HUD CPD issues Notice CPD-2025-01 implementing guidance for BABA Buy America Preference (BAP) and supersedes CPD-2023-12

HUD CPD issued Notice CPD-2025-01 providing updated implementation guidance for BABA’s Buy America Preference (BAP) requirements for CPD programs and superseding CPD-2023-12. The notice includes key applicability clarifications for housing/infrastructure determinations (e.g., treatment of 1–4 unit versus 5+ unit housing in relation to BAP applicability), as well as guidance on project scope, recordkeeping, and waiver processes. CPD grantees and contractors should review and align project scoping decisions, procurement documentation, and waiver requests to the updated CPD guidance.