As part of the Duty to Serve program, Fannie Mae and Freddie Mac (the Enterprises) have submitted for comment their proposed 2025-2027 Underserved Markets Plans. Duty to Serve requires the Enterprises to proactively serve three historically underserved markets: rural housing, affordable housing preservation, and manufactured housing. The rule requires each Enterprise to develop three-year Underserved Markets Plans, and these 2025-2027 Plans represent the next upcoming cycle of Duty to Serve activity.

HAC has submitted comments on all three underserved markets. While our comments covered many different topics and aspects of the proposed Plans, some highlights include:

• Duty to Serve goals that rely on low baselines and/or do not scale up year-over-year do not send a message of proactive commitment from the Enterprises. A great deal of work has clearly gone into these Plans, and HAC applauds many of the goals laid forth. However, we continue to feel that, broadly, the Plans are not ambitious enough when compared to the need on the ground in rural areas. The true, yet-untapped potential of Duty to Serve requires the Enterprises to set and stick to ambitious goals, and we encourage that in the 2025-2027 Plans.
• Permitting targeted equity investments in CDFIs is, in HAC’s opinion, the single most impactful action that the FHFA could currently take to improve Duty to Serve outcomes. It would allow community-based nonprofit lenders to bring the power of the Enterprises to markets in which little to no mortgage activity currently occurs, growing new markets for future activity by the Enterprises. We continue to encourage the FHFA to take this opportunity to approve the use of the equity investment tool for CDFIs.
• The preservation of USDA Section 515 multifamily properties must remain a core Duty to Serve goal. Section 515 preservation deals are complex and time consuming, and HAC appreciates the time that both Enterprises have invested in exploring avenues for engagement with the preservation of this important rural rental housing stock. But more ambitious Section 515 preservation goals are needed from both Entreprises, especially Freddie Mac.
• The focus in the proposed Plans on heirs’ property and colonias is welcome. We encourage even more robust goals in these areas, as well as goals specifically for farmworker communities.
• Much more ambitious goals are needed for loan purchases and other activities in Native communities. Housing finance in Native American communities has been a stunning example of both racial and geographic inequity at both the policy and private market levels. Many lenders have all too often chosen to simply not serve these investment-worthy markets. The Enterprises need to set significantly higher loan purchase goals for Native families living in Indian areas.
• Renewed commitment to the purchase of manufactured housing loans titled as personal property is needed. The majority of manufactured homes are financed with personal property, or “chattel,” loans. The Enterprises could play a positive role by bringing chattel loans into their secondary market and encouraging more favorable terms for borrowers who rely on these loans.

HAC DTS 2025-2027 Plan Comments FINAL