Policy News from the Administration

HAC Recommends FHFA and the GSEs Prioritize Addressing Inequity

HAC submitted comments in response to the Federal Housing Finance Agency’s (FHFA) Request for Input on the Enterprises’ 2022-2024 Duty to Serve Underserved Markets Plans. Through the Duty to Serve mandate, the Enterprises (Fannie Mae and Freddie Mac) are tasked with increasing liquidity and investment capital in three traditionally underserved markets: Rural Housing, Manufactured Housing, and Affordable Housing Preservation. HAC’s comment noted that secondary housing market policy is and has historically been part of a system that is delivering vastly different outcomes for people depending on where they are born – and this inequity must be addressed by more ambitious Duty to Serve investment and purchase goals.

Key Takeaways from HAC’s Comments

 

  • Be Ambitious

    More ambitious purchase and investment goals are needed as we enter the next phase of Duty to Serve.

  • Prioritize Equity

    Racial and geographic equity should be core to the Duty to Serve mission.

  • Encourage Partnership

    Strong rural partnerships are essential to Duty to Serve’s success.

  • Measure Success

    More transparent data is needed for stakeholders to truly understand and evaluate the success of Duty to Serve.

Policy News from the Administration

HAC Supports USDA’s Interest in Racial Justice, Equity, and Underserved Communities

Federal policy and programs benefit some areas of the United States while harming others. HAC was pleased to see the Administration’s Executive Order On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, published on President Biden’s first day in office. In Section 2 of that Order, we were glad to see “persons who live in rural areas” included in the list of groups who need to be granted “consistent and systematic fair, just, and impartial treatment.” Further, we were glad to see “geographic communities” a category that should be considered when determining an “underserved community.”

On this basis, HAC supports USDA’s efforts to advance justice and equity for communities underserved by USDA itself and by others. HAC’s comments submitted in response to USDA’s request for information on Identifying Barriers in USDA Programs and Services; Advancing Racial Justice and Equity and Support for Underserved Communities at USDA address actions that are necessary in several areas. Building capacity, improving access to capital, increasing flexibility, and engaging with stakeholders are among the subjects addressed in HAC’s comments.

In a similar vein, HAC also recently commented on an administration request for input on equity across all federal agencies.

Policy News from the Administration

HAC Supports Fair Housing Rule

HAC has submitted comments strongly supporting HUD’s decision to replace a fair housing regulation it issued in 2020. The new interim final rule is a positive step in a years-long process to require states, localities, and public housing agencies that receive HUD funds to “affirmatively further fair housing” (AFFH). As HAC’s comments note, working towards equality is essential. It is inherently the right thing to do – and it is crucial because research shows children’s life chances are deeply impacted by the neighborhoods where they grow up. Taking active steps to eliminate discrimination and segregation in homes and neighborhoods through enforcement of the Affirmatively Furthering Fair Housing requirement leads to inclusive and equitable rural, urban and suburban communities, where all residents can thrive.

The interim final rule does not mandate any specific fair housing planning mechanism for recipients of HUD funds. HUD plans to request comments on that subject through a separate notice.

Policy News from the Administration

HAC Recommends Federal Actions for Rural Equity

HAC submitted comments in response to an Office of Management and Budget request for input on whether federal agency policies and actions equitably serve all eligible individuals and communities, including rural residents. Noting that rural and persistently poor places have historically been and continue to be underserved by federal programs, HAC recommended a focus on capacity building, access to capital, and proactive and deliberate tailoring of federal programs to produce lasting rural equity.

Key Takeaways from HAC’s Comments

 

  • Rural Inclusion

    HAC is thrilled to see rural and persistently poor places included explicitly in the Executive Order on equity that President Biden released on his first day in office, and that is the basis for this OMB effort.

  • Historic Disinvestment

    Rural and persistently poor places have historically been and continue to be underserved by federal programs.

  • Focus on Equity

    We need federal focus on capacity building, access to capital, and proactive and deliberate tailoring of federal programs to produce lasting rural equity.

Policy News from Congress

HAC Weighs In on The Federal Reserve’s CRA Plan

The Community Reinvestment Act (CRA) is vitally important to communities across the nation. Through CRA, financial services have been made available to many neighborhoods that would otherwise be overlooked. In speaking of the importance of the CRA, Chairman Powell said, “The CRA plays a vital role in supporting economic opportunity in low-income and minority communities, in both rural and urban areas, and is a top priority for the Federal Reserve.”

The Housing Assistance Council responded to the Federal Reserve System’s Advanced Notice of Proposed Rulemaking on the Community Reinvestment Act to lend our voice to the process and help ensure rural community concerns are included in the discussion. HAC’s comments in response to the ANPR are focused on making sure CRA fulfills its yet unrealized potential in rural communities currently, and in any modernization effort.

HAC’s comments to the FHFA aim to improve Duty to Serve program

The Housing Assistance Council (HAC) offered comments on Duty to Serve as the Enterprises (Fannie Mae and Freddie Mac) react to the housing and economic challenges of the COVID-19 pandemic and work to plan for the future of Duty to Serve. Our country is facing an unprecedented health and economic challenge, and Duty to Serve remains critically important to help rural areas weather the storm.

HAC’s comments covered all three Duty to Serve markets (rural housing, manufactured housing, and affordable housing preservation) and called for:

  • More transparent data availability so that stakeholders can better understand Duty to Serve progress and areas for improvement.
  • Continued investment in building partnerships with existing housing providers including local, regional and national nonprofits; tribes; and Community Development Financial Institutions (CDFIs) who already work in high-need communities,
  • More ambitious loan purchase goals in all three Duty to Serve markets.

HAC firmly sees Duty to Serve as a social justice issue. In an era in which racial and economic inequities are top-of-the-fold news stories, we can use Duty to Serve to go past minimum promised levels of loan purchase and try to fundamentally shift the lives of Black, Hispanic, Indigenous and persistently poor families.

Click here to read HAC’s full comment letter.

HAC’s Response to CRA Modernization Plan

The Housing Assistance Council submitted comments to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) on their proposal to modernize the Community Reinvestment Act.

For numerous reasons, The Housing Assistance Council does not support the OCC and FDIC’s proposal. HAC appreciates efforts and ideas in the plan to improve CRA’s reach and effectiveness in rural communities. These proposed improvements, however, are far outweighed by a considerable number of ill-conceived and unsubstantiated aspects of the plan that run counter to the intent, value, and effectiveness of CRA. Furthermore, the Housing Assistance Council is disappointed that the OCC and FDIC did not include the Federal Reserve as part of this proposal. Uniform implementation and oversight is critical for an effort as far reaching and important as CRA. Additionally, with the health and economic catastrophe created by the COVID-19 pandemic, there should be an indefinite suspension of the CRA comment period. The comment period deadline, which was initially proposed for only 60 days, should have been at least 120 days even under the best of circumstances.

The Housing Assistance Council unequivocally supports the Community Reinvestment Act and what it stands for. In any effort to modernize or modify CRA, it is imperative to fully consider the impact of those modifications and to ensure that CRA continues to build upon its unparalleled legacy of expanding access to financial products and services. HAC believes CRA can be modernized and improved, but it is important to acknowledge that CRA has been responsible for more than $1.5 trillion in capital investments to underserved communities. Without CRA, many communities would lack access to capital, revitalization efforts would have not occurred, and disinvestment would be more common. CRA should build upon its established platform for improving communities’ access to credit, not jeopardize the ethos, intent, and effectiveness of this vital institution.

HAC Comments on HUD's Proposed Rule Change for Mixed-Income Families

In May 2019 HUD proposed a change in regulations that would require public housing authorities and private landlords with HUD-assisted tenants to check tenants’ immigration status and to evict those who are not eligible for HUD aid. (Eligibility is not determined solely by citizenship or undocumented status. Some non-citizens who are legally in the U.S. are eligible and others are ineligible.) Currently, when ineligible immigrants have family members such as citizen children who are eligible, the dollar amount of the assistance is pro-rated and all members of the mixed-status family are allowed to live in the unit. The change would mean ineligible family members would have to separate from their families, or entire families would have to move out of their homes in order to stay together.

HUD received over 30,000 comments on its proposal. HAC submitted comments opposing the change. 

HAC Shares Comments on OCC's "Reforming the Community Reinvestment Act Regulatory Framework" ANPR

The Housing Assistance Council (HAC) is presenting its comments to the Office of the Comptroller of Currency (OCC) on its “Reforming the Community Reinvestment Act Regulatory Framework” Advanced Notice of Proposed Rulemaking (ANPR). Through this ANPR, the OCC is seeking stakeholder comments on avenues to modernize CRA and increase lending and investment where it is needed most, reduce reporting burden, and assess performance, all in a manner consistent with the statute’s original purpose. Given its organizational focus on rural housing, HAC has prioritized its remarks related to questions and issues that most impact rural communities and consumers. 

Download HAC’s Comments: PDF

HAC Shares DRAFT Comments on USDA Proposed Rule on Income Banding

The Housing Assistance Council is making available its DRAFT comments on USDA’s proposed rule published August 31, 2018, The proposal seeks to amend USDA’s regulations to implement a two-tier income limit structure and revise the methodology to determine area loan limits for its Single Family Housing direct loan and grant programs and make other changes. The proposed change to the income limit structure is intended to minimize the observed disconnect between minimum wages and the low median income in many areas. The proposed change to the Area Loan Limit methodology is intended to streamline the process and improve the reliability of the data set used to establish the area loan limits. HAC agrees that these are desirable goals. However, we are concerned that the proposed solutions will divert limited program resources to applicants with much higher incomes. HAC strongly urges the Agency to take positive steps to assure the program continues to serve those who are most in need. Comments are due to the Agency on or before October 30, 2018.

Download HAC’s Draft Comments: PDF | Word