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HAC Comments on Duty To Serve Plan Modifications – December 2023

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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 equity investments in CDFIs – a decision which relies on approval from the FHFA.
HAC DTS Plan Modification Comments 12.06.23 FINAL
Policy News from the Administration

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

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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
Policy News from the Administration

HAC’s Comments on Rental Assistance Decoupling – August 2023

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The Fiscal Year 2023 President’s Budget included a request to decouple USDA Section 521 Rental Assistance from Section 515 Multifamily Loans to facilitate the rehabilitation and preservation of the multifamily portfolio. To explore the potential impacts, Congress directed USDA to conduct a series of stakeholder meetings and provide a report on how decoupling would be implemented. HAC submitted comments in support of decoupling, with a focus on the topics below.

  • Making Long Term Affordability Parameters the Top Priority
  • Considering A Pilot Concept When Implementing Decoupling
  • Clarifying the Annual Rent Increase Process for Decoupled RA Units
  • Establishing A Plan for Units Without Rental Assistance in Decoupled Properties
  • Maintaining Support for the Entire Suite of Preservation Programs, Even If Decoupling Becomes an Option
  • Establishing A Plan for Prepayments, Since the Bulk of Units Are Lost to Prepayments
  • Improving Data Transparency At RHS

Read HAC’s full comments.

HAC Decoupling Comments 2023
Policy News town

HAC’s Comments on Duty to Serve – July 2023

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The FHFA requested comments on Fannie Mae and Freddie Mac’s Duty to Serve plans as part of their annual Duty to Serve Listening Sessions. Jonathan Harwitz, HAC’s Director of Public Policy, provided oral comments, accompanied by longer written comments, on behalf of HAC. If implemented robustly, Duty to Serve has the potential to improve the lives of people living in the most underserved communities. HAC’s comments focused on:

  • Maintaining USDA Section 515 preservation as a core goal of the rural Duty to Serve Plans;
  • Permitting targeted equity investments in CDFIs;
  • Using, and further refining, the new Colonias Census Tract definition; and
  • Meeting rural LIHTC equity investment goals.

Read HAC’s full comments.

HAC DTS Rural Listening Session Comments
Policy News field

HAC’s network supports improvements to USDA’s Rural Housing Service in letter to Congress

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With the help of our network of organizations working across the country in rural areas, more than 100 organizations signed on to support bipartisan, cross-Committee collaboration to consider improvements to USDA’s Rural Housing Service (RHS) programs as part of the larger Farm Bill. Historically, the RHS programs have not been included in the Rural Development Title of the Farm Bill because they fall within the jurisdiction of the Banking Committee. But in recent months there has been increased cross-Committee momentum to include some bipartisan RHS modernizations in the Farm Bill, and we want to encourage that momentum to keep building. Check out the letter below to learn more. Thanks to all the organizations who signed on in support!

HAC Rural Housing Farm Bill Sign-on 2023 FINAL
Policy News town

HAC’s Comments on Greenhouse Gas Reduction Fund

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HAC has submitted its second comment letter to the Environmental Protection Agency (EPA) about the the new $27 billion Greenhouse Gas Reduction Fund (GGRF) created by the Inflation Reduction Act. In late April, EPA released an implementation framework explaining that it plans to divide the program into three competitions. The $14 billion National Clean Investment Fund will fund two or three national nonprofits to partner with private capital providers to deliver financing at scale to businesses, communities, community lenders, and others. The $6 billion Clean Communities Investment Accelerator competition will fund two to seven hub nonprofits to build the capacity of lenders such as CDFIs and housing finance agencies to finance clean technology projects. The $7 billion Solar for All competition will make grants to states, Tribal governments, municipalities, and nonprofits to prepare low-income and disadvantaged communities for residential and community solar. EPA expects to issue Notices of Funding Opportunity as early as June.

HAC first commented in December after EPA asked for general feedback. In its second letter, HAC repeats some of the suggestions made in December and makes some additional points about the implementation framework, asking EPA to:

  • Address the unique needs of rural and persistent poverty communities.
  • Ensure that nonprofit CDFIs and their nonprofit housing development partners are explicitly eligible for GGRF resources.
  • Increase clarity and reduce administrative burden on recipients.
  • Exempt housing from Build America, Buy America requirements.

Read HAC’s full comments here.

HAC GGRF Comment Letter
HAC President & CEO, David Lipsetz, testifies in front of the Senate Committee on Banking, Housing, and Urban Affairs Subcommittee on Housing, Transportation, and Community Development

HAC’s CEO Testifies to Senate Banking Subcommittee on Rural Housing Reforms

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HAC was honored to be invited to testify on May 2, 2023 before the Housing, Transportation, and Community Development Subcommittee of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to discuss commonsense, bipartisan reforms to the U.S. Department of Agriculture’s Rural Housing Service (RHS) programs. HAC’s President & CEO, David Lipsetz, was one of five witnesses on the hearing panel.

The hearing was held to discuss the bipartisan Rural Housing Service Reform Act of 2023, which has been introduced by Subcommittee Chairwoman Tina Smith (D-MN) and Senator Mike Rounds (R-SD). The RHS Reform Act includes a slate of provisions to improve the multifamily, single-family, and capacity building programs at RHS. Senators Smith and Rounds engaged deeply with stakeholders on the creation of the bill, including offering a call for policy recommendations in the summer of 2022. HAC’s response to that comment opportunity can be seen here. We were thrilled to see many of our recommendations included in the bill, and applaud Senators Smith and Rounds on their thoughtful engagement with stakeholders and their commitment to improving the RHS programs.

Highlights from the RHS Reform Act include:

  • Multifamily

    • Authorizing the Multifamily Preservation and Revitalization (MPR) program and Multifamily Preservation Technical Assistance Program
    • Allowing for the decoupling of a Section 515 mortgage and Section 521 Rental Assistance
    • Allowing Section 542 rural vouchers to be adjusted based on changes in tenant income
    • Streamlining the process for Section 515 nonprofit transfers and increasing the Section 515 nonprofit set aside

  • Single Family

    • Establishing the Native CDFI Section 502 relending program
    • Increasing the threshold for the mortgage requirement on a Section 504 home rehab loan from $7,500 to $15,000
    • Extending the loan term for a Section 502 loan up to 40 years

  • Capacity Building

    • Authorizing the Rural Community Development Initiative (RCDI) and waiving the matching funds requirement for groups working in areas of persistent poverty
    • Requiring RHS to publish more data on their housing programs
    • Authorizing funding for much needed technology upgrades at RHS
Watch the Recording Read David’s Testimony HAC’s 2023 Policy Priorities

News Coverage

Policy News town

HAC’s Comments on Affirmatively Furthering Fair Housing

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In February 2023, the U.S. Department of Housing and Urban Development (HUD) requested public comments on a proposed regulation that is intended to ensure that HUD and entities receiving funding from HUD will “Affirmatively Further Fair Housing” (AFFH). This rule would implement the Fair Housing Act’s requirement for HUD and its awardees to proactively take meaningful actions to overcome patterns of segregation, promote fair housing choice, eliminate disparities in housing-related opportunities, and foster inclusive communities that are free from discrimination. The 2023 proposed rule is based on a 2015 rule that was never fully implemented.

HAC supports many aspects of HUD’s proposal. HAC also supports suggestions for improvements made in comment letters prepared by the National Community Reinvestment Coalition and National Housing Law Project, and HAC — along with many other organizations — signed those letters. In addition, to emphasize some points that are particularly relevant to AFFH efforts in rural America, HAC submitted its own comment letter.

In its letter, HAC makes three primary points regarding state and local governments’ development of AFFH Equity Plans:

  • Community engagement must be offered in many different ways.
  • Analyses must be conducted in smaller geographic areas.
  • Data on USDA-supported housing must be specifically included.

Read HAC’s full comments here.

HUD AFFH 2023 Comment Letter
HAC in the News

Advocates eye farm bill to avert drop in affordable rural housing – CQ Roll Call

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By Caitlin Reilly

Posted April 11, 2023 at 5:00am

Housing advocates are turning to this year’s farm bill in an effort to steer rural communities away from an affordable housing cliff ahead.

Without action from Congress, rural communities stand to lose more than 100,000 affordable rental units in the next decade as federally subsidized loans used to build the apartments are paid off, ending landlords’ obligations to keep rents low. In a second blow for those renters, they will lose their eligibility for the Agriculture Department’s rental assistance.

“It’s a big problem, and it’s going to only get worse,” said Sarah Saadian, senior vice president of public policy at the National Low Income Housing Coalition.

“The heyday or the peak of rural housing was in the ’70s and ’80s, when their rental housing program was nearly a billion-dollar program, and it’s been cut really dramatically over the last several decades,” Saadian said in an interview. “All of those properties that were built at that time are now reaching the end of the maturity on their 515 mortgage, or the 515 loans that USDA provides in order to get those properties built.”

Advocates are pushing Congress to include provisions in the farm bill that would decouple the two programs, allowing the Agriculture Department to provide rental assistance even after a building’s owner has paid off the subsidized mortgage.

Read the full article

“The biggest issue in rural housing is the rapid loss of the 515 units due to mortgage maturity, prepayments, foreclosures. That is the 800-pound gorilla, or really the $31 billion gorilla over the next 30 years to preserve.”

Policy News field

HAC Comments on HUD’s CDBG-DR Disaster Recovery Program

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Responding to two requests for information from HUD, on February 21 HAC submitted comments on some of the specifically rural concerns involved in using the Community Development Block Grant Disaster Recovery (CDBG-DR) program.

The program does not receive regular annual funding in HUD’s appropriations bills. Instead, Congress provides funds to help with recovery from specific disasters after they occur. As a result, HUD has not been able to write regulations for the program. The department is now developing a “Universal Notice” that would standardize the CDBG-DR allocation and implementation process. HUD asked for input on the program’s rules and waivers and on its allocation formula. HAC combined its responses and submitted one letter.

Key Takeaways

  • To make CDBG-DR most effective in rural and Tribal areas, HUD must build local capacity itself, or require state grantees to do so.
  • To achieve geographic equity in the distribution of CDBG-DR resources, HUD must account for the difficulties of appraising rural properties, as well as for a variety of nontraditional housing and nontraditional forms of ownership that are common in rural places.
  • HUD, FEMA, the U.S. Department of Agriculture, and other agencies involved in the disaster recovery process should develop a single set of standardized forms and templates for applicants to use.

To learn more about HAC’s full recommendations, read our full comment letter. Other comments are posted here and here.

HAC Comments on CDBG-DR

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