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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
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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
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HAC’s Comments on HUD’s 2023 Learning Agenda

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HAC submitted comments to the Department of Housing and Urban Development’s (HUD) Request for Information on their Fiscal Year 2023 Learning Agenda. There is a lack of rural research on a variety of housing topics, and HUD can play a role in investing in high-quality research and data to better define rural needs.

HAC’s comments suggested these areas and topics as ripe for HUD research investment:

  • Farmworker housing conditions
  • Manufactured housing issues
  • The fate of housing units leaving the federally subsidized housing stock
  • The impact of rural Area Median Incomes on HUD program access
  • Rural data in the American Housing Survey

Read HAC’s full comments here.

HUD Learning Agenda 2023 Comment Letter
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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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HAC Comments on Community Investment Focus on Capacity Building and Capital Access

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Several federal government agencies recently formed an Interagency Community Investment Committee (ICIC), focused on the operations and execution of federal programs that facilitate the flow of capital and the provision of financial resources into historically underserved communities, including communities of color, rural communities, and Tribal nations. The ICIC requested public input on ways the agencies can promote economic conditions and systems that reduce racial disparities and produce stronger economic outcomes for all communities. According to the request for comment, responses may be used to inform ICIC’s future actions to improve the operations and delivery of federal community investment programs through stronger federal collaboration. The committee is composed of representatives from the Department of the Treasury, Small Business Administration, Department of Commerce, Department of Transportation, Department of Housing and Urban Development, and Department of Agriculture.

Key Takeaways

  1. Support capacity building for local organizations embedded in their communities.
  2. Provide equitable access to capital for rural America.
  3. Address rural needs, particularly in persistent poverty areas, directly.
  4. Accelerate interagency coordination and sharing of best practices.
  5. Improve data and information accuracy and availability.

Read HAC’s comments, submitted on December 19, 2022. Other comments are posted here.

HAC Comments on Community Investment Focus on Capacity Building and Capital Access
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HAC Submits Comments on Proposed Duty to Serve Modifications

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The Federal Housing Finance Agency (FHFA) requested comments on Fannie Mae and Freddie Mac’s (the Enterprises) proposed modifications to their Duty to Serve 2022 Underserved Markets Plans. If implemented robustly, Duty to Serve has the potential to improve the lives of people living in the most underserved communities. HAC’s comments highlighted two proposed modifications:

Key Takeaways

  1. USDA Section 515 preservation is critical to the Duty to Serve mission. Freddie Mac’s proposal to remove the Section 515 purchases from their Plan should be rejected.
  2. Equity investments in CDFIs are the single most impactful action that the FHFA could currently take to improve Duty to Serve outcomes. Fannie Mae’s proposal to add equity investments in Native CDFIs to their plan is a step in the direction of better serving Indian Country. For more suggestions on how the Enterprises could better serve Indian Country, see HAC’s comments from the July 2022 Native American Housing Listening Session.

Read HAC’s full comments.

HAC Duty to Serve Plan Modification Comments

HAC also signed on to a letter from the Underserved Mortgage Markets Coalition with a longer set of comments on the proposed modifications.

All the comments received by the FHFA can be viewed here.

 

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HAC Submits Comments on the Greenhouse Gas Reduction Fund

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HAC submitted comments in response to the October 21, 2022 Notice of Proposed Rulemaking on the Greenhouse Gas Reduction Fund (GHGRF) published by the Environmental Protection Agency (EPA). GHGRF is a new program created by the Inflation Reduction Act and will be administered by EPA. This first-of-its-kind program will provide $27 billion in competitive grants to mobilize financing and leverage private capital for clean energy and climate projects that reduce greenhouse gas emissions, with an emphasis on projects that benefit low-income and disadvantaged communities. A wide range of activities, including those related to housing, could qualify for GHGRF.

GHGRF funds are divided into three pools. There are $7 billion for competitive grants to enable low-income and disadvantaged communities to deploy or benefit from zero-emission technologies, including distributed technologies on residential rooftops. Nearly $12 billion will be used for competitive grants to eligible entities to provide financial and technical assistance to projects that reduce or avoid greenhouse gas emissions. Another $8 billion is for competitive grants to eligible entities to provide financial and technical assistance to projects that reduce or avoid greenhouse gas emissions in low-income and disadvantaged communities.

HAC’s comments focused on four main points.

Key Takeaways

  1. Leverage the extensive existing network of CDFIs to ensure rapid, equitable, and widespread investment.
  2. Address the unique needs of rural and persistent poverty communities.
  3. Recognize the key role of housing assistance in meeting GHGRF’s goals.
  4. Include equity principles in all elements of the GHGRF program design.

To learn more about HAC’s full recommendations, read our full comment letter.

GGRFCommentHACFinal

 

HAC Advises Housing Protections and Education for H-2A Farmworkers

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HAC responded on October 24, 2022, to a request for information from the U.S. Department of Agriculture’s Farm Service Agency (FSA), which is developing a Farm Labor Stabilization and Protection Pilot Program.  FSA says this “grant program will use up to $65 million in American Rescue Plan Act funding to provide support for agricultural employers in implementing robust labor standards to promote a safe, healthy work environment for both U.S. workers and workers hired from Northern Central American countries under the seasonal H-2A visa program.”

HAC’s comments noted that currently, the H-2A program requires employers to provide free housing to visa holders that complies with a set of guidelines. While the law requires these living quarters to be inspected before occupancy, Department of Labor (DOL) data shows that neither federal nor state governments have allocated sufficient resources to conduct these inspections. In 38 states, there is no regulation of farmworker housing or dedicated agency to perform the required inspections. States that do have housing inspection systems in place are often under resourced.

Key takeaways:

  • Affordable, Decent Housing

    The pilot program should incentivize accessible, affordable, and decent housing for farmworkers

  • Wellness Checks

    This pilot program should fund farmworker organizations and partner organizations who are on the ground and familiar with farmworker communities to perform regular wellness checks

  • Survey of Conditions

    The pilot program should fund a detailed, comprehensive survey on farmworker housing conditions

  • Appropriate Communication

    Services and information should be provided in appropriate languages and using appropriate communication techniques

  • Training in Rights

    Trainings and informational resources should be made available that cover workers’ rights (including housing) and how to report exploitative practices

Policy News from the Administration

HAC’s Recommendations to the CFPB on HMDA Rule Assessment

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HAC submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) Request for Information regarding the Home Mortgage Disclosure Act (HMDA) Rule Assessment. HAC and our rural stakeholders have relied on HMDA data for decades to improve our understanding of rural mortgage markets. The CFPB will use these stakeholder comments to help better evaluate the effectiveness of these changes in meeting the purposes and objectives of Title X of the Dodd-Frank Act.

Key takeaways:

  • Reporting Threshold

    HAC strongly urges the CFPB to return to the 25-origination reporting threshold, for closed-end loans, as opposed to the new 100-origination threshold, in order to more accurately capture rural markets that are disproportionately served by small financial institutions.

  • Reliability Index

    HAC Recommends that the CFPB resource and publish a HMDA “Reliability Index.” While not a fix for overly limited reporting thresholds, the development of an indicator would be helpful for the CFPB, data users, and consumers.

  • Additional Data

    HAC applauds increased HMDA data reporting, but additional data and reporting are still needed. While the new housing data points – specifically those on manufactured housing – enhance the HMDA data usefulness, more data could improve an understanding of certain underserved markets. This is particularly true when it comes to tribal lands and specific loan programs.

  • Data Browser

    HAC applauds CFPB’s HMDA data browser, which offers improved access to HMDA data over previous interfaces.

Policy News from the Administration

HAC Applauds OCC Rescinding 2020 CRA Rule

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HAC submitted comments in response to the Office of the Comptroller of the Currency’s (OCC) proposal to rescind its June 2020 Community Reinvestment Act (CRA) rule. HAC applauds the OCC’s move to rescind and replace this rule, and we look forward to working together in the future to improve and modernize the CRA in a way that equitably serves rural places. To explore HAC’s 2016 CRA research series, “The Community Reinvestment Act in Rural America,” click here [https://ruralhome.org/rural-cra-resources/].

Key takeaways:

  • Support the CRA

    HAC unequivocally supports the Community Reinvestment Act

  • Opposed June 2020 Rule

    For numerous reasons, HAC did not support the OCC’s June 2020 rule and is glad to see this proposed rescinding

  • CRA Modernization

    OCC should work together with the Board of Governors of the Federal Reserve System and Federal Deposit Insurance Corporation (FDIC) to thoughtfully modernize CRA

  • Promote Equity

    Any CRA modernizations should seek to equitably serves rural places

HAC OCC CRA Rule Rescinded Comment

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