The 21st Century ROAD to Housing Act & Opportunity Zones

JAJimmy Atkinson·March 31, 2026 · 7 min read

The 21st Century ROAD to Housing Act has advanced in the Senate with 89 yes votes — and it explicitly touches Opportunity Zones. Jimmy Atkinson and Andy Hagans break down what's in the bill, what it means for OZ investors, and why its restrictions on institutional ownership of single family homes could have significant unintended consequences for the nation's housing supply.

Plus, Jimmy and Andy cover The Wyoming Reserve's recent Wall Street Journal feature, take a live test drive of the new OZ tax benefits calculator at OpportunityZones.com, share updates about upcoming OZ Insiders events, and close out with their picks of the month.

Opportunity Zone News & Events

About OZ NewsHour

OZ NewsHour covers the key stories happening right now in the world of Opportunity Zones. Hosts Andy Hagans and Jimmy Atkinson discuss the powerful trends that investors, fund managers, real estate developers, and industry professionals need to know. If it's a must-know development in the Opportunity Zone world, we cover it here.

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Episode Summary

In this month's edition of OZ NewsHour, Jimmy Atkinson & Andy Hagans cover the 21st Century ROAD to Housing Act, which recently advanced in the Senate, 89-10. The bill originated in the House, where an earlier version was passed, and the Senate combined that legislation with their own amendments to produce the current bill. It now returns to the House, where it is expected to face some friction.

The bill has broad bipartisan support. The two Senate cosponsors are Senator Tim Scott — the creator of the Opportunity Zones program — and Senator Elizabeth Warren. Jimmy and Andy note that the bill reflects a populist consensus that cuts across both parties, connecting the JD Vance wing of the right with the Bernie Sanders and Elizabeth Warren wing of the left.

The bill touches Opportunity Zones in two specific places. Under Title II, Section 202, it would allow HUD to prioritize projects located in Opportunity Zones for grant allocations. Under Section 212, it creates what Jimmy describes as the RESIDE Act, which would convert vacant or abandoned industrial buildings into housing, with OZ-located projects receiving preferential treatment for grant allocations. Jimmy notes the bill does not fundamentally alter the Opportunity Zone tax incentive itself — it primarily addresses grant prioritization.

More broadly, the bill would severely restrict — and in some cases prohibit — the amount of single family homes that can be owned by institutional investors, which the bill defines as any firm that owns at least 350 units. Jimmy traces the origin of this provision to an executive order from President Trump, who has expressed concern about institutional investors owning a large share of the nation's single family homes. Andy notes that institutional ownership of single family homes is "about as popular with the American public as gonorrhea" — unpopular on the right among normally free-market voters, and unpopular on the left with the Bernie Sanders and Elizabeth Warren wing of the party.

Jimmy references a Jay Parsons rental housing economics article that goes as far as to say this could spell the end for the build-to-rent industry and some institutional single family rental asset classes. Jimmy points out that in the years since the Great Recession, a significant portion of the nation's housing supply has been built by institutional investors — including 47,000 BTR units built last year alone — and raises the question of what happens to those units if the restrictions go into effect. Andy draws a parallel to rent control, noting that policies designed to make housing more affordable can end up reducing supply and having the opposite effect. Both Andy and Jimmy note that the policy details could change before the bill is finally reconciled and signed into law.

The Wyoming Reserve

Jimmy and Andy discuss the Wyoming Reserve, a qualified opportunity zone business located in Casper, Wyoming. The Wyoming Reserve was a sponsor of the most recent OZ Pitch Day event on March 12 and has presented at OZ Pitch Day events multiple times. The business operates in what they call the "gold economy," with significant exposure to the price of gold and silver.

The Wyoming Reserve recently relocated from Scottsdale, Arizona to Wyoming, in part to take advantage of the Opportunity Zone tax incentive and Wyoming's openness to this type of business. A recent Wall Street Journal article covered the Wyoming Reserve in connection with a new state law requiring Wyoming to hold a portion of its state portfolio in precious metals. The state of Wyoming currently holds approximately 2,300 ounces of gold — worth around $10 to $11 million depending on spot price — stored at the Wyoming Reserve facility. Jimmy notes he toured the vault approximately a year ago and described the security as impressive.

OZ Insiders

OZ Insiders, Jimmy's private Opportunity Zone mastermind community, is hosting its first dinner of 2026 in New York City the following Thursday at the Parlor Room on West 36th Street in Midtown Manhattan. The dinner has a cap of 32 people. Three additional dinners are planned for later in the year: Los Angeles in the spring or early summer, Dallas or Fort Worth in early September, and Washington DC the night before the Novogradac conference on October 28.

In addition to the in-person dinners, OZ Insiders hosts a monthly master class and group coaching session on the second Monday of every month via Zoom. Upcoming topics include OZ structuring for sponsors and investors led by Dallas-based opportunity zone business attorney Gerry Reihsen, creating unique OZ capital stacks and combining the OZ incentive with other tax credit programs led by Graham Allison, and — in June, just before the OZ 2.0 nomination process opens on July 1 — a class on getting zones designated under OZ 2.0.

New OZ Tax Benefits Calculator at OpportunityZones.com

Jimmy walks through a newly launched free OZ tax benefits calculator available at opportunityzones.com/calculator. The calculator allows users to input a capital gain amount, the date of the gain, the planned QOF investment date, the type of fund (standard QOF or qualified rural opportunity fund, or QROF), the planned hold period, an assumed annual appreciation rate, and the applicable federal capital gains rate including the net investment income tax.

Using a hypothetical $200,000 K-1 gain invested in a rural QROF at a 20% annual appreciation rate over ten years, the calculator produces an estimated federal tax benefit of $435,000, with a projected QOF value after ten years of $1,238,000 — a gain of over a million dollars that is totally tax free. Jimmy also demonstrates how shifting the investment date to January 2027 changes the regime to OZ 2.0, updates the deferral date to 2032, and applies a 30% basis step-up for the rural fund selection.

Picks of the Month

Jimmy's pick is the third edition of the Novogradac introduction to Opportunity Zones booklet, which is fully updated for OZ 2.0. Available at novoco.com, the booklet covers the four main benefits of Opportunity Zone investing, a sample investment timeline, the working capital safe harbor, how OZs work with other incentives, and a glossary of terms.

Andy's pick is a thought leadership piece titled "Opportunity Zones 2.0: A Critical Role for State Agencies," co-authored by Bruce Katz and OZ Insiders member Frances Kern Mennone. The article argues that state housing agencies should have a seat at the table during the OZ 2.0 zone designation process, which officially opens July 1.

Jimmy notes that while some states — including California and Texas — have already updated their guidance and begun informal nomination processes, only about a dozen states have updated their websites with any guidance on how the nomination process will work. Texas is specifically called out in the article for developing a data-driven selection process, an approach that Frances and Bruce believe is likely to be repeated across the country.

Jimmy also notes that some states with a minimum number of eligible census tracts, such as Vermont and Wyoming, will receive all of their eligible tracts automatically and do not need to go through a competitive selection process.