Whole-Home Repairs Act: forgivable repair loans for small landlords, explained

Small landlords with older buildings now have a federal repair program written into law, but not yet running. Section 202 of the 21st Century ROAD to Housing Act authorizes HUD to fund local programs that make repair loans to landlords owning fewer than 10 rental properties, and those loans may be forgiven up to 3 years after the work is done if the owner keeps the loan terms. On Sept. 30, a bipartisan group of lawmakers wrote to HUD urging it to stand the program up.

The catch is the strings: unless the assisted units are rented to voucher holders, the owner takes on a rent-increase cap, lease-extension offers and an affordability requirement that run for at least three years. Here is what the statute says, who qualifies, and what to do before the money shows up.

What happened

The Whole-Home Repairs Act rode into law inside the 21st Century ROAD to Housing Act, which became law in July 2026 without the president's signature, according to Sen. John Fetterman's office. The statute authorizes a pilot program that sends HUD grants to "implementing organizations" (states, which by statute include Indian tribes, or local governments, which can work through other governments, tribal housing entities or qualified nonprofits) to run whole-home repair programs for eligible homeowners (generally earning up to 80% of area median income) and eligible small landlords. The pilot terminates on Oct. 1, 2031.

In a Sept. 30 letter, Sens. Fetterman and Cynthia Lummis and Rep. Nikema Williams asked HUD Secretary Scott Turner to establish the program through HUD's Office of Lead Hazard Control and Healthy Homes. They cited almost 7 million Americans living in homes that need significant repair and asked for a staff meeting on how HUD plans to use appropriated funds. Realtor.com covered the push on Oct. 9. We have not found a HUD funding notice for the program yet.

Key points from the statute text:

• Who counts as a small landlord. An individual who owns, directly or through a spouse, dependent children or a closely held entity they control, fewer than 10 eligible rental properties, operated as primary residences, with a majority of affordable units and no more than 25 total units, as determined by the implementing organization.
• What "affordable" means. Rent of no more than 30% of the gross income of someone earning at or below 80% of area median income, as HUD defines it.
• What it pays for. Accessibility modifications, habitability and safety repairs, and energy, water and weatherization work that other federal repair programs do not cover. Landlord loans can fund affordable units, common areas and shared structural elements, up to per-unit maximums HUD approves based on local construction costs.
• How the money flows. In any year it makes awards, HUD funds 2 to 10 implementing organizations, no more than one per state, "as application numbers and funding permit." Landlords would apply to the local administrator, not to HUD.

Why it matters for property managers

The loan agreement is where the cost sits. For each property that gets a loan, the statute requires the owner to comply with federal accessibility rules, including Section 504. Then the terms split:

• If the assisted units are rented to tenants with Housing Choice Vouchers or another tenant-based subsidy, the owner follows that program's rules.
• If not, the owner must offer current tenants lease extensions on current terms for at least 3 years after the repairs (with exceptions for nonpayment, an illegal act in the unit, or an uncorrected violation after notice); keep a unit affordable for the rest of the 3-year period if a tenant moves out; document that the property meets state and local codes; attest to no known serious violations of renter protections that led to fines, penalties or judgments in the past 10 years; and cap annual rent increases on each assisted unit at 5% of base rent or inflation, whichever is lower, for at least 3 years.

The loan is secured by a recorded lien. Forgiveness is not automatic: the implementing organization may forgive it, and only if you stayed in compliance. If repairs are not finished and the scope is not updated, the statute calls for prorated repayment based on completed work. The statute also treats assisted rental properties as projects assisted under title I of the Housing and Community Development Act of 1974, the law behind the CDBG program, so ask the local administrator which federal requirements come with that.

Is it worth it? On a building whose rents already sit below the 80% AMI line, a three-year cap at the lower of 5% or inflation may cost little compared with a forgiven roof, electrical panel or HVAC replacement. On a unit you planned to push to market at renewal, the math changes. Run it unit by unit.

The need is real. The Philadelphia Fed estimates it would cost $198.4 billion to fix repair needs in occupied U.S. housing in 2024, and its brief says renters and multifamily residents are disproportionately likely to report cooling repair needs. HUD data cited by Realtor.com found units renting for under $500 a month were about four times as likely to be permanently lost from the housing stock as units renting for $1,500 or more. For owners of older, lower-rent buildings, deferred capital work is the risk this program targets.

What to do this week

1. Check whether you qualify on paper. Count properties and units across every entity you, a spouse or dependent children control. The test is fewer than 10 eligible rental properties and no more than 25 units, with a majority affordable.
2. Map rents against your area's 80% AMI. Use HUD's income limits for your county and the 30%-of-income test to flag which units already meet the affordable-unit definition, and which would need a rent change.
3. Build a deferred-repair list now. Price roofs, wiring, plumbing, accessibility and weatherization items, with photos and contractor quotes. A documented scope of work will make any application faster to complete.
4. Ask your state housing agency or city housing department whether it plans to apply to HUD as an implementing organization. Pennsylvania already ran a state version that, per Fetterman's office, helped homeowners and small landlords make repairs.
5. Pull your compliance history. The 10-year attestation covers serious renter-protection violations that led to fines, penalties or judgments. Know what is on the record before you sign anything.
6. Model the 3-year cap. For each candidate unit, compare projected rent with and without a cap at the lower of 5% or inflation against the repair cost you would avoid. Have your attorney review lien and lease-extension terms against your state's landlord-tenant law.

What we're watching

• Funding. The statute funds grants from appropriated money, and the lawmakers' letter asks HUD how it will use appropriated funds. Watch for a HUD notice of funding opportunity from the Office of Lead Hazard Control and Healthy Homes.
• Per-unit maximums. HUD has to calculate and approve the caps on landlord loans. Those numbers decide whether the program covers a roof or a water heater.
• Which states apply. With no more than one award per state per year, early applicants will set the pattern. The pilot runs only until Oct. 1, 2031.

This is general information, not legal or financial advice. Program terms will depend on HUD's rules and your local administrator's loan agreement; confirm with local counsel before committing a property.