fewer units. It was subsequently amended to provide landlords with assistance for up to 10 units even if the landlord owned additional units.
Grants were administered by San Mateo County’s Community Fund, the San Mateo County Association of Realtors, the California Apartment Association, and County agencies. Program administrators noted that it was critical to have the Community Fund on board, as their experience with documentation to establish ownership and ability to conduct real-time data analysis allowed the program to be tailored mid-stream.
Program Outreach: The County conducted program outreach in English, Chinese, and Spanish. The County’s Office of Community Affairs pushed out communications for the program including via social media posts. County municipalities also highlighted the program in their communications. The program application was made available in English, Spanish, and Chinese, although some questions/responses were required in English.
Arrears and Concessions: The program offered to cover 80% of rent losses incurred from April 1 through August 31, 2020, up to a total of $6,000 per qualifying unit. Grantees were required to “discharge back-rent owed in an amount equal to the amount of rental losses between April 1 and August 31, 2020 up to a maximum forgiveness amount of $7,500 per qualifying unit.” Ultimately, 39 landlords were provided with a total of $225,000 in assistance for 53 rental units, (representing a per unit average of $4,245 in assistance).
Eligibility and Documentation Requirements: The program was initially limited to landlords who earned 50% of their income from rental properties, who earned less than $400,000 in annual gross rental income in 2018 and 2019, and whose properties were rented at or below HUD 2020 Fair Market Rent. Originally, San Mateo had a short application timeline, but a couple of weeks after the program launched, application rates were low. To increase uptake, the county eliminated its income and revenue limitation criteria and lengthened the application period.
Lessons Learned: The County believed that its landlord residency, income, and size requirements overly-restricted the pool of eligible and interested applicants and emphasized the importance of keeping program applications and requirements as simple as possible; additional proscriptions around eligibility diminished the universe of eligible and interested applicants.
Program administrators recommended that similar programs should not be run on a first-come, first-served basis. Apportioning assistance after the application period closes enables prioritization if there is over-subscription (while the program did not exhaust its funding allocation, it planned to prioritize assistance if needed on the basis of the ratio of rental loss to the property owner’s income). In addition, programs that are first-come, first-served may also disadvantage those with limited technology access or face other challenges in completing the application rapidly or in its entirety. San Mateo noted that there were some applicants with whom they had to spend extended periods of time providing technical assistance with application completion, document uploading, etc.
Sources: NLIHC, Small Property Owner Assistance Program (archived), Application Document Checklist (archived), San Mateo Co. Supes Approve $5 Million in Assistance For Renters, Landlords (news article) , San Mateo County approves aid program for small landlords (news article), County supervisors approve grant program for small landlords (news article), Small Property Owner Assistance Program In Millbrae (news article), discussion with program administrators
Small Landlord Emergency Grant Program, New Orleans, Louisiana
Program Funding and Structure: New Orleans offered $1.5 million in mortgage assistance to landlords owning eight or fewer rental units whose rental income has been impacted by the COVID-19 pandemic via the Small Landlord Emergency Grant Program (SLEG). The City estimated that the fund would assist at least 100 landlords and stabilize housing for between 500 and 700 households.
Program Outreach: Landlords interested in applying to the program were encouraged to call a phone number for the Mayor’s Office of Community Development. There did not appear to be an online or another application mechanism.
Eligibility and Documentation Requirements: Applying landlords were required to provide documentation of their hardship and inability to make mortgage payments.
Awards and Concessions: Awardees could receive up to $15,000 in total assistance. Upon receipt of SLEG assistance, rent must be considered current and awardees could not seek repayment of rent for the months that mortgage assistance was provided by the program. Awardees were additionally required not to evict current tenants through Jan. 31, 2021 (the program was launched on October 8, 2020). Should an awardee’s unit become vacant through Jan. 31, 2020, the unit must be rented within 30 days to an 80% or below AMI household.
Sources: NLIHC, Program press release, New Orleans government to offer $1.5M in mortgage help for landlords (news article)