Detailed Information on the
Capacity Building for Community Development and Affordable Housing Assessment

Developing long-term outcome measures to better capture the effect investments have on communities and neighborhood quality. HUD will work with the intermediaries to develop indicators that measure the change in the condition of neighborhoods in which the CDCs operate.

Developing a program summary, accompanying website links to Section 4 and program performance information on the HUD website to make program information available to the public.

HUD will include at least one long-term performance measure for NCDI as part of its Annual Performance Plan and Reports.

Measure: Number of homes renovated, preserved or newly constructed

Explanation:Number of homes renovated, preserved, or newly constructed by CDCs and CHDOs as a result of the capacity building efforts of organizations funded under the Section 4 program.

Measure: Number of trainings created and provided to CDCs and CHDOs.

Explanation:Number of trainings created and provided to CDCs and CHDOs by organizations funded under the Section 4 program.

Measure: Total development cost estimate of community development projects funded by CDCs and CHDOs in millions of dollars (shows increased capacity of CDC and CHDO industry).

Explanation:Dollars spent on community development projects funded by CDCs and CHDOs. CDCs and CHDOs show increased capacity as a result of the efforts of organizations funded under the Section 4 program. Capacity may be built by subgrants, trainings, or other activities approved by HUD. Increased outputs by CDCs and CHDOs show successful outcomes of the Section 4 program.

Measure: Amount of capacity building money provided to organizations necessary to produce, renovate, or preserve a unit of housing will remain consistent.

Explanation:The program expects the cost of capacity building efforts to remain consistent and HUD's efforts will focus on maintaining capacity building levels. Variation could occur, however, due to grantee participation and available appropriations.

Is the program purpose clear?

Explanation: The purpose of the program is to strengthen the capacity of community-based organizations engaged in community development activities with operating support, training, technical assistance and project financing provided through experienced national intermediary organizations that must match every federal dollar they receive with at least three dollars of private funding.

Evidence: NCDI was formed in 1991 by eight private foundations and financial institutions. The initiative, currently in its second decade, was established with the stated goals of 1) assisting in the development and maturation of local systems that support community development; and 2) increasing the availability of usable long term financing for community development corporation (CDC) developed projects. Congress directed HUD to join the initiative in 1994 for Round 2. The program was enacted as Section 4 of the 'HUD Demonstration Act of 1993' (P.L. 103-120) and amended in the fiscal year 1997 'Emergency Supplemental Appropriations Act' (P.L. 105-18.).

Does the program address a specific and existing problem, interest, or need?

Explanation: There is a clear and present need to have effective organizations that foster sustainable community development in low-income neighborhoods. Many urban and rural communities are distressed and in need of revitalization. The federal government has long recognized the vital role that community based organizations, including faith-based groups play in strengthening low-income families and communities. The Section 4 program addresses this specific need, by strengthening locally accountable community development corporations (CDCs) to address immediate and ongoing neighborhood revitalization goals in low-income communities. In addition, the Section 4 program effectively mobilizes private sector involvement, leveraging private resources at a ratio of at least three to one, and by ensuring that CDCs effectively utilize other federal production programs, such as HOME, CDBG, Low Income Housing Tax Credits, etc.

Evidence: Researchers have noted challenges in urban centers and rural areas including market disinvestment, lack of housing and housing affordability, concentrations of poverty in many neighborhoods, etc. In 2000, 7.9 million persons lived in high poverty-areas (census tracts with poverty rates above 40 percent), of which 3.5 million were poor. Persons living within poverty areas, compared to persons outside, are more than twice as likely to be unemployed, nearly twice as likely to have female householder, three times as likely to have a household with seven or more members, less than half as likely to have a bachelors's degree, twice as likely to be suffering from health condition for 6 months, and earn 2/3 as much income. Thus, neighborhood quality plays an important role in positive outcomes of families. Replacing or upgrading distressed properties is a precondition for neighborhood revitalization and public investment in housing often triggers private investment that ultimately improves quality of life and increases economic opportunity.

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: While possessing some unique qualities such as a steady funding stream, HUD's contribution to the initiative duplicates private contributions. Several other HUD programs and funders provide resources for capacity building through NCDI and otherwise. The Urban and Rural Community Economic Development program also provides competitive grants to CDCs, for projects that create employment, training and business opportunities for low-income residents. Private organizations also provide funding for these activities.

Evidence: The Section 4 program emerged from a partnership ' the National Community Development Initiative (NCDI) ' that is a consortium of national foundations, corporations and financial institutions and HUD (now known as Living Cities/NCDI). Other HUD programs that provide capacity building funds include: Housing Assistance Council, Rural Housing Capacity Building, HOPWA, Resident Opportunity and Self Sufficiency, Fair Housing Assistance/Initiative Program, Mark to Market, and Lead-Based Paint Initiative. CDBG and HOME funds can also be used for this purpose. However, the Section 4 program is unique in its sole focus on strengthening community capacity to undertake specific activities such as economic development, job generation, and affordable housing within a broader and long-term community strategy, while requiring substantial private matching funds.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The program design is free of major flaws. Several independent evaluations have indicated that this program is effective in strengthening the capacity of community-based organizations and achieving significant leverage of private resources -- both requirements of the program.

Evidence: Independent evaluations completed by The Urban Institute and Weinheimer & Associates have demonstrated the program's efficiency and effectiveness. The program has mobilized resources for formal operating support programs or funder collaboratives. Across the NCDI cities, the number of operating support programs grew from 8 to 21 from 1991-2001. The Urban Institute found that these operating support programs attracted new funders and instituted more rigorous planning protocols and performance measures in order for CDCs to obtain funding. On average NCDI funds, (inclusive of private and Section 4 funds) supplied only 37 percent of funds pooled in local operating support programs with nearly two-thirds leveraged from local funders. NCDI funds also filled gaps in the local production system. The number of CDCs able to produce 10 units or more annually and considered to have solid local reputations for effective management, governance and ties to the neighborhood as measured in NCDI cities increased from 4.5 to 8.3 per city from 1990 to 1998.

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: The program design ensures efficient administration, significant private funding leverage and sustained community-based capacity in assisting hundreds of small organizations with disparate needs serving hundreds of communities facing widely varying conditions. Section 4 NCDI funds are targeted to a finite number of urban and rural communities where Local Initiatives Support Corporation (LISC) and Enterprise have local expertise and a sustained effort is possible.

Evidence: The Enterprise Foundation and LISC have been the primary national intermediaries working to building capacity in the nonprofit industry in urban communities since 1982, 12 years prior to the creation of the Section 4 program. The intermediaries that administer the program provide funds directly to community-based groups, primarily for organizational development support of various kinds. The remaining funds pay for the delivery of training and technical assistance to community development corporations by intermediary staff and outside service providers, another explicit statutory purpose of the program. The intermediaries provide most funding through local and regional offices around the country whose staff are in regular contact with the organizations, assuring strong program oversight and quality control ' ensuring that funds are most effectively used for their intended purposes.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program's long term measures of performance focus on the program's purpose of increasing the capacity of CDCs. HUD will also work with the intermediaries to develop indicators that measure the change in the condition of neighborhoods in which the CDCs operate.

Evidence: Current long-term measures focus on the following priorities: (1) to improve the overall capacity of CDCs; (2) to improve CDCs' ability to produce tangible project results (e.g., units, square footage of nonresidential space); (3) to strengthen community development systems in local areas; and (4) to engage the private sector at the national and local levels to participate in community development. Main measure focuses on number of CDCs per city that are able to produce more than 10 houses. HUD should work with LISC and Enterprise develop quantitative measures of performance that demonstrate the program's impact on the community or lives of persons assisted by organizations. For example, a recent analysis showed that housing price trends increased in five urban neighborhood studied and that "policy interventions of the sort represented by CDCs' community developments can produce real results that are scientifically measurable."

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: NCDI lacks targets for its long-term measures; however, LISC and the Enterprise Foundation have developed sustained three-to-four year strategies and work plans for each grantee that include performance indicators as well as baselines and annual targets to measure progress.

Evidence: HUD reviews and approves these work plans. Measures are designed with annual benchmarks that measure progress and serve as an evaluative tool for any mid-course correction. The intermediaries provide most funding through local and regional offices and have developed customized strategies and performance measures for each local field program that receives Section 4 funding.

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: The intermediaries, LISC and Enterprise, ensure that sub-grantees' work plans establish specific objectives and outcomes and submit annual reports to the intermediaries on their usage of funds as well as a final report at the end of the grant term. HUD receives quarterly and annual updates that correspond to measures listed.

Evidence: Annual measures should focus on steps intermediaries and CDCs are taking to improve capacity of organizations. For example, dollars leveraged, total development costs, and other outputs are useful measures of progress toward improving the capacity of CDCs--the primary mission of Section 4.

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: Baselines and benchmarks have been produced by each field office of LISC and Enterprise receiving Section 4 funds under NCDI. HUD receives annual reports on progress toward these benchmarks.

Evidence: See response to 2.3.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Enterprise and LISC work plans explicitly reflect discussions with and commitments by local private and public sector partners. The program allows intermediary recipients to establish goals for their specific uses of funds, within the parameters of the law, in accordance with local needs and conditions and subject to HUD review and approval. This flexibility is a key component of the program's success. Grantees, sub-grantees, contractors and other parties to the program grant agreements perform work in support of specified work plan objectives that have been approved by HUD pursuant to the program goals.

Evidence: One of the most innovative and effective partnerships the program has helped build are local 'operating support collaboratives.' These collaboratives, which exist in dozens of cities where the program is most widely utilized, pool public and private resources to support community-based groups. The collaboratives also provide a mechanism for assessing and enhancing community group capacity, developing appropriate goals and outcomes and building strong and enduring local support for grassroots groups and their community development activities.

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The program has been and continues to be the subject of extensive independent evaluations, all of which to date have shown a high degree of efficiency and effectiveness. A report to Congress in 1998 that found the program highly effective.

Evidence: Evaluations have been performed by the Urban Institute and Weinheimer & Associates. Metis Associates is conducting continuing evaluations of a major aspect of the program, using standardized tools that could prove applicable across the entire program and throughout the community development field. Previous assessments of the Section 4 and NCDI program completed by the Urban Institute and Weinheimer & Associates found that HUD Section 4 funds were invested well and wisely - particularly structured through this program that increases the scale of the projects to be undertaken, as well as accelerates the completion of projects.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: This program meets several of HUD's strategic goals: increase homeownership opportunities; promote decent, affordable housing; strengthen communities; and promote participation of faith-based and community organizations.

Evidence: As noted in 2.1, LISC and the Enterprise Foundation set appropriate program priorities which support several objectives in HUD's Annual Performance Plan for FY 2004 including (1) Objective FC.2: conduct outreach to inform potential partners of HUD opportunities; (2) Objective FC.3: expand technical assistance resources deployed to faith-based and community organizations; (3) encourage partnerships between faith-based and community organizations and HUD's traditional grantees; (4) Objective C.1: provide capital and resources to improve economic conditions in distressed communities; (5) Objective C.2: help organizations access the resources they need to make their communities more livable; (6) Objective C.4: mitigate housing conditions that threaten health.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: Weinheimer's report noted several shortcomings, which the intermediaries have taken steps to address: 1) Section 4 work plans were narrowly drafted and could not assess whether important gaps were addressed; 2) lacked assessment of local CDC capacities; 3) work plans did not facilitate peer learning and knowledge sharing; 4) intermediaries should concentrate Section 4 in fewer program areas, but in multiple CDCs within program areas; and 5) intermediaries should assure that it works with local partners who work with CDCs. The intermediaries have addressed these shortcomings as noted in Evidence/Data column.

Evidence: HUD and intermediaries have responded to these deficiencies with the following: 1) NCDI sites go through a rigorous assessment called 'City Portraits,' which comprehensively looked at the capacity of CDCs and the local system, to develop strategies to address identified needs; 2) LISC has developed CapMap, a diagnostic tool that assesses CDCs in nine core areas of operations (e.g., human resources, asset management, board governance, information systems, etc.) and measures growth along a continuum of organizational development. Enterprise Foundation applies a similar tool in its cities operating collaboratives; 3) Enterprise has tapped is Network Advisory Committee, a nonprofit advisory board comprised of mature CDCs, to identify the most pressing issues facing the larger, more complex nonprofits; 4) the intermediaries are located in 55 sites and in rural areas; and 5) 75 percent of all Section 4 funds are allocated as pass through grants to CDCs to help them strengthen their organizational capacity.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: HUD collects performance information from LISC and the Enterprise Foundation at regular intervals.

Evidence: First, LISC and Enterprise submit to HUD work plans outlining specific measurable outcomes that will be achieved with the funding during the period. Second, several levels of reporting are submitted by the intermediaries. This is also an opportunity for the intermediaries to report challenges that may arise and indicate steps that they are taking to address them. LISC and Enterprise report annually on progress toward annual targets and outcomes. The intermediaries also report to HUD on its compliance with the program's private funding matching requirement on a quarterly basis. Finally, the intermediaries invoice HUD monthly for reimbursement of costs incurred. The invoices include detailed information on the activities being invoiced with discussion on their progress against goals.

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: There are several processes by which HUD ensures accountability in cost schedule and performance results. See Evidence/Data column.

Evidence: Program funds only flow to reimburse either the intermediaries or their sub-grantees for eligible costs already incurred. HUD requires the intermediaries to verify that all costs are consistent with HUD approved work plans and federal spending requirements. HUD also requires the intermediaries to receive regular financial reports from sub-grantees (quarterly or monthly depending on the disbursement schedule contained in each grant agreement) that the intermediaries and HUD both review for appropriateness and eligibility. In addition, HUD requires the intermediaries to provide quarterly and annual reports to HUD on their and their sub-grantees' progress towards achieving the performance outcomes identified in their annual plans for utilizing funds.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: HUD ensures that LISC and the Enterprise Foundation obligate federal funds in a timely manner and spend them for the intended purposes within the contract period. The intermediaries achieve this goal by working with each of their regional offices to create specific work plans (which are reviewed and approved by HUD) delineating proposed program service delivery methods to be achieved within the period, and outlining the budgets with proposed spending for the year.

Evidence: There are no unobligated funds or carryover balances for Section 4/NCDI. All funds are obligated in the year of appropriation. Program funds only flow to reimburse either the intermediaries or their sub-grantees for eligible costs already incurred. LISC and Enterprise track and report on program performance progress through quarterly and annual reports to HUD; they track spending through compliance reports and submit eligible, appropriate expenditures to HUD for reimbursement.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: LISC and Enterprise Foundation have implemented IT system upgrades to improve the management of program funds and ensure consistently monitoring for future improvements. While the program does not currently measure gains resulting from IT upgrades, they have procedures to measure and achieve efficiency in program execution.

Evidence: Many of the awards to CDC's have go through a competitive process. Those awards made not using procurement procedures are subject to internal allocation processes that consider programmatic impact and specific outcomes to be achieved. Progress against these detailed work plans are monitored by the intermediaries and reported back to HUD.

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program's three-to-one match requirement mandates combination of program funds with private resources from many sources, which substantially increases the program's impact and effectiveness. One of the program's primary purposes is to ensure that community-based groups can effectively access and utilize the widest feasible range of public and private support for their activities. The program's statutory purpose and regulatory flexibility enable community-based groups to use it effectively in collaboration with other capacity building, training and technical assistance programs, as well as programs to fund particular projects, such as an affordable housing development or day care center.

Evidence: Community-based groups that receive assistance under the program utilize numerous federal state and local program and access private financing from a broad range of organizations. Program leverage occurs through local funding collaboratives, described earlier. Community-based sub-grantees are major users of HOME and CDBG funds and Low Income Housing Tax Credits, among many other federal, state and local community development programs. They must compete at the state and local level for the majority of these resources. CDCs increased their total amount of funding available for/expended for development costs from $400 million to $800 million from 1991 to 2001. The Weinheimer report concluded that Section 4 grant funds leveraged private funds at more the 7:1, far exceeding the 3:1 match required by Congress.

Does the program use strong financial management practices?

Explanation: Intermediary fund recipients have strong financial management and auditing procedures in place to appropriately administer these funds.

Evidence: HUD releases money on these grants on a cost reimbursable basis. Vouchers for funds are accompanied by detailed evidence of expenditures. HUD reviews the vouchers for eligibility, appropriateness, and progress toward goals. Only then is money released to the grantees. Both LISC and Enterprise have strong Finance/Accounting departments, and receive annual A-133 and Financial audits. Both organizations ensure compliance with federal OMB Circulars and other federal and contract regulations; both prepare regular financial reports tracking: the spending of government funds; both submit regular reports to HUD for reimbursement of funds expended appropriately. LISC and Enterprise likewise closely manage the administration of funds by sub-grantees.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: Neither of the grantees, LISC and the Enterprise Foundation, has had any management deficiencies identified in audits or in the 2002 GAO audit of HUD technical assistance programs. The intermediaries, working with HUD, have ensured that internal and external systems are in place for evaluating program management and correcting any deficiencies identified.

Evidence: Both LISC and the Enterprise Foundation have effective internal systems in place to evaluate sub-recipients use of these funds, including regular reporting on the achievement of performance goals, monthly/quarterly financial reporting, and site visits to community development corporations. Externally, while both organizations receive regular single audits (for which there have been no findings), there have also been several independent reviews of the Section 4 and NCDI programs as a whole. To date, 16 groups have been defunded. Also see response for Q 2.8.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: HUD is involved as an oversight agency in monitoring grantee activities. HUD works very closely with LISC and the Enterprise Foundation to ensure program compliance. In cities where Enterprise and LISC have local offices, every CDC has at least one site visit annually, to evaluate the strength of CDCs' infrastructures and their ability to provide the planned development activities. LISC and Enterprise require that all funded CDCs have independent organizational audits and/or A-133 audits completed annually. Through the subrecipient monitoring process, CDCs are formally notified of any audit findings and given corrective action recommendations. CDC findings and the status of corrective action are taken into account when reviewing any future funding requests.

Evidence: HUD ensures that LISC and the Enterprise Foundation perform the following: a) develop and submit work plans for review outlining all program outcomes to be achieved during the period, as well as the plan for achieving them; b) submit regular reports - quarterly and annually - documenting program performance in achieving the outcomes outlined in the work plans; c) submit regular financial reports - drawdowns - delineating exactly how program funds were spent (for reimbursement on funding that LISC/Enterprise have advanced to CDCs); d) conduct site visits to each of the sub-grantee sites during the period to ensure that the program activities are being carried out as planned, and to provide on-site technical assistance; e) provide regular training and support to build CDC capacity so that program funds are more efficiently utilized in the communities being served.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: LISC and the Enterprise Foundation report annually to HUD on the performance of Section 4; however, this information is not made available to the public in a detailed manner.

Evidence: HUD, LISC, and Enterprise should determine ways to make aggregated or local performance information available to the public. Evaluation reports by Living Cities/NCDI and the Urban Institute are available on their public websites, www.livingcities.org and www.urban.org.

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: Evaluations of the Section 4 program have demonstrated progress toward the program's long term goals. These reports have noted notable improvement in community development systems as a result of Section 4 and HUD's participation in NCDI. HUD has also begun to work with stakeholders to develop a framework to better assess its technical assistance programs.

Evidence: NCDI demonstrated success in several areas relating to increasing the organizational capacity of CDCs. For example, the number of top tiered CDCs with strong reputations for efficient production, governance and management grew from 100 to 184 from 1990 to 1998. Furthermore, capable CDCs (those able to produce more than 10 units of housing per year) doubled in the 1990s. Total development costs also doubled from 1991 to 2001. Support systems for capacity building improved most significantly as Section 4 and NCDI funds capitalized performance-based operating support collaboratives.

Does the program (including program partners) achieve its annual performance goals?

Explanation: The initiative met or exceeded most of its targets and collaboratives leveraged significant local financial support as well as stronger leadership for community development.

Evidence: NCDI aggregates the indicators listed in each cities' work plan to represent their annual performance goals and results. See measures tab.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: While demonstrating improved efficiencies over time is not a primary focus of the program, LISC, Enterprise and HUD should work to develop efficiency measures to monitor progress (e.g., cost per unit measures). NCDI support should increases the capacity of community development corporations to expand the scale of, and accelerate the rate of, lasting project outcomes in low income communities. However, there are no measures in place to document improved efficiencies over time.

Evidence: With a rather flat Federal investment, NCDI funding has grown in each round. In 1991, the initial round of NCDI was funded at $62.86 million in grants and loans from 8 private foundations and financial institution. HUD joined NCDI in 1994 for Round II and the private partners (now numbering ten) increase their share to $67.65 million in grants and loans. For Round III, the private NCDI partners increase their participation, raising $87 million in grants and loans from 15 foundations, corporations and financial institutions. Finally, in the current phase of NCDI, the private partners again raised their stake, to $96.7 million in grants and loans from 16 foundations, corporations and financial institutions.

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: The LISC and Enterprise Foundation NCDI programs are not comparable to other government programs as they are subject to the oversight and monitoring of HUD and the other funders through Living Cities/NCDI. The Section 4/NCDI programs have been the subject of intensive, independent analyses and evaluations by institutions such as The Urban Institute and GAO.

Evidence: Few comparisons have been made among capacity building programs, but several components such as high leveraging ratio, involvement of private sector, and the ability of the intermediaries to increase capacity of CDCs compare favorably to other programs. The Section 4 program is unlike other HUD programs in that it is a Congressionally designated grant to a few specified grantees. The program requires a three for one match. The program is cost reimbursable and funds are released for only appropriate eligible expenditures.

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: The evaluations by the Urban Institute, Weinheimer & Associates, and Metis Associates currently are sufficient in scope and independence to provide a measured and responsible review of program effectiveness and efficiency. The completed evaluations by the Urban Institute and Weinheimer & Associates have found the program to be efficient and effective at achieving both its short-term and long-term goals. In addition, a recent GAO report (September, 2003) found that "lenders and funders indicated that Section 4 funding had both a psychological and a real impact on private sector involvement in the initiative...and... have leveraged nearly $800 million in cash and in-kind contributions from the private sector."

Evidence: The Urban Institute found that community group strength, production and local support systems in many cities have grown significantly as a result of Enterprise and LISC's support with program funds, supplemented by private resources. As a result, community-based groups 'in many cities are now the most productive developers of affordable housing, outstripping private developers and public housing agencies,' according to the Institute. According to a report by Weinheimer & Associates for HUD on Enterprise and LISC's use of Section 4 funds in urban as well as nearly 120 rural areas, 'by and large the Section 4 program met and exceeded the goal established by Congress to develop the capacity of community development corporations [CDCs] to undertake community development and affordable housing projects and programs.'