Why Oklahoma Needs a NOAH & Stabilization Strategy Now

In the housing industry, apartment properties are commonly graded by “class” based on their age, condition, and amenities. While Class A refers to premier developments (usually less than a decade old), Class B and C properties are older, more modestly built complexes that rent at lower price points simply because they haven’t been recently updated. These older Class B/C apartment properties make up a substantial portion of Oklahoma’s affordable housing supply. There are an estimated 4,100 Class B/C properties statewide, comprising more than 240,000¹ units and 44%² of all occupied rental stock.

Many of these properties are labeled as “NOAH,” which stands for Naturally Occurring Affordable Housing — not because they were built or subsidized to be affordable, but simply because they’re aging and, in most cases, unrenovated. No public program protects them, so when one fails, whether physically or financially, the units it once offered usually don’t come back online as affordable.

If a property is not NOAH, its rents may be capped by federal subsidy program requirements, such as the Low-Income Housing Tax Credit (LIHTC) program requirement that developments have an “affordability period” of no less than 30 years. These types of properties face a similar challenge after their affordability period expires: How do we ensure that the units in these complexes remain affordable for years to come?

Because there’s no realistic way to replace this housing at the same scale through new construction or subsidy programs, losing Class B/C properties doesn’t just displace the tenants who live there – often households with families, young adults, and seniors living on fixed incomes – it drives up competition and rents for everyone else in the market. The stakes reach further than any one household.

Protecting this housing type benefits all Oklahomans.

Learning in Real Time

A recent example of this kind of system failure is unfolding in the destabilization of a large portfolio originally owned and operated by Vesta Realty. Vesta owned more than 30 properties across Oklahoma, accounting for more than 4% of Tulsa’s rental market and more than 2% of Oklahoma City’s. This problem is at a scale large enough that its failure isn’t just a story about one landlord, but about what happens when a whole segment of the housing market has no safety net beneath it.

The condition of Vesta’s portfolio represents failures on two fronts at once: deferred maintenance and fiscal irresponsibility. For months, tenants have been sounding the alarm over water shutoff notices, uncollected trash, and, in some cases, outright uninhabitable conditions. Many tenants reached out to local media and city code officials, unsure of who else to contact in situations like these.

In addition, subcontractors employed by Vesta have alleged that the company’s CEO was diverting funds and had racked up over half a million dollars in unpaid invoices³ — a signal that this is financial distress, not just neglect, and one that raises the odds of foreclosure or further utility shutoffs.

However, Vesta is just a symptom of a larger problem: Oklahoma lacks the statewide systems for accountability and infrastructure that can provide relief when failures like this happen. The collapse of Vesta’s portfolio happened in slow motion, in full view. So why are we still caught in dire straits, and how can we build systems that prevent this from happening again?

Below are five interventions that state and local governments can act on now.

Intervention 1 — Early Warning: Know Which Properties Are at Risk Before They Fail

The state currently has no landlord registry, primarily because of HB 2620, a 2014 Oklahoma law barring cities from requiring registry, so cities and advocates have no systemic way to track ownership and management. This law has effectively shifted the burden of discovering habitability issues onto renters and has forced cities to take action against troubled properties reactively rather than proactively. While repealing or amending the 2014 law would be an important step for Oklahoma to consider, several municipalities have already begun compiling their own property lists without a required registry. Pairing a baseline list like this with additional real-time data, such as water utility billing, code enforcement activity, and commercial mortgage data, is essential for spotting early signs of trouble. Once those early signs of distress are identified, local governments, nonprofit organizations, and communities must be ready to take immediate action.

Intervention 2 — Capital Ready to Move: Preservation, Stabilization, and Emergency Funds

When tenants in distressed properties face the acute risk of mass eviction, whether due to utility cutoffs or because an apartment complex has reached the end of its required affordability period, emergency funds must be ready to deploy immediately. Without intervention, properties that change hands after an affordability period expires can see rents sharply increase, causing mass displacement of tenants who were relying on capped rents to stay housed. And in the case of utility shutoffs, it takes only 15 days for a landlord to evict in Oklahoma, which means intervention must be swift to protect residents, particularly tenants with limited options if displaced, such as households in income-restricted units and people who need accommodations for a disability.

Legislators can look to states such as Minnesota for a model. Its Housing Finance Agency administers the Preservation Affordable Rental Investment Fund (PARIF), a legislatively appropriated program designed to protect units at risk of losing subsidy through market conversion or deferred maintenance by offering funds for acquisition, rehabilitation, equity take-out loans, and debt restructuring, ensuring those units remain affordable for decades to come. Oklahoma could benefit from a similar fund, given both the large number of NOAH units and the more than 54,000⁴ federally subsidized units already in Oklahoma.

Intervention 3 — Right of First Refusal & Opportunity to Purchase Policies

When large NOAH or federally subsidized properties are at risk of selling to new owners who are not required to keep unit rents affordable, a way to maintain resilient communities would be ensuring that municipalities and nonprofit housing providers have the opportunity to purchase the property. This would provide housing stability and continuity, benefiting both existing tenants and guaranteeing the longevity of affordable rents. Even with capital ready to move, preservation buyers often lose to the highest, fastest bidder. Legislation like the District of Columbia’s Opportunity to Purchase Act provides a level playing field for these buyers to purchase with a commitment to preserve affordability. Passing Right of First Refusal protections would help ensure Oklahomans continue to enjoy affordable rents in properties owned by local companies, not out-of-state or international prospectors.

Intervention 4 — State & Local Protections That Are More Balanced

Oklahoma’s Landlord-Tenant Act dates to the 1970s and is one of only six state frameworks without anti-retaliation protections, meaning that a landlord can penalize renters for simply reporting health/safety violations or requesting repairs. In 2026, HB 2015 attempted to rectify this by allowing tenants to seek damages or withhold rent in specific circumstances when landlords fail to maintain properties. There have also been many attempts, as recently as this year with SB 1209, to decrease the number of evictions occurring in our state.

As we continue to make incremental progress in this area, legislators and local leaders may consider introducing reforms seen in other states, such as an implied warranty of habitability, repair-and-deduct ordinances, or rent-withholding escrow accounts. Requiring accountability from speculative landlords who make risky financial decisions that endanger tenants must be part of the equation. So, we must reward responsible owners for investing in the long-term viability of their assets.

Intervention 5 — Local Controls

Unfortunately, the story of Vesta Realty’s portfolio collapse is not unique, nor will this year be the last time our cities face the possible loss of hundreds of units. Local governments can prepare for scenarios like this by documenting collective strategies before the first signs of trouble appear. Which nonprofit will do what? Who coordinates with the school district, and with the housing authority? Which code and law enforcement tools need to be deployed? What programs step in to assist our most vulnerable tenants to prevent homelessness?

It may seem like there are endless actions that need to take place to protect Oklahomans and our sensitive, affordable housing ecosystem when cases like Vesta occur. But by having a clear, written plan of action in place before situations arise, municipal governments can rely on the commitment and expertise of our local housing providers to step in when it counts.

While the prospect of so many affordable rental units being at risk in Tulsa and Oklahoma City is daunting, now is the time for our state and local governments to make some long-needed strides in housing preservation — not just for those dependent on affordable housing, but for all Oklahomans.

Sources:

1. Total number of Class B and C properties in Oklahoma was calculated using individual property data from CoStar Suite. Retrieved August 13, 2026.
2. Percent of occupied rental units that are in Class B or C properties was calculated using the American Community Survey, Table B25003, 2024 5-Yr estimates. Accessed August 13, 2026.
3. “A Rat’s Nest of Fraud and Deceit”: New Lawsuit Adds to Vesta Realty CEO’s Legal Troubles — Jake Ramsey, Oklahoma Watch, April 8, 2026.
4. “How many subsidized housing units are available in Oklahoma?” — USAFacts, updated June 29, 2026. Accessed August 13, 2026.