A new pilot program here in DC is taking an innovative approach to providing rental assistance.
It’s no secret that the District’s low-income families struggle to afford rent. Two-thirds of households earning less than 30% of the Area Median Income are extremely rent burdened, meaning that they spend more than half of their income on housing.
But how exactly rental assistance should be delivered is less clear. The most common type of rental assistance is through rental vouchers, like HUD’s Housing Choice Voucher and DC’s Local Rent Supplement Program, that make sure recipients never pay more than 30% of their income for housing.
The dependability of housing vouchers is essential for many families, and DC housing advocates have consistently called for LRSP to be expanded.
But some families only need subsidy some months out of the year, rather than every month. That’s because the lower your income, the more likely you are to be income insecure. Households with lower incomes are more likely to be in the service industry or depend on temporary jobs, positions where income can fluctuate greatly from month to month.
Currently these households often have to turn to the Emergency Rental Assistance Program, DC’s eviction prevention fund, during lean times. It’s a process that can be time-intensive, and all too often families fall through the cracks.
Instead, a new pilot program would let these families on the edge do their own budgeting. Households would be given $7,200 per year to manage as they choose. If the primary earner has more work than usual, the may choose not to draw any funds. If they’re unemployed, they may take a full month’s rental payment.
It would even let the money be spent on other needs, like groceries or medical care. The idea recognizes that the households themselves are in the best position to know their monthly needs.
And while full housing vouchers are still in desperately need of expansion, this kind of flexible, shallow subsidy could go a long way towards helping families living on the edge.
Senator Elizabeth Warren has introduced an ambitious package of reforms and improvements for the United States’ affordable housing system. The bill, if passed, would represent the largest legislative change to the nation’s housing since the Community Reinvestment Act (CRA) in 1977.
Senator Warren, a Democrat from Massachusetts, has long been a favorite of the party’s progressive wing and is viewed as a potential 2020 presidential candidate.
The bill, as audacious as it is comprehensive, deals with CRA reform, Fair Housing, downpayment assistance, and more. It would cover its $450 billion price tag by reinstating the estate tax at its level under the Bush Administration, a move that would impact only the country’s top 10,000 earners. We’ll break down a few of the bill’s top features below.
Community Reinvestment Act reform
Up until 1968, the federal government actively encouraged segregation by only backing home loans made in exclusively white neighborhoods. The practice, known as “redlining” because of the maps showing red-lined neighborhoods of color where banks should not lend, plays a large role in today’s racial wealth gap.
In 1977, Congress passed the Community Reinvestment Act, which requires banks to lend in all the neighborhoods they serve and scores them based on their community lending activity. The CRA has resulted in billions of dollars of (safe, profitable) lending that would never have otherwise happened.
However, the CRA does not have authority over all mortgage lenders. Non-bank mortgage lenders—the Rocket Mortgages and Loan Depots of the world—are not covered. Since these non-bank lenders now originate half of all mortgages, that’s a problem.
Sen. Warren’s bill extends CRA enforcement to these lenders, ensuring that they too are lending in previously redlined communities. What’s more, CRA enforcement across the entire industry would get a boost, with tougher penalties for lenders who fail to meet their legal obligations.
The National Community Reinvestment Coalition recently released research indicating that weakening the CRA, as the Trump Administration has proposed, could result in over $20 billion of lost lending each year. NCRC has yet to calculate the impact of Sen. Warren’s bill, but their work makes clear the magnitude of the potential impact from CRA reform.
To further combat the history of redlining, the bill would institute a sort of national version of the Home Purchase Assistance Program. First-time homebuyers in communities that had faced redlining or other intentional segregation would be eligible for downpayment assistance from the federal government.
As HPAP has in DC, this downpayment assistance program could open homeownership to families for whom it would never otherwise have been possible and start building the generational wealth that so many families of color were locked out of in the 20th century.
The bill also would provide financial relief for homeowners whose properties are underwater. Since communities of color were targeted for predatory mortgages at higher rates than white families regardless of income, this also would serve to decrease the racial wealth gap in homeownership.
National Housing Trust Fund
Again following DC’s lead, the bill would dramatically increase funding for the National Housing Trust Fund. The Trust Fund, established in 2008 and funded in 2016, has so far distributed less than a billion dollars. Sen. Warren bill would make an investment of $445 billion.
That, along with additional federal investments to leverage private funds, is estimated to create or preserve up to 3.1 million affordable units across the country. That’s roughly how many units the Low-Income Housing Tax Credit, the government’s current number-one tool for affordable housing, has produced in the last twenty years.
The bill would expand the Fair Housing Act to cover sexual orientation, gender identity, and the use of a housing voucher. In many places across the country, it is still legal for housing providers to deny tenants based on any of these factors.
The bill also places a special focus on the creation of affordable housing on Native American tribal land, an area of housing that is currently severely underserved.
As the affordable housing crisis continues to gain recognition at the national level, Sen. Warren’s bill will be an important one to watch. And if Sen. Warren does decide to run for president, it could prove influential in the 2020 election and beyond.
A new pilot program from the District’s Department of Housing and Community Development offers grant money for needed rehab work at small rental, co-op, and condo buildings.
The Small Buildings Grant Program offers an important opportunity to preserve affordable ownership and rental housing as more affordable homes are lost each year in DC.
More than 1,000 affordable homes disappeared in the District between 2006 and 2014, and another 1,750 are in danger. Keeping affordable homeowners and renters in place helps stabilize changing neighborhoods and is more cost effective than constructing new affordable homes.
To be eligible, a building must have between 5 and 20 units, with a portion of households earning less than 50 or 80% of the Area Median Income. The grant offers $25,000 per unit for repairs, with a maximum award of $200,000.
The program is similar to the Common Interest Communities legislation attached to the budget for FY2019. That legislation establishes a fund for low- and moderate-income co-op and condo associations to repair common elements of their buildings, such as roofs, plumbing, or electrical systems.
Since that legislation was crafted with community input, it avoids several pitfalls of the new Small Buildings Grant Program. One important difference is that the Common Interest Communities program allows residents to submit an independent assessment of their buildings’ needs, rather than relying on a DCRA inspection report.
Unfortunately, the requirements of the Small Buildings initiative may coerce buildings into seeking out a fine from DCRA just in order to be eligible for the needed grant funds. That could discourage participation and work counter to the stated goals of the program.
The Common Interest Communities legislation also imposes no cap on the number of units an eligible association can have. Although the Small Buildings Grant Program may have found such limitations necessary while working within the parameters of a limited pilot budget, Common Interest Communities has legal access to funds from the sale of city-owned property—a sufficient pot to have a much larger impact.
We hope to see both the Small Buildings Grant Program and the Common Interest Communities legislation fully implemented and expanded!
On Tuesday, the Trump Administration formally started work towards a long-held goal: weakening the Community Reinvestment Act (CRA).
The Office of the Comptroller of the Currency, one of the federal entities in charge of enforcing the CRA, announced that it is seeking input about how to “modernize” the legislation and reduce the “burden” imposed by its requirement to lend to low- and moderate-income borrowers.
Here’s a quick refresher on the CRA from an earlier post. Feel free to skip down if you’re already familiar.
The CRA was written after several decades of growing pressure for Congress to reverse damage done by the legalized racism of the mid-20th century. Between 1934 and 1968, the Federal Housing Authority effectively required that private mortgage institutions avoid lending to non-white communities by refusing to back loans that did not comply with their rules.
In the practice known as “redlining,” detailed city maps were distributed by the Authority to mortgage companies with neighborhoods color-coded to determine their desirability for lending based on how homogenously white the neighborhood was.
This policy and others like it are in large part responsible for our present day racial wealth gap. The CRA attempts to correct this by monitoring the volume of loans banks make to low- and moderate-income communities, as well as the number of branches and ATMs they have in these areas.
Financial institutions that do significant lending in low- and moderate-income neighborhoods are more likely to be approved to open new branches and merge with other banks, whereas noncompliant institutions may be denied or required to make a plan for investment with community groups before being given approval.
But all that could be a thing of the past if the Trump Administration gets its way. The public request for comment includes a number of softball questions offered up for the banking lobby to knock out of the park. Based on these questions, we can gather a picture of the chances the Trump Administration has in mind.
One of their key goals seems to be to weaken the importance of assessment areas and physical bank branches.
Since the CRA’s primary purpose is the undo the effects of redlining, it places a heavy emphasis on the location of bank branches and the neighborhoods that banks are lending in. Having more banks and making more loans in low- and moderate-income neighborhoods gets banks more CRA credit.
The Administration (and, coincidentally, the banking lobby) have argued that online banking services have made physical bank branches irrelevant for serving low-income communities.
But that’s clearly not true.
Residents in low-income communities are less likely to have high-speed internet or own a smartphone, making online banking harder for them to access.
Additionally, the relevance of bank branches is evidenced by their continued existence and expansion in more affluent neighborhoods. Many large banks still make more than half of their loans through traditional brick-and-mortar locations, and they’re not closing “irrelevant” branches in these wealthier locales.
Another Trump Administration goal appears to be expanding the categories of loans that count for CRA credit to the point that they are meaningless. Providing financing for the construction of a new hospital, for instance, has been floated as a possible expansion.
While financing a new hospital in Ward 8 is a worthy goal, adding yet another hospital to Northwest DC is not.
There are meaningful updates and expansions to the CRA that could be helpful, and many good ideas have been proposed by the National Community Reinvestment Coalition. But with the Trump Administration’s list of questions released yesterday, it’s clear that their only goal is to satisfy the banking lobby.
MANNA and other DC nonprofits depend on funding incentivized by the CRA to offer affordable housing and homeownership counseling services. So do low- and moderate income families looking to buy a home.
If the incentive goes away, that funding won’t last long. A recent review of changes to CRA designations in Philadelphia found that lending to lower income borrowers fell a whopping 20% when a neighborhood no longer qualified for CRA credit.
Now is the time to weigh in. Click here for information about how your organization can submit a comment in support of the CRA’s low- and moderate-income lending requirements.
Residents of DC General and Barry Farms share a lot of common concerns. Their homes are crumbling. Their environments are toxic. And they don’t trust DC’s plan to fix it.
At DC General, the District’s shelter for homeless families, residents are dealing with hazardous dust from the demolition of other buildings on the shelter’s campus. Ambulances arrive regularly to take away residents with breathing problems exacerbated by the pollution, and Washington City Paper recently reported that lead had been found at the site.
Even before this latest health hazard, residents had to deal with vermin, problems with the hot water, and infections spread by unsanitary conditions.
At Barry Farms, a public housing complex just south of the Anacostia neighborhood in Ward 8, conditions are equallydire. A majority of the 444 homes now sit empty. Those boarded up units have become breeding grounds for rats and bed bugs, and residents contend that the Housing Authority has stopped performing routine maintenance.
But in both cases, residents and activists are fighting District plans to move residents out.
Residents at DC General have made headlines with their protests against the continued demolition work while they still live there, calling for the end of the asthma-exacerbating dust. But some residents and advocates have also called for the closing of the shelter to be postponed indefinitely, until replacement shelters are complete.
At Barry Farms, residents recently won a court challenge against the redevelopment plan for their homes, and the families that remain have now managed to stay for years longer than the District’s original relocation plans called for.
District officials have promised that residents at Barry Farms will be able to return to the shiny, new development when it is completed, and DC General is scheduled to be replaced by brand new smaller shelters across the District, better suited to meet families’ needs.
So why have residents fought so hard to stay when their homes are in such unlivable conditions?
In a word, history.
The New Communities Initiative, under which Barry Farms is being redeveloped, has a poor track record of delivering on promises. The Temple Courts community near Union Station, demolished over a decade ago, is only now in motion to begin constructing replacement units. Because of that gap, most of the community’s original residents will never exercise their right to return.
At Barry Farms, the number of affordable and family-sized units is significantly reduced under redevelopment plans, falling from 444 affordable units to just 344. A significant number of multi-bedroom apartments will also be lost.
Although the community has now been winnowed down to just over 100 families, advocates and residents have argued that loss of affordable units changes the culture and demographics of the neighborhood.
And a District judge agrees. The redevelopment is now on hold, as the judge has ordered the District to reconsider how their plans can better accommodate current residents.
At DC General, there’s a general consensus among the residents that demolition should wait until after all the families have moved out. But some are also pushing for that move-out date to be extended past September, even though it means staying in the shelter’s substandard conditions.
They fear that DC’s replacement shelters won’t be ready, in which case their families could be moved to hotels in Maryland. And there’s good reason to think their fears are correct.
Washington City Paper recently reported that despite official reassurances, several replacement shelters are significantly behind schedule—likely by about a year.
At both DC General and Barry Farms, residents have a straight-forward take: they want their new homes to be ready before they move out of their old ones, and they don’t trust officials asking them to move out on faith. Given DC’s history, it’s hard to blame them.
Advocates across the country worked tirelessly last November and December in a failed attempt to stop the Trump Administration’s tax cuts for the wealthy. As the dust settled after the fight, some advocates took comfort in the law’s creation of Opportunity Zones, low-income areas that offer tax breaks for investment.
At least, thought these advocates, here was something for our communities. But upon closer inspection, it becomes clear that much of the “opportunity” here is the opportunity for gentrification.
The Opportunity Zones are low-income census tracts chosen by local governments (more on that later) for this special status. They allow tax-free investments in real estate and businesses within the designated areas. According to the Brookings Institute, investors can avoid $7.50 in taxes for every $100 they invest. That’s a pretty big incentive.
Certainly our low-income communities are in need of investment. After decades of neglect from both the private and public sectors, Opportunity Zones sound like the solution that these communities deserve—a governmental program to pull in reluctant businesses and investors.
And there could be some good. Affordable housing projects will be eligible for these tax breaks, too, meaning that some low-income communities will see some benefit.
But the problem is that these investors have no stipulations that their investments be for the good of the people who already live there. A new luxury condo building would receive the same subsidy as an affordable development. New businesses could flourish with the subsidy coming their way, while long-time community institutions will be largely left out in the cold.
As Peter Moskowitz documents in his bookHow to Kill a City, a blanket subsidy for a low-income area almost always ends of benefiting newcomers at the expense of those who already live there. Private investment without stipulations for the public good naturally seeks the highest profit, and that almost always means a displacement of the lower-income community that already called the neighborhood home.
What’s more, only one in every four low-income census tracts can be chosen by local governments. There’s some evidence that local jurisdictions have been targeting census tracts where public-private deals are already in place, meaning that there will be additional government subsidy for private investment that was already going to happen anyway. That completely misses the ostensible point of the program, which is to incentivize new investment in underserved areas.
Hopefully Opportunity Zones can help more affordable housing move forward in vulnerable communities. But without more direction towards public benefit, this program could all too easily turn into another governmental subsidy for gentrification.
Most people realize that 9 to 5 jobs are not the norm for DC’s working class, many of whom have irregular hours in the service industry. But no one expects those irregular days to add up to 91 hours per week.
Unfortunately, if you’re only making the minimum wage, that’s exactly what it takes to afford an average 1-bedroom apartment in DC. A new report from the National Low Income Housing Coalition looks at what it would take for a minimum wage worker to spend only the recommended 30% of their income on an average 1-bedroom apartment.
The results are discouraging. If a minimum wage worker is “only” working 40 hours a week in DC, they’re likely spending about 70% of their income on rent. And although the situation in DC is particularly dire, there are only 22 counties across the entire country where a full-time minimum wage worker can afford an average 1-bedroom apartment.
The numbers are even worse for DC families who need bigger apartments. A 3-bedroom apartment, if you can find it, would take a full-time minimum wage worker’s entire paycheck, with nothing left over for other bills and groceries.
All of these calculations are actually based on a minimum wage of $13.25, which won’t go into effect until July 1st. That means things have been even worse for minimum wage workers who have been earning the current rate of $12.50.
But solutions exist. DC’s Local Rent Supplement Program (LRSP) provides rent vouchers to some low-income families, ensuring that they pay no more than 30% of their income on rent. Close to 4,000 households either already receive assistance through that program or will soon with recent investments.
The Council needs to keep expanding LRSP to cover more households, alongside continual increases to the minimum wage. DC depends on people who do working class jobs to keep the city running, and if the District forces out its working class, it might just stop working.
The DC Council released its budget for a first of two votes on Tuesday, May 15th, and there’s a lot for housing advocates to be excited about. In all, the Council added $15.6 million for housing programs on top of what the Mayor had proposed. Check out the (partial) round-up below:
Local Rent Supplement Program
The Local Rent Supplement Program, or LRSP, is the District’s version of HUD’s Housing Choice Vouchers. These vouchers, which serve households making 30% or less of the Area Median Income, are a subsidy that ensures low-income households never have to pay more than 30% of their income for housing.
The vouchers can either be given directly to residents who then search for housing on the open market, called tenant-based vouchers, or they can be tied to a specific unit that remains affordable and is only available to low-income households, called a project-based voucher.
New investments in LRSP are a big deal—taking vouchers away from residents who need them would be a disaster, so funding for more vouchers is seen as a semi-permanent commitment. Mayor Bowser recommended no new funding for LRSP in her budget, proposing that DC only fund the vouchers it had already issued.
The Council, however, heard calls from advocates to expand LRSP and responded by placing $1.5 million in new tenant-based vouchers and $3.2 million in new project-based vouchers. That’s projected to create a total of 238 newly affordable homes.
The rest of the housing funding added and reshuffled by the Council largely went to housing for residents coming out of homelessness. The Way Home Campaign, a local initiative dedicated to ending chronic homelessness, noted that the Council’s investments were exciting and important, but cautioned that the funding still fell well short of the need.
Among the programs with increased funding were Permanent Supportive Housing, which provides social services as well as housing to residents coming out of homelessness, and Targeted Affordable Housing, often used by residents in PSH who no longer need social services. In all, 616 new units for ending homelessness will be created above and beyond the Mayor’s proposal. A meeting of MANNA’s Homebuyers Club
Housing Counseling Funds
Another issue that we wrote about previously was the proposed cut to housing counseling funds. These funds are the backbone of programs like MANNA’s Homebuyers Club, which offers a range of services to low- and moderate-income residents getting ready to become first-time homebuyers.
That issue was also resolved, although neither local advocates nor the Council can take credit—Congress passed a budget with full funding for the grant program that makes housing counseling and a whole host of other local programs possible. Advocates must now work to make sure that the local housing department uses those funds for their intended purpose.
Budget Support Act Legislation
Several pieces of housing legislation are also passing with the budget in the Budget Support Act. The Housing Advocacy Team has testified in support of several of these bills, and their inclusion in the BSA is a cause for celebration.
One such bill is the Common Interest Community Repairs Funding Amendment Act, which sets up a rehab fund for condominium and cooperative associations where 2/3rds of residents make less than 60% AMI. Eligible communities will be able to receive up to $100,000 for repair work on common elements like roofs, piping, and electrical systems.
Another housing bill in the BSA aims to keep seniors with reverse mortgages from losing their homes. This bill aims to help low- and moderate-income seniors who fall behind on property tax or insurance payments after taking out a home equity loan (also called a reverse mortgage). Seniors who qualify can receive up to $25,000 in assistance. The bill was prompted by reports of older Washingtonians losing their homes over fees of several thousand dollars or less.
It’s important to remember that the Mayor also had many great factors in her proposed budget, including a big increase for the Home Purchase Assistance Program. The Council preserved that increase, and HPAP looks set to be fully funded through the end of 2019.
Thanks to all the advocates for their hard work this budget season! Feel free to comment with any questions about housing programs in the budget, and we’ll do our best to answer quickly.
Advocates cheered this spring when Mayor Muriel Bowser’s proposed budget showed a $9 million increase for the Home Purchase Assistance Program, enough to keep the program fully funded through 2019. Not as readily obvious, however, was the deep cut proposed for the housing counseling that makes HPAP purchases possible.
Kept under the Department of Housing and Community Development, the Neighborhood Based Activities budget contains funds for homeownership and tenant counseling services. That budget is proposed to be cut from $9.5 million for the current year to just $6.1 million next year—a drop of more than a third for these vital programs.
The housing counseling funds allow MANNA and other groups to offer guidance to residents working through the difficult demands of the homebuying process. A 2016 report from the Department of Housing and Urban Development found that homebuying counseling and education increases participants credit scores, encourages better communication with lenders, and improves their understanding of how their mortgage works.
Members of MANNA’s Homebuyers Club typically need help managing their credit score, setting a financial plan, and navigating the lengthy HPAP process, but they also need assistance getting through the typical barriers that arise while trying to buy in DC.
Erin Skinner, a lifelong Washingtonian, as well as HPAP buyer and former member of MANNA’s Homebuyers Club, can attest to that firsthand. She recounts having a first deal fall through and countless hours of work in the two-year process that finally landed her a home. (Read her full story here!)
The Council and the Mayor have shown a great commitment to homeownership in recent years through their increases in the budget and loan amounts for HPAP. Indeed, Councilmembers regularly cite affordable homeownership as a top priority, and the HPAP budget looks set to sail through Council.
But the housing counseling funds are an equally important part of the equation. Affordable ownership is, at best, an incredibly daunting process to work through without a counselor, and the turn-around HPAP has seen from its worst days a half a decade ago is largely due to the efforts of housing counselors.
Thankfully, even if the Council fails to act, DHCD and its Director Polly Donaldson have the power to put funding into this important program. Keep up with our blog for more information going forward!
When the DC Auditor’s Office released its report on the District’s Housing Production Trust Fund earlier this week, the headlines started rolling in right away. City Paper called it “damning.” Think Progress spoke of “astonishing failures.” But a deeper dig into the report’s talking points reveals that the truth in this case is a good bit less sensational than promised.
Where it misleads
The Housing Production Trust Fund is DC’s number one source of affordable housing dollars, and it has a hand in the construction of the vast majority of the District’s affordable homes—more than 10,000 such homes in the past 15 years, according to the audit. The trust fund is legally required to be used as gap financing, meaning that it can fund no more than 49% of any unit’s cost. This allows the fund to do significantly more work and touch significantly more projects than if it were the sole funding source for every unit it produced.
Given the variable level of funding each project receives, plus the fact that the size of DC’s investment in affordable housing is unrivaled in the US, it’s almost impossible to compare what the District is doing with other cities. But that’s exactly what this report tried to do.
The audit found that the trust fund’s average subsidy per unit was $61,700—a number that doesn’t seem bad compared to the District’s median home value of more than $550,000. But the report instead compared that number to Philadelphia and Seattle’s trust funds, which the auditors determined spend only $21,190 and $36,000 per unit respectively.
Even without comparing the size of the funds being managed, these numbers don’t take into account different amounts of federal funding, different income levels being served, or the vastly different markets that they’re working in (Philadelphia’s median home value is a full $400,000 lower than DC’s). Nevertheless, that $61,700 per unit and its comparison to other cities has been presented as the end-all-be-all in determining the fund’s efficiency.
Another point that the audit and its media coverage have overblown is the state of the fund’s revolving loans. All the money that the trust fund sends out is structured as a loan, set to be repaid based on a project’s cash-flow or the expiration of its affordability covenants.
The audit notes that in the past four years, only 4% of the fund’s resources have come from loan repayment. But as the Department of Housing and Community Development’s (DHCD) Director Polly Donaldson has noted, delayed repayment is a key feature of the fund, not a flaw. Deferred loans allow smaller developers and non-profits the time they need to repay District funds. To put it another way, it’s no wonder this audit’s 15-year scope didn’t capture 40-year loans.
The revolving loans have also caused a flap with the somewhat inexplicable revelation that almost all of the fund’s long-term loans have been written off as unrecoverable. While repayment of 40-year loans on affordable housing projects may not be 100%, it’s certainly not going to be zero.
Finally, the audit causes confusion by not specifying the administrations responsible for some of its worst findings. For instance, while it’s a serious problem that DHCD had to give back $16 million in federal funds, it’s also important to note that that bungling came under a previous administration. It’s certainly not the sort of thing that should keep Councilmembers from investing more in the trust fund now. Where it shoots straight
The report is certainly helpful in some areas. It’s no secret that administrative costs for the trust fund have been too high, and the audit also points out a few instances in which small amounts of money were spent on non-housing projects, like bicycle education. Those issues are real, and they need to be addressed.
The report also points out that the trust fund hasn’t been meeting its legal requirement to spend 40% of its funds on very-low income residents, those making less than 30% of the Area Median Income. It’s an important problem to address, one that has come up frequently in Council hearings over the past few months.
The trust fund is already doing better than it seems, however, when other programs are taken into account. While trust fund income limits may not be low enough to meet requirements, those units are often cross-paired with rent supplement programs that serve residents under 30% AMI. Because those units require so much funding to produce and operate, it often requires more than one source of subsidy.
The real take-away
At the end of the day, the lede is buried, both in this post and The Washington Post. The Housing Production Trust Fund has produced or preserved more than 10,000 affordable homes over the past 15 years. That’s over 10,000 families who would otherwise almost certainly be rent burdened—if they managed to stay in DC at all.
There’s certainly room to improve the trust fund. But that improvement has to come in the context of the incredible work the fund has done and continues to do. Otherwise, this audit will cause more harm than good for the families it hopes to serve.