HAC has reviewed, and summarizes below, the housing positions set forth in Mandate for Leadership: The Conservative Promise 2025, which is published by Project 2025 and which describes itself as “the conservative movement’s unified effort to be ready for the next conservative Administration to govern at 12:00 noon, January 20, 2025.” Axios has collected post-election statements by supporters of President-elect Donald Trump stating that this document is their agenda for Trump’s second term.

Across-the-Board Positions

The document’s chapters, written by different individuals, take a variety of approaches, but consistent themes include:

• Put loyal political appointees in all leadership roles and positions of authority.
• Eliminate everything related to equity.
• Eliminate everything related to climate change.

Rural Housing

There is one mention of rural housing, which appears in the document’s HUD chapter as part of a paragraph encouraging Congress to support single-family housing. “Congress can propose tax credits for the renovation or repair of housing stock in rural areas so that more Americans are able to access the American Dream of homeownership.” (HAC’s analysis of Census Bureau data shows that a large proportion of the rural housing stock is neither dilapidated nor rented.)

Although the document has a chapter about USDA, its only mention of USDA’s Rural Housing Service is in the HUD chapter as part of explaining the function of the Government National Mortgage Association. The USDA chapter covers agriculture and food issues only, with nothing about USDA’s Rural Development agencies. It recommends that the department’s role be limited to agriculture and that a limited version of its food and nutrition programs be moved to the Department of Health and Human Services.

Department of Housing and Urban Development

Former HUD Secretary Ben Carson is listed as the author of the chapter on HUD, which asserts the primary importance of single-family homeownership and of local control of zoning and building regulations.

The document recommends several general steps for improving HUD, in addition to the across-the-board positions noted above:

• “Conduct a thorough review of all subregulatory guidance that has been instituted outside of the Administrative Procedure Act.”
• Restrict program eligibility “when admission would threaten the protection of the life and health of individuals and fail to encourage upward mobility and economic advancement through household self-sufficiency.” No details are provided on how such determinations would be made.
• Reduce “the implicit anti-marriage bias in housing assistance programs.”
• Strengthen work and work-readiness requirements.
• Continue “modernization initiatives” for information systems and program offices.
• Provide strong financial controls and financial reporting for HUD.

It also calls for eliminating a number of specific initiatives and approaches:

• End Housing First policies.
• End the Biden Administration’s Property Appraisal and Valuation Equity (PAVE) initiatives and reverse any Biden Administration actions that “threaten to undermine the integrity of real estate appraisals.”
• Repeal the Affirmatively Furthering Fair Housing (AFFH) regulation “and any other uses of special-purpose credit authorities to further equity.”
• Eliminate the Housing Supply Fund. This fund was proposed in President Biden’s 2023 budget, but was not created. It would have provided $25 billion to states and localities for affordable housing production and $10 billion to reduce affordable housing barriers.
• Suspend all external research and evaluation grants in HUD’s Office of Policy Development and Research and “end or realign to another office any functions that are not involved in the collection and use of data and survey administration functions and do not facilitate the execution of regulatory impact analysis studies.”

The chapter seems inconsistent regarding tenant-based vouchers. It states that “the turn toward mobility vouchers constitutes an abandonment of America’s public housing stock.” A few paragraphs later, it recommends that “enhanced statutory authorities for local autonomy should extend to the prioritizing of federal rental assistance subsidies that emphasize choice and mobility in housing voucher subsidies over static, site-based subsidies and provide authority for maximal flexibility to direct PHA land sales that involve the existing stock of public housing units.” When public housing is sold, it says, the land can be “put to greater economic use, thereby benefiting entire local economies through greater private investment, productivity and employment opportunities, and increased tax revenue.”

For renters, the document suggests imposing some new requirements or reviving ones previously attempted:

• Revive a regulation proposed in the previous Trump administration to prohibit noncitizens, including all mixed-status families, from living in all federally assisted housing. This rule was never finalized and was withdrawn in 2021 by the Biden administration.
• Implement unspecified “maximum term limits” for PBRA and TBRA residents.
• Move the Real Estate Assessment Center from PIH to the Office of Housing and consider giving HUD the “flexibility for physical inspections through private accreditation.”
• Make the HUD Secretary a member of the Committee on Foreign Investment in the U.S., “which will gain broader oversight authorities to address foreign threats, particularly from China with oversight of foreign ownership of real estate in both rental and ownership markets of single-family and multifamily housing, with trillions worth of real estate secured across HUD’s portfolio.”

For homebuyers, Project 2025 recommends:

• Limit FHA mortgages to first-time buyers. FHA is also mentioned in the Treasury Department chapter, which asserts that “the missions of the Federal Housing Administration and the Government National Mortgage Association (‘Ginnie Mae’) must [be] right-sized to serve a defined mission,” without providing more detail.
• Encourage shorter FHA mortgages by increasing the FHA mortgage insurance premium for all products above 20-year terms. “FHA should encourage wealth-building homeownership opportunities, which can be accomplished best through shorter-duration mortgages.”

The HUD chapter ends with a sweeping recommendation for statutory change: “Congress could consider a wholesale overhaul of HUD that contemplates devolving many HUD functions to states and localities with any remaining federal functions consolidated to other federal agencies (for example, by transferring loan guarantee programs to SBA; moving Indian housing programs to the Department of the Interior; moving rental assistance, mortgage insurance programs, and GNMA to a redesignated Housing and Home Finance Agency). Generally, this reform path could consolidate some programs, eliminate others that have failed to produce meaningful long-run results, and narrow the scope of many programs so that they are closer to what they were when they were created.”

GSEs, Financial Regulators, and CFPB

Project 2025’s Treasury Department chapter calls for ending the conservatorships of Fannie Mae and Freddie Mac and privatizing both enterprises. It suggests the Federal Reserve should be precluded from any future purchases of mortgage-backed securities and should wind down its MBS holdings.

The Treasury Department chapter also suggests that, to improve efficiency and reduce the size of the government, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Federal Reserve’s non-monetary supervisory and regulatory functions should be merged. Financial firms’ activities should not be restricted and regulations should be reduced. The Community Reinvestment Act is not specifically mentioned.

The document’s chapter on the Consumer Financial Protection Bureau proposes eliminating the agency.

Labor Department

The author of this chapter recommends that, because “the low cost of H-2A workers undercuts American workers in agricultural employment,” the H-2A farmworker visa program should be capped at the current number of annual visas and then phased out over 10 to 20 years. This approach, the document states, can “produc[e] the necessary incentives for the industry to invest in raising productivity, including through capital investment in agricultural equipment, and increasing employment for Americans in the agricultural sector.”

Presenting an “alternative view,” the writer notes that “some conservatives … credibly argue that, absent the H-2A program, many farmers would have to drastically increase wages, raising the price of food for all Americans, and that even such wage increases may not be sufficient to attract enough temporary American workers to complete the necessary farm tasks to get food products to market since those jobs are, by their nature, seasonal.”

This author also proposes that federal contracts should require a high proportion of contractor employees be U.S. citizens and that employers should be permitted to give hiring preference to citizens over work-authorized noncitizens. An “alternative view” holds that the government must limit its spending, so decisions about citizenship requirements for government contractors should be based on cost rather than “arbitrary quotas.”

Federal Emergency Management Agency

Project 2025 calls for reducing FEMA’s responsibilities and its expenditures.

• Wind down and privatize the National Flood Insurance Program.
• End FEMA grants for disaster preparedness.
• Require states and localities to bear most of the cost of disaster response, except for the largest disasters.
• Require states, localities, and private organizations getting FEMA grants to certify that they comply with federal immigration laws. Require state and local governments to certify that all their agencies (not just disaster response agencies) use E-Verify, and that they will share all information with federal law enforcement and immigration enforcement, including department of motor vehicles databases.