Policy News from the Administration

HAC’s Recommendations to the CFPB on HMDA Rule Assessment

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

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
Policy News from the Administration

HAC Recommends a Focus on Racial and Geographic Equity in FHFA Comments

HAC submitted comments in response to the Federal Housing Finance Agency’s (FHFA) Request for Input (RFI) on the Enterprise Equitable Housing Finance Plan framework. Fannie Mae and Freddie Mac (the Enterprises) have been instructed to submit Equitable Housing Finance Plans to FHFA by the end of 2021. The Plans will frame the Enterprises’ goals and action plans to advance equity in housing finance for the next three years. These plans will work alongside other FHFA efforts, including Duty to Serve, the importance of which HAC has long championed. HAC applauds the focus on equity outlined in this RFI, and encourages consideration of the unique needs of rural communities of color in the creation of the Equitable Housing Finance Plans.

Key Takeaways

  • Limited Activity

    Enterprise activity in rural communities of color has been very limited.

  • Support Capacity Building

    Enterprise support for capacity building and access to capital are critical factors necessary to build racial and geographic equity in rural places

  • Rural is Different

    Rural realities must be considered in the creation of the plans

  • Stakeholder participation

    Stakeholder engagement in the process of creating and revising the plans will be key

FHFA Equitable Housing Finance Plan Comments 10.25.21
Policy News from the Administration

HAC Urges Census Bureau to Expand Data Offerings

The Housing Assistance Council (HAC) has submitted comments to the U.S. Census Bureau on its new 2020 Census Data Product Planning Crosswalk

HAC urges the U.S. Census Bureau to provide sub-county geographies in all elements of the new Data Product Planning Crosswalk, as well as all public-use data products it produces. Political and economic geography is an important consideration when determining the population and residential patterns of an area. The county is a commonly used unit of geography. In many rural areas, the county is often identified within political, social, and economic contexts.  However, county-based designations are not the optimum criteria on which to assess or research social, economic and housing conditions.

The Housing Assistance Council is pleased to have this opportunity to provide comments to the U.S. Census Bureau on its new 2020 Census Data Product Planning Crosswalk. HAC looks forward to working with the Census Bureau to continually improve the provision of data for all communities – urban, suburban, and rural.

Read HAC’s Comments.

Policy News from the Administration

HAC’s Statement on the End of the CDC’s Eviction Moratorium

The Housing Assistance Council (HAC) is concerned by the Supreme Court’s decision ending the national eviction moratorium. Without federal protection, hundreds of thousands of families now face the threat of eviction. Across America, many of these families will lose their homes.

“This pandemic and the unprecedented job loss it caused have exacerbated the housing challenges that rural communities have faced for a long time,” stated HAC CEO David Lipsetz. Millions of tenants, homeowners, and landlords across the country have fallen behind on rent and mortgage payments. Rural residents including Native Americans and farmworkers are among the Americans hardest hit by the pandemic and its housing impacts.

The end of the eviction moratorium is particularly troubling because housing loss poses serious dangers for renters’ health, as well as their finances. Eviction increases the risk of COVID-19 transmission and falls hardest on people of color, who are most likely to be evicted. Plus, renters with eviction records find it much harder to rent decent housing in the future since landlords often screen applicants with prior evictions.

Assistance to help cover rent, utilities, mortgages, and other costs is available from the federal government, states, and county or city governments. HAC has compiled links to resources for tenants, homeowners, and landlords on our website: ruralhome.org.

HAC works to ensure that everyone has a safe, decent, and affordable place to call home. We will continue to serve rural communities with dedication and compassion, just as we have for the last 50 years.

Policy News from the Administration

HAC Agrees with HUD Fair Housing Rule

HAC has submitted a comment letter supporting HUD’s proposed cancellation of a fair housing regulation issued by the Trump administration in September 2020. This rule governs fair housing violation claims based on policies or actions with “disparate impacts” on categories of people protected by the Fair Housing Act.

The 2020 HUD rule, which would have made it more difficult to prove a disparate impact claim, never went into effect. A federal judge issued an injunction that left a 2013 disparate impact regulation in place while a lawsuit against the 2020 version was underway.

In June 2021, HUD proposed to reinstate the 2013 rule. HAC – along with thousands of others – supports that action.

As HAC’s comments pointed out:

Fair access to housing is essential. Research shows that decent, affordable housing improves residents’ physical and mental health, their ability to hold jobs, their children’s performance in school. Children’s life chances are deeply impacted by the neighborhoods where they grow up. Enforcing the Fair Housing Act against discrimination, both intended and incidental, helps our nation move towards inclusive and equitable rural, urban and suburban communities, where all residents can thrive.

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.