This article was originally published 9/30/25, and was updated 10/01/25 to reflect the most current information.
As of today, Congress has not passed the appropriate spending bills to fund the government for the next fiscal year beginning October 1, 2025. A Continuing Resolution (CR) was passed by the House of Representatives to continue funding until November 21, but this Resolution did not pass the Senate. Since there is no current CR, or other funding, the government shut down at midnight on September 30.
At Harris Affordable Housing Group, we remain committed to supporting our clients. In the event of a government shutdown, we will continue to serve you to the best of our abilities, helping all of our clients remain Exceptional HUD Business Partners.
So, what is affected in a government shutdown?
Short answer- what isn’t affected?
On October 1st, we received notice that HUD has updated their contingency plan for this year’s government shutdown. Denise Muha at NLHA has kindly provided the links to this updated document as well (Thanks Denise!).
But what does this mean for us and our clients?
The Most Immediate Effect-Obtaining Access to New Clients, Entities, and Individuals:
When we obtain access to your entities and individuals in the HUD system, we do so through HUD’s Secure Systems portal. This portal submits a request through the REAC system, which generates an Activation Key Code that is mailed to the address on file. If you have not received your letters, we then electronically submit a Direct Activation Letter to the REAC-TAC help desk. These wonderful people at the REAC-TAC help desk manually assign us to you and your entities between 24-48 hours.
The 2025 contingency plan states that the REAC offices will be closed. We can still send Direct Activation Letters to the REAC-TAC help desk, but no one will be there to process the request until the shutdown is lifted.
As of 10/01/25, we are unsure if the REAC office will still send Activation Key Code letters via USPS (which remains operational during a shutdown). If they are, we will still be able to gain access with these key codes provided that the addresses on file are up to date. If the addresses have changed, or HUD is not mailing these key codes, we will not be able to gain new access in HUD Secure Systems and will not be able to file any 2530 submissions for those entities.
This does not affect clients whose information we already have access to in HUD Secure Systems.
APPS & 2530 Processing:
Like most other offices, the HUD Field Offices and HUD Headquarters offices will be closed during the shutdown or operating with a skeleton crew. This means:
- Any 2530 submissions in review will likely remain as such. If you have a firm closing date, you can expect to close on the loan.
- Any submissions sent to HUD during the shutdown will not be reviewed.
• Once the shutdown is lifted, these submissions will take longer to process than normal due to a backlog of submissions. - We will not be able to contact either office for support.
- No REAC/NSPIRE inspections will take place unless there is reason to believe there is a threat to life or property. Any other scheduled inspections will be postponed.
- Any emergent inspections that took place before the shutdown will be reviewed by appropriate HUD staff. Non-emergent inspections will not be reviewed or released.
- Staff will be on hand to review emergent circumstances that may appear as a result of these inspections. This is likely also the case for failed inspections that took place before a shutdown that have not yet been resolved.
- Clients should continue to upload additional documents to the NSPIRE portal as required from past inspections even if there is no HUD employee available to review them. Please be aware that there will be no technical support staff available if an issue occurs.
- Clients must still submit any inspection appeals before the deadlines, but responses will be delayed.
- PBCAs will continue work as usual, and any scheduled Management Occupancy Reviews (MORs) will still take place.
SAM.gov renewals/UEI
The SAM.gov website will remain active, and we will continue to submit your SAM renewals as usual. However, if an issue arises, we may not be able to contact the Federal Service Desk for resolution.
There may also be a delay on their end for processing SAM renewals, as part of this process includes IRS verification.
Asset Management- FHA, Loans, Section 8, HAP
HUD’s 2025 contingency plans confirms that any projects with a firm commitment/firm approval letter issued before the shutdown or critical deadlines will proceed as usual. This includes Section 8, Section 202/811, and any HUD loans. HUD will also continue to make payments under Section 8 and PRAC contracts for as long as funding is available and will process renewals for expiring contracts.
- Any Section 202/811 projects currently under construction will only be able to access funds in response to issues causing imminent threat to life or related to the protection of a property. Any construction inspections will be postponed until the shutdown is lifted.
HUD will not process Section 8 or other waiver requests except for properties labeled as troubled assets. These requests will likely be delayed, as only a limited amount of staff will be on-site. For emergency requests, i.e. health and safety purposes, owners and agents should call 202-402-2855 to make the request. (These will be processed on a limited basis.)
HUD will process emergency releases from reserves for critical repairs only, and on a limited basis. These requests should be emailed to the Asset Management Division Director for your assigned HUD office.
HUD will continue to approve 9250s for release of residual receipts to offset monthly voucher requests for Section 8 payments.
The Tenant Rental Assistance Certification System (TRACS) will process vouchers as long as funds are available. The Multifamily End User Support Help Desk will be available to answer general questions regarding this system.
Clients should continue to submit their financial statements through FASS as normal but will not be able to receive assistance if there is a problem. This help desk is also under REAC-TAC.
Mark-Up-To-Market (MU2M)
Contract Administrators (CAs) will continue to process MU2Ms as usual unless they need HUD approval or authorization to continue. HUD staff will only grant approvals, waivers, or authority to proceed if the failure to do so would threaten the property.
RAD
RAD deals that are scheduled to close before the shutdown will continue as normal. Other conversions will close only if a failure to do so would threaten the property, which necessitates an immediate response, such as the threat of lost tax credits.
Applications for RAD can be submitted, but will not be reviewed during a shutdown. HUD staff will also not be able to continue RAD processing. Applications can be submitted by emailing RADApplications@hud.gov .
LIHTC Concerns
HUD staff will only close transactions involving the expiration of Low Income Housing Tax Credits (LIHTC) on an emergent basis, ie if the closing date cannot be extended, and failure to close would threaten the proposed project.
For other circumstances, please contact your development partners and investors.
Resources:
These HUD resources WILL be available during a shutdown. Websites will likely not be updated during a shutdown but can still provide helpful information:
To read the updated 2025 contingency plan, click here .
HUD/FHA Resource Center: 800-225-5342, answers@hud.gov
HUD/FHA National Servicing Center: 877-622-8525
HUD Primary Website and FAQs: www.hud.gov, www.hud.gov/answers (these websites will be available but will not be updated during a shutdown.)
HUD Multifamily Housing End User Support Help Desk will answer questions related to IREMS, TRACS, and select EIV procedures.
Grants.gov Systems: 800-518-4726, support@grants.gov
(The phone number listed in the contingency plan is not active. The above phone number is from the website www.grants.gov .)
Most available HUD staff will not be able to answer case-specific questions. If your question cannot be answered by available staff, you will have to contact the appropriate office once the shutdown is lifted. HUD staff will also not be able to respond to items sent through the mail until they return to work.
Information about USPS operations during a government shutdown can be found on their website. All other information regarding HUD’s 2025 contingency plan, unless otherwise stated, is taken directly from the document itself. Featured image by Andrew Winkler via Unsplash. This article was updated on 10/01/25 to reflect current information.
