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HAC Comments on Community Investment Focus on Capacity Building and Capital Access

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

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

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

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

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.