Green and Resilient Retrofit Program (GRRP) - Leading Edge grants and loans

Green and Resilient Retrofit Program (GRRP) - Leading Edge grants and loans is sponsored by U.S. Department of Housing and Urban Development (HUD). The GRRP provides funding for direct loans and grants to improve energy and water efficiency, reduce climate pollution, and generate renewable energy in eligible HUD-assisted multifamily properties. It also supports benchmarking at assisted properties.

Nelson Mullins - HUD Makes Significant Changes to the Green Resilient Retrofit Program Effective March 2026 Affordable and Workforce Housing Cybersecurity & Data Privacy Environmental, Health & Safety Government Contracts & Grants Real Estate Capital Markets Bankruptcy, Creditors' Rights & Restructuring E-Discovery & Information Governance Environmental Enforcement & Litigation International Arbitration Securities and Corporate Governance White Collar Defense & Government Investigations Intellectual Property Litigation Patent Counseling and Procurement Government Relations Strategies Advertising, Marketing, Sponsorship & Promotions Aerospace, Defense, and National Security Automobiles & Other Motor Vehicles Banking & Financial Services Banking & Financial Services Construction and Construction Transactions Consumer Products & Retail Family Office Transactions Hospitality, Leisure & Travel Life Sciences, Pharmaceuticals & Medical Devices Private Clubs, Branded Residences & Hospitality Technology and Commercial Transactions Nelson Mullins’ Affordable Housing News HUD Makes Significant Changes to the Green Resilient Retrofit Program Effective March 2026 The U.S. Department of Housing and Urban Development (HUD) announced significant changes to the Green Resilient Retrofit Program (GRRP) on January 26, 2026 in Notice-H-2026-01 (the “Notice”).

For those awardees who did not close prior to March 1, 2026, the changes found in the Notice will have immediate and substantial impact on their award.

The prior requirement for reduction and measuring of greenhouse gas emissions and using materials that reduce Embodied Carbon (i.e., greenhouse gas emissions from the mining, manufacturing, and transportation of building materials due to the energy-intensive processes for extracting raw materials and converting them into the end product and materials with high carbon storage capacity) have been removed to focus on “streamlining and cost-saving measures” with focus on energy and water efficiency, and the mitigation of casualty risk and disruption caused by natural disasters and severe storms.

Under the prior notices, the owner had the option to select the form of the GRRP award - grant or surplus cash loan. All Comprehensive Awards must now be in the form of a surplus cash loan. Owners that originally elected to receive their Comprehensive Award in the form of a grant will be required to execute an amendment to the Award Letter to modify the form.

For Leading Edge Awards, if the owner selected the award to be in the form of a grant, the owner will need to execute an amendment to modify the award letter changing the form to a surplus cash loan, unless a Leading Edge Transaction Plan (described in Section 4.

4 of the Notice) or Leading Edge Closing Package containing draft documents to implement the Leading Edge Award and such other materials required by HUD were submitted, or the award already closed. The Notice requires that all Elements Awards recipients that have not reached closing or submitted its closing package prior to March 1, 2026 be in the form of a surplus cash loan.

For any award that the form of the award must be changed from a grant to a surplus cash loan, the owner will be required to amend the award letter or have its award subject to termination. For awards that have not yet achieved closing, GRRP funds cannot “directly pay for installation of any Electric Vehicle Chargers or photovoltaic systems that convert sunlight to electricity.

” The prior notices had a prohibition on the use of GRRP funds for the “purchase, repair, or upgrade of any in-unit fossil fuel combustion applications or equipment. ” This prohibition was struck. Comprehensive Award Specific Changes The owner will be responsible for procuring the required assessments, as HUD will no longer engage the Multifamily Assessment Contractors.

The assessments will no longer require a Renewable Energy Assessment or Climate Resilience Assessment. The Climate Resilience Assessment was replaced by a Risk Mitigation Assessment that “evaluat[es] the Property’s exposure to and risk from extreme weather or other natural disaster hazards.

” The owner must additionally “prepare the Scope of Work for review and approval by HUD no later than” October 1, 2026, unless HUD approves of a good cause exemption. HUD will review the Scope of Work and, once acceptable, “will issue an Approval Letter setting forth the approved Scope of Work and allocation of GRRP Funding.

” GRRP Affordability Period for Comprehensive Award properties will be the later of “the term of the Surplus Cash Mortgage or five (5) years beyond any existing use restriction regarding affordability running in favor of HUD”.

The term of any Surplus Cash Loan shall be requested by the [o]wner and shall be either (i) of the date which is six-months after the maturity of any first lien mortgage financing or (ii) up to 30 years following the Closing. ” In light of the changes in the Notice, project owners will need to assess the impact on the scope of the project taking into consideration the financial structure and/or compliance requirements.

Early legal and financial review may help address potential risks and preserve the viability of affected awards. Affordable and Workforce Housing Please keep in mind that merely contacting Nelson Mullins Riley & Scarborough LLP will not establish an attorney-client relationship.

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