Cody Bannon

Washington, DC Office

Cody’s practice focuses on all aspects of affordable housing development and finance. Cody represents public housing authorities, non-profit developers, for-profit developers and property owners and purchasers engaged in complex affordable housing transactions using mixed-finance resources, Section 8 Project Based Vouchers, tax-exempt bonds, conventional financing, Low Income Housing Tax Credits, Choice Neighborhoods Implementation Grant funds, HUD public housing funds and other federal and state affordable housing resources. In addition, Cody advises on a wide variety of regulatory and compliance matters.

Selected Recent Transactions

  • Closed on the conversion of more than 7,000 units of public housing to Section 8 assistance under the HUD Rental Assistance Demonstration (RAD) program.
  • Closed three phases of RAD conversions, including 556 units, for an Ohio housing authority undertaking self-development and utilizing complex financing, including: public housing capital funds, tax-exempt bonds, low income housing tax credits, Ohio Housing Finance Agency Housing Development Assistance Program (HDAP) funds, multiple equity bridge loans, National Housing Trust Funds, FHA financing and Capital Magnet Funds.
  • Closed the first two phases of an ongoing multi-phase redevelopment effort for a housing authority in California, with public and private financing in excess of $137 million, which includes substantial infrastructure improvements, public and private parks, and RAD and Project-Based Voucher replacement units.
  • Represented a New York housing authority in the disposition of two projects comprising 720 units and related community space pursuant to 2 C.F.R. part 200, the conversion of public housing units to Section 8 Project-Based Vouchers and rehabilitation with a $170 million development budget.
  • Converted the entire public housing portfolio of a Tennessee housing authority to Section 8 Project Based Rental Assistance under RAD in more than 15 individual conversion transactions, including one scattered-site transaction of 368 units spread across 198 sites.t
  • Closed seven transactions under the Mixed-Finance and/or Choice Neighborhoods Initiative programs with financing including: low-income housing tax credits, tax-exempt bonds, public housing funds and other city and state funds.
  • Successfully represented clients in HUD-assisted affordable housing development transactions across the country, including in Ohio, New Jersey, New York, Virginia, Alabama, Florida, Vermont, California, Texas, Colorado and Indiana.
  • Provided legal assistance to housing authorities related to organizational governance, HUD regulatory matters, operational issues, entity structure issues, 501(c)(3) formation and other corporate matters.

Speaking Engagements

  • Speaker, “RAD 2019 – Today’s Legal Challenges in the Rental Assistance Demonstration Program,” HDLI 2019 Spring Legal Conference, Washington, DC, May 10, 2019
  • Presenter, “Rental Assistance Demonstration (RAD) Closing the Deal: 101,” ABA Forum on Affordable Housing and Community Development teleconference, April 2019
  • Presenter, “Rental Assistance Demonstration (RAD) Program Basics and Closing the Deal,” ABA Forum on Affordable Housing and Community Development Law Boot Camp, October 2018
  • Presenter, “Reinventing Public Housing,” New York State Association for Affordable Housing Annual Update New York Affordable Housing Conference, September 2018
  • Presenter, “Tax Credit Development 101 for Small and Medium Housing Authorities,” Maryland Association of Housing and Redevelopment Agencies Spring Conference, May 2018
  • Presenter, “The Latest on Project-Based Vouchers,” National Leased Housing Association Mid-Year Membership Meeting, January 2018
  • Presenter, “Navigating Today’s World of Mixed Finance—Legal Strategies for Funding and Development,” Housing Development Law Institute NAHRO Conference, October 2017

Awards and Professional Activities

  • Member, American Bar Association Forum on Housing and Community Development Law
  • Member, Urban Land Institute
  • Member, ULI Housing Initiatives Council 2017-2018
  • Member, New York State Bar Association

Major Prior Work Experience

  • Presidential Management Fellow, U.S. Department of Housing and Urban Development, Office of Multifamily Housing
  • Community and Economic Development Law Clinic, American University Washington College of Law
  • Center Human Rights & Humanitarian Law, American University Washington College of Law
  • U.S. Department of Transportation, Office of the Inspector General
  • Administrative Office of the U.S. Courts, Bankruptcy Judges Division
  • Kyle Moyer & Company, Public Affairs Consulting


American University Washington College of Law, J.D.

  • Reports Editor, International Law Review

American University School of International Service, M.A. International Affairs

Arizona State University, B.S. Housing and Urban Development, cum laude

Bar Admission

District of Columbia Bar

New York Bar

Virginia Bar


Tempe, AZ