HAC Opposes Proposed Changes to ECOA Equal Lending Rule

The Consumer Financial Protection Bureau has proposed to change its rules for the Equal Credit Opportunity Act, which requires fairness in lending, including mortgage lending. The revisions would eliminate use of disparate impact — the legal concept that conduct is discriminatory if it has inequitable effects, even if there was no intent to discriminate — and would revise provisions on discouragement of applicants or prospective applicants and on special purpose credit programs. HAC’s response argues that disparate impact is a necessary tool to identify discrimination in mortgage lending, including discrimination against rural residents.

CFPB ECOA disparate impact HAC Final

HAC Comments on Rural Housing Supply

The House Financial Services Committee held a hearing December 3, 2025 titled Building Capacity: Reducing Government Roadblocks to Housing Supply. HAC submitted written comments to the committee, pointing out that rural areas are lagging in development of new housing. HAC also reminded lawmakers that preservation of existing housing is essential to provide an adequate housing supply, and that rural places face a rental housing preservation crisis.

HAC Comments for the Record on Housing Supply for HFSC Hearing 12.03.25

HAC Comments on Proposal to Outsource USDA Single-Family Loan Servicing

USDA is collecting comments from stakeholders and potential vendors to take over a portion of the single-family loan servicing functions currently handled by the Servicing Office in St. Louis. The Servicing Office was established in 1996 in St. Louis, Missouri as part of USDA Rural Development’s national restructuring effort to centralize loan servicing functions. Over the last three decades, the office has become the core operational center for the single-family programs, managing more than 185,000 active loans and approximately $14.5 billion in outstanding debt. Comments and vendor proposals were due on July 16. HAC submitted comments opposing this privatization of single-family loan servicing. Our comments highlighted that:
  • Servicing for this portfolio is unique due both to the structure of the loan products and the needs of the borrowers served. Any external vendor would have a steep and costly learning curve.
  • Given these unique and complex servicing needs, cost savings of privatization are highly unlikely. Any anticipated cost savings need to be made public before this process moves forward.
  • A better solution lies in adequately staffing the Servicing Office and upgrading its servicing technology.
HAC’s full comment can be viewed here:

HAC CEO Responds to Executive Order Impacting Rural CDFIs

I’ve worked in enough small towns across America to know this: rural communities prosper when they have financial partners ready to invest in homeownership dreams and small business start-ups. A recent Executive Order targeting Community Development Financial Institutions has me concerned that rural America could lose access to the $6 billion in business CDFIs generate in their local economies.

For years, rural areas faced dwindling access to financial services. The number of rural headquartered banks fell by over 3,600 since 1995, an astounding 57% decline. Thankfully over that same 30-year period over 500 rural CDFIs have been created, filling gaps in the banking landscape of every State. And they do it effectively, leveraging $8 in private investment for every $1 in federal support. This has been especially helpful for local organizations with projects that are too small or specialized for the remaining banks or distant commercial lenders to finance.

HAC is one of those rural-serving CDFIs. Our work is supported by the resources the recent Executive Order is trying to undermine. We want to continue delivering real results for real people.

  • In Clearfield County, PA, where 45% of grandparents are raising grandchildren due to the opioid epidemic, HAC’s financing helped build the Village of Hope, a multigenerational affordable housing development designed for seniors and youth to live together.
  • In Pahokee, FL, our loan helped Diverse Housing Services breathe new life into Amaryllis Gardens, 44-units of workforce housing for employees of the surrounding farms.
  • In Visalia, CA, HAC’s $12 million in financing to Self-Help Enterprises has enabled over 300 low-income families to help construct their own homes as “sweat equity” downpayments.

The good news here is that the Executive Order is to be “implemented consistent with applicable law and subject to the availability of appropriations.” The CDFI Fund is not a discretionary policy—it’s embedded in federal statutes such as the Riegle Act, the Community Renewal Tax Relief Act, the Housing and Economic Recovery Act, and the Small Business Jobs Act. And funds for CDFI’s were included in this year’s appropriations and continuing resolutions.

It also helps that the CDFI Fund programs were created and supported by bipartisan consensus. Leaders across political lines and branches of government understand that rural America’s need for economic opportunity and stable housing is a shared national priority. We are encouraged by Treasury Secretary Bessent’s recent statement recognizing “the important role that the CDFI Fund and CDFIs play in expanding access to capital” and affirming that “CDFIs are a key component of President Trump’s commitment to supporting Main Street America.” For over 50 years, HAC has worked directly with rural policy-makers — Republican, Democrat, and Independent alike — to make affordable housing a reality. We hope that under the current Administration, the CDFI Fund will continue to be staffed and funded as Congress has legislated.

HAC stands ready to continue serving the millions of Americans who depend on the stability and opportunity CDFIs’ investments create. The path forward must strengthen, not undermine, our ability to serve hardworking rural families. They deserve nothing less.

HAC CEO issues statement on cuts to housing programs and professionals

In response to reports of extensive cuts in federal programs and staff that serve rural and small town interests at the Department of Housing and Urban Development (HUD) and U.S. Department of Agriculture (USDA), Housing Assistance Council CEO David Lipsetz made the following statement.

After this fall’s election, I observed that urban and rural voters had come closer together, as their shared frustration with the economy put a new Administration in the White House.  It seemed this would lead to a rebalancing of public and private investment in housing—one where small towns finally get their fair shot at prosperity. One-quarter of all rural families—5.6 million rural households—are paying more than they can afford for housing. Rural communities are experiencing unprecedented levels of homelessness, with rents outpacing household income, and a housing market that puts the American Dream of homeownership out of reach for many young working families. I expressed hope that the outcome of the election would finally bring national attention to the severe housing crisis facing rural communities.

However, this glimmer of hope is now fading. The public frustration that I thought would drive positive changes to an imperfect system is instead fueling an indiscriminate effort to dismantle the very programs and professionals we need. Recent cuts at USDA and HUD are setting small towns back.

Millions of rural Americans can rent decent apartments and buy good homes in places that banks and builders do not serve because we the people believe everyone deserves a chance. Hundreds of thousands of rural families—many elderly and disabled—live in HUD’s publicly supported housing or rely on HUD and USDA rental programs to find a place they can call home. These public programs sustain rural communities as they cycle through tough times.

When the market doesn’t generate enough good housing in small towns, mortgages from USDA and rent vouchers from HUD fill the gap. Yet, these are not simple programs to run. For these programs to ensure that good housing is built and maintained, we need experienced professionals in the administration. Plans to terminate half of HUD’s workforce and dismiss employees at USDA threaten to severely disrupt these vital investments in rural housing. A bank would never tell its shareholders it plans to fire half its underwriters and still expects to make good quality loans.

We cannot afford this kind of disruption to programs that rural communities depend on. Congress has appropriated funding for these programs, rural families need them, and they cannot operate effectively without adequate, experienced staff to administer them.

HAC has been in small towns for 54 years and plans to be here for 54 more. We stand ready to work with the President and everyone else who wants to build up rural communities. We look forward to partnering with new leaders at HUD and USDA to make sure they have the resources to address rural America’s pressing housing challenges.  But one thing is clear: the affordable housing crisis in rural America requires more capacity and attention, not less.

HAC Supports Rural Provisions in Capital Magnet Fund Interim Rule

The CDFI Fund has released for comment an interim rule for the Capital Magnet Fund (CMF) program. The Capital Magnet Fund offers competitively awarded grants to CDFIs and nonprofit affordable housing organizations to finance affordable housing solutions and community revitalization efforts that benefit individuals and families with low-incomes and low-income communities nationwide. HAC has received several CMF awards, most of which have been used for the preservation of USDA’s Section 515 multifamily properties amid the maturing mortgage crisis. HAC is broadly supportive of the CMF interim rule, and submitted comments on several rural elements, including:
  • Support for the addition of a national Rural Service Area. This change will make it easier to use CMF in rural areas, and will all organizations who serve rural areas across the country to be nimble and flexible with their CMF funds.
  • Support for aligning CMF income targeting with other federal programs, with the caveat that the application competition should prioritize applications that propose deeper income targeting. Not all CMF deals include LIHTCs, especially in rural places. We encourage the CDFI Fund to consider how to continue to encourage this deeper income targeting in the CMF application scoring process, since raising the Very Low-Income threshold could result in fewer households under 50 percent AMI being served.
  • Support for the use of the Duty to Serve definition for rural areas. HAC has done extensive research on the myriad of rural definitions, and feels that the Duty to Serve definition is the most precise rural definition available.
HAC CMF Rule Comments 08.26.24

HAC Comments on Proposed New Rule for HOME Investment Partnerships Program

In late May, HUD published a proposed rule which would enable much needed revisions and updates to the requirements governing the HOME Investment Partnerships program. The proposed rule would make changes across the HOME program, from homeownership to rental, and included a specific focus on improving Community Housing Development Organization (CHDO) availability and capacity in rural areas. In response, HAC submitted comments on the proposed rule, applauding many of the proposed changes and pushing for additional rural-focused priorities. Specifically, key takeaways in HAC’s comments included:
  • The reality of the rural landscape must be taken into consideration as this new rule is finalized. Affordability is the greatest issue facing rural communities, like it is for the country at large. But rural areas are also disproportionately impacted by persistent poverty, substandard and overcrowded housing, and a lack of local capacity and access to capital.
  • Varying HOME program administration across Participating Jurisdictions (PJs) has been the most significant barrier for the small rural communities we serve. Over the last decade, we have observed that rural organizations experience significant challenges in effectively accessing HOME funds. Primarily, these difficulties arise from how PJs have adapted their programs, largely as a response to the 2013 regulation changes and subsequent funding reductions. PJs will need significant training in the impacts of this new rule to ensure it is implemented effectively.
  • Regulatory change alone cannot solve all the challenges within the HOME program. Because of the highly prescriptive nature of the HOME statute, a variety of statutory changes are also needed to fully transform the program such that it more positively impacts rural America.
  • Rural Community Housing Development Organizations will benefit from the proposed changes, but more is needed to move the needle. HAC applauds changes to Board Member requirements, organizational capacity requirement, and capacity building funds. We do, however, have concerns around the proposal to allow for statewide CHDOs, intended to improve rural program outcomes. Statewide CHDOs could inadvertently further disadvantage small, rural groups who are hoping to access the CHDO set-aside by forcing them to potentially compete with high-capacity, statewide organizations.
  • Streamlining and improved flexibility across the program is welcome. Helpful changes are proposed with respect to homebuyer housing, rental housing, Community Land Trusts, tenant-based rental assistance, tenant protections, maximum per-unit subsidy limits, and green and resilient property standards. These changes will help small, lower capacity groups to access and see success with the HOME program.
HAC HOME Rule Comments 07.29.24 FINAL

HAC Applauds New Farm Bill Framework

The Housing Assistance Council (HAC) celebrates the inclusion of key priorities for rural community development in the Rural Prosperity and Food Security Act, released by Senate Agriculture Committee Chairwoman Debbie Stabenow earlier this week. Strong rural communities are a vital part of building a stronger, better future for the whole country. This bill recognizes that reality. Including robust new resources for rural community development in the Farm Bill would be a historic victory for small towns and rural places nationwide.

The framework released by Chairwoman Stabenow creates, for the first time, baseline funding for Rural Development, with $50 million per year for the Rural Partnership Program, a new capacity building program that HAC has long been supportive of. This sustained investment in rural communities would help them build the capacity to access complex federal funding streams and overcome their greatest challenges, from housing to childcare to broadband.

HAC also continues to be glad to see the bipartisan interest in Senator Tina Smith’s and Senator Mike Rounds’ Rural Housing Service Reform Act. This bill makes tested, commonsense reforms to USDA housing programs so that they can better serve rural America. Modernizing the Rural Housing Service is an important step in solving the growing crisis in rural multifamily preservation. While not under the jurisdiction of the Agriculture Committee, we hope that this bill can move through the Banking Committee and join with the Farm Bill as a floor amendment.

“Rural Development is an often-overlooked title within the Farm Bill,” notes HAC Director of Public Policy Jonathan Harwitz. “Chairwoman Stabenow’s new framework changes that narrative for Rural Development. Improving those programs and providing baseline funding would give rural communities nationwide the tools they need to build a better, stronger future. We look forward to hopefully seeing the Farm Bill move forward this year and thank Chairwoman Stabenow for her leadership.”

HAC Comments on Duty To Serve Plan Modifications – December 2023

The Federal Housing Finance Agency (FHFA) put out a call for comments on the Enterprises’ (Fannie Mae and Freddie Mac’s) proposed 2023 Duty to Serve Plan modifications. Both Enterprises proposed cutting a variety of their loan purchase goals in rural areas, citing market conditions as the justification. HAC pushed back on these proposed cuts in our comments. Specifically, HAC made in following points in our comment:

  • HAC is generally agnostic as to which section of Freddie Mac’s Duty to Serve plan USDA Section 515 purchases fall under, but strongly supports their continued inclusion and tangible results. We support mainlining the Section 515 purchases currently included in the rural section of the plan because they focus on rural-targeting of properties.
  • HAC opposes cuts to loan purchase goals in high-needs rural regions and from small, rural financial institutions.
  • HAC opposes cuts to loan purchase goals for manufactured housing communities.
  • HAC supports Fannie Mae’s new proposed objective to better serve the manufactured housing needs of Native communities.
  • HAC support permitting the Enterprises to make investments in CDFIs – a decision which relies on approval from the FHFA.
HAC DTS Plan Modification Comments 12.06.23 FINAL

HAC Comments on OMB Guidance on Grants and Agreements – December 2023

The Office of Management and Budget (OMB) put out a call for comments on their guidance for Grants and Agreements, with a lens toward making grants processes more equitable. HAC submitted comments in support of more proactive geographic equity in the federal grants process. In addition to recognizing capacity building and access to capital as two essential equity issues in rural places, HAC’s comments focused on the recommendations below.

  • Instituting a Rural Impact Analysis for New Regulations
  • Investing in Capacity Building and Rural Intermediaries
  • Eliminating, Reducing or Modifying Cost-sharing and Matching Requirements that Disparately Impact Rural Communities
  • Streamlining and Increasing Uniformity in Applications
  • Including or Increasing Administrative and Predevelopment Costs as Eligible Activities in Rural Places
  • Recognizing the Rural Challenges in Metrics and Data Reporting
HAC Comments on OMB Guidance on Grants and Agreements 12.04.23

GET THE HAC NEWS!

Sign-up for HAC information products

SIGN UP HERE

Housing Assistance Council   |  1828 L Street. N.W., Suite 505, Washington, D.C. 20036
(202) 842-8600 (202) 347-3441 hac@ruralhome.org |

Board Portal

HAC is an equal opportunity provider, employer, and lender. | Civil Rights | Privacy