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Q&A

CM Brewer Q&A: Mangin on HDFCs and on-site vs off-site affordable housing

New York City Council · Sep 1, 2026 · starts 3:18:20 · 4 min 9 sec

Brewer asks about HDFCs and BSA's role. Mangin explains HDFCs are the vehicle for publicly sponsored affordable housing and the BSA Fast Track requires HDFC status. Brewer then presses on on-site vs off-site affordable units, arguing off-site in Manhattan sends poor people to lower-income areas. Mangin notes City of Yes shifted to primarily on-site requirements.

Shaun Abreu

HDFCs, I think we talked about them a little bit.

Shaun Abreu

How do you at all figure into what BSA does or will do?

Shaun Abreu

And HDFCs, if at all.

John Mangin

Thank you for the question.

John Mangin

So HDFCs, or Housing Development Fund companies, those are the state laws.

Shaun Abreu

I was there when they started with Phillips St.

Shaun Abreu

George.

Shaun Abreu

I know what they are.

John Mangin

Right.

John Mangin

So, you know, you and I, when we hear HDFCs,

John Mangin

We may think most immediately of limited equity co-ops in places like the Upper West Side or Lower East Side where I live or North Brooklyn or Northern Manhattan.

John Mangin

HDFCs are actually a much broader category, however.

John Mangin

that encompasses basically all newly created affordable housing, whether it's rental or homeownership.

John Mangin

In order to qualify for the BSA Fast Track for Affordable Housing, you have to be an HDFC.

John Mangin

That's, again, the vehicle for publicly sponsored affordable housing.

John Mangin

That requirement in the BSA Fast Track ensures that only projects under public control can go through that process as opposed to a formal rezoning.

Shaun Abreu

Okay.

Shaun Abreu

Off-site, on-site.

Shaun Abreu

Now, we've had a lot of discussions today about community-based agreements, CBAs.

Shaun Abreu

The question I have is, when you have a situation with a developer who's building, do you support only on-site in terms of his contribution of affordable housing, or do you support off-site?

Shaun Abreu

This is a big issue right now in Community Board No.

Shaun Abreu

7.

Shaun Abreu

My position is very clear, but I want to hear yours.

John Mangin

Thank you for the question.

John Mangin

I mean, I've had a hand in creating various citywide affordable housing programs over the years, starting with MIH.

John Mangin

MIH does include an off-site option.

John Mangin

It was seen as crucial to provide as many compliance opportunities as we could in the context of a mandatory program to make sure that we were creating affordable housing and enabling housing to be produced.

John Mangin

While avoiding any kind of legal

John Mangin

More recently, we created universal affordability preference as part of City of Yes for Housing Opportunity.

John Mangin

In that, we shifted towards a primarily on-site program.

John Mangin

In order to comply with universal affordability preference, you need to have your affordable units on the same zoning lot.

John Mangin

With the limited exception of if you had an off-site option before under the old inclusionary housing programs, then you retained an off-site option.

John Mangin

We didn't want to take that away from folks.

John Mangin

But in the main, that shift in housing policy away from a program with an off-site option towards one that's

John Mangin

you know, overwhelmingly on site is in line, it sounds like, with your views on the matter.

Shaun Abreu

Okay, I mean, I support on-site because I think otherwise you're supporting basically a racist agenda in the sense that you're sending the poor people elsewhere and letting the rich people be in one location.

Shaun Abreu

That's a Manhattan situation.

Shaun Abreu

Because, so I would like to hear people say on-site only is the way to go.

John Mangin

Just to add, if I may, when off-site options are available, there is a geographic nexus within a half mile or the same community district.

John Mangin

I know, but it's not.

John Mangin

So that you can't ship your affordable units, you know, to some distant land.

Shaun Abreu

But in Manhattan, that ends up being in a lower income community 100% of the time.

Shaun Abreu

I've seen it 100% of the time.

Shaun Abreu

So even though half a mile sounds like not so far, it actually is a different location.

Shaun Abreu

So you're still supporting.

Shaun Abreu

off-site if necessary.

Shaun Abreu

Is that what you're saying?

John Mangin

Well, as I mentioned, we've shifted away from, you know, MIH model towards UAP, which is overwhelmingly an on-site.

Shaun Abreu

Would this come up at all at a BSA situation, this type of situation?

John Mangin

I can't imagine offhand a situation where it would, but I can't answer definitively.

Shaun Abreu

All right.

Shaun Abreu

Thank you.

John Mangin

Thank you, Council Member.

Sandra Ung

Okay, thank you.