HAC Submits Comments on Proposed Duty to Serve Modifications

December 6, 2022/in Advocacy, Federal Register Comments, News, Policy CDFI, Duty to Serve, Native American Lands

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

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.
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.

HAC’s Comments on Duty to Serve for Native American Communities

July 13, 2022/in Advocacy, Policy Duty to Serve, High Need Regions, Native American, Native American Lands, Vulnerable Populations

The FHFA requested comments on Fannie Mae and Freddie Mac’s Duty to Serve plans for Native American communities. Dave Castillo, CEO of Native Community Capital and a HAC Board Member, provided oral comments, accompanied by longer written comments, on behalf of HAC. 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 for decades. If implemented robustly, Duty to Serve has the potential to improve the lives of people living in the most underserved communities. HAC has several improvements that we think should be made to best serve Native communities’ need:

Key Takeaways

Allow GSE Equity Investments for Native CDFIs
Equity investments would allow CDFIs serving Native communities to strengthen their capital structures, leverage additional debt capital, and, as a result, increase lending and investing in their communities.
Increase purchase goals for mortgages on Native lands
Fannie Mae has no set goal and Freddie Mac’s is very modest. Increasing these would show the Enterprises’ commitments to Native housing and help Native communities house more people adequately.
Establish Native lending teams
These teams would focus on Native communities and help ensure that these communities are treated equitably and with cultural competency.
Create Native-tailored mortgage products
Tribal lands have unique property ownership structures and creating loan structures that can meet Native communities’ specific needs would help increase investments and economic growth.
Increase LIHTC investment in Native communities
Despite how successful LIHTC has been in many communities, rural and Native communities have not been able to benefit equitably from these tax credits. The Duty to Serve plans have goals to invest in rural communities but adding goals for Native communities specifically would ensure that they are served as well.

Read HAC’s Comments

HAC DTS Rural Native Housing Listening Session Comments 07.13.22

Race and Ethnicity in Rural America - Rural Research Brief

Housing Assistance Council

The United States is Becoming More Racially Diverse – And So is Rural America

September 28, 2021/in Information Products, Rural Research Briefs Rural Data, Rural Demographics

Race and ethnicity are central and often complex components of our national identity, history, and struggles. Racial dynamics also manifest themselves in our geographies and communities. Rural communities across the United States are comprised of many races, ethnicities, and cultural histories that have been essential to the story of the nation. Contrary to the long-standing narrative of racial and ethnic homogeny across rural America, many racial and ethnic groups are represented in rural communities.

Using the Census Bureau’s recently released P.L. 94-171 Redistricting data, the Housing Assistance Council (HAC) presents an initial review of characteristics, trends, and issues related to race and ethnicity in rural America.

HUD Releases Native American Housing Studies

January 23, 2017/in News Native American, Native American Lands, U.S. Department of Housing and Urban Development

American Indian tribes are building more housing units after enactment of the Native American Housing Assistance and Self-Determination Act of 1996 (NAHASDA) but housing conditions are substantially worse among American Indian households than other U.S. households. These are some of the findings of three new comprehensive reports of tribal housing needs just released by the U.S. Department of Housing and Urban Development (HUD) and the Urban Institute.

Special circumstances on tribal areas — remoteness, lack of infrastructure, complex legal issues and other constraints related to land ownership — make it extremely difficult to improve housing conditions in some areas, according to the reports. Based on the assessments of doubled up households and the number of severely distressed housing units in tribal areas, it is estimated that 68,000 more units are needed to replace severely inadequate units and to eliminate overcrowding in tribal areas. While tribes have been able to use NAHASDA funds effectively, their purchasing power has been eroded by inflation.

Key findings from the Housing Needs of American Indians and Alaska Natives in Tribal Areas report:

Housing conditions vary by region but are substantially worse overall among American Indian and Alaska Native households in tribal areas than among all U.S. households, with overcrowding being especially severe.
Physical deficiencies in plumbing, kitchen, heating, electrical, and maintenance issues were found in 23 percent of households in tribal areas, compared to 5 percent of all U.S. households.
Overcrowding coupled with another physical condition problem was found in 34 percent of households in tribal areas, compared to 7 percent of all U.S. households.
The percentage of households with at least one “doubled-up” person staying in the household because they have nowhere else to go was 17 percent, estimated to be up to 84,700 people.

Key findings from the Mortgage Lending on Tribal Land report:

While Native Americans value homeownership as much as other Americans, mortgage lending is limited in Indian Country because reservation land is held in trust and cannot be used to secure a mortgage loan.
Since 1994, nearly half of mortgage loans originated on tribal lands were in Oklahoma (45 percent by number and 37 percent by dollar value). The entire state of Oklahoma is considered an ‘eligible area,’ the state has no tribal trust areas, there are several participating lenders in the state, and many Native Americans live in Oklahoma.

Key findings from the Housing Needs of American Indians and Alaska Natives in Urban Areas report:

Native Americans are becoming more urban but are still less likely to live in a city than other Americans. Even within urban areas, these households often live in census tracts within or near a village or reservation.
American Indian and Alaska Native households are more likely to occupy worse housing than the rest of the population and more likely to be overcrowded.
American Indian or Alaska Native individuals leave their village or reservation due to lack of opportunities and some people cycle back and forth between their tribal home and a nearby primary city.
For Native Americans who struggle to transition from a village or reservation to an urban area, there are a specific set of challenges, including lack of familiarity with urban life and urban housing markets, lack of employment, limited social networks, insufficient rental or credit history, and race-based discrimination.

HAC News: December 12, 2012

December 12, 2012/in HAC News

HAC News Formats. pdf

December 12, 2012
Vol. 41, No. 24

• Congressional committee leaders announced • Streamlining HUD’s rental assistance again considered by Senate committee • Lead paint grants offered • Final rule issued for IHBG and Title VI loan guarantees • Input sought on Native American access to capital and credit • Downpayment sources for FHA mortgages addressed • HUD report shows homelessness rate statistically unchanged • Concentration of poverty growing in nonmetro areas, ERS reports • Rural poverty and housing need persist, HAC report says • HAC honors six for rural housing work

December 12, 2012
Vol. 41, No. 24

CONGRESSIONAL COMMITTEE LEADERS ANNOUNCED. Key positions will change in the 113th Congress, which starts in January. On the House Financial Services Committee, Rep. Jeb Hensarling (R-TX) will be the new chairman and Rep. Maxine Waters (D-CA) will be the new ranking member (top Democrat). For the Appropriations Committee, Rep. Nita Lowey (D-NY) will be the new ranking member, while Rep. Harold Rogers (R-KY) continues as chairman. Some House subcommittee leadership spots and Senate positions will also change but have not yet been announced. The HAC News will provide further updates as available.

STREAMLINING HUD’S RENTAL ASSISTANCE AGAIN CONSIDERED BY SENATE COMMITTEE. The Senate Banking, Housing and Urban Affairs Committee held a second hearing December 11 titled “Streamlining and Strengthening HUD’s Rental Housing Assistance Programs.” The first hearing on this subject was held in August.

LEAD PAINT GRANTS OFFERED. Applications are due February 4 for HUD’s Lead-Based Paint Hazard Control Grant and Lead Hazard Reduction Demonstration Grant programs, subject to congressional appropriation of program funds for FY13. States, counties, tribes, and other local governments are eligible, and funds can be used in owner-occupied or rental housing. Contact Michelle M. Miller, HUD, 202-402-5769.

FINAL RULE ISSUED FOR IHBG AND TITLE VI LOAN GUARANTEES. Changes in the regulations reflect consensus decisions by HUD and tribal representatives in a negotiated rulemaking process and implement changes enacted in several statutes, including the 2008 NAHASDA reauthorization act. Contact Rodger J. Boyd, HUD, 202-401-7914.

INPUT SOUGHT ON NATIVE AMERICAN ACCESS TO CAPITAL AND CREDIT. The CDFI Fund requests comments from tribes and others on research about access to capital and credit in Native communities, updating a 2001 study. It hopes to provide a baseline of information on the subject and to identify barriers and provide options to address them. Comments can be submitted in writing or in webcast meetings on January 15 and 17. Contact CDFI Fund staff.

DOWNPAYMENT SOURCES FOR FHA MORTGAGES ADDRESSED. Comments are due January 4 on a regulation clarifying that state and local government programs that provide funds for all or part of homebuyers’ downpayments for FHA mortgages are exempt from statutory prohibitions on some sources of downpayment funds. Contact Millicent Potts, HUD, 202-708-2212.

HUD REPORT SHOWS HOMELESSNESS RATE STATISTICALLY UNCHANGED. Data collected in January 2012 shows the number of homeless people nationwide almost the same as in January 2011, although there were increases and decreases in some states, and homeless veterans declined by 7%. The 2012 Annual Homeless Assessment Report counts people in shelters, transitional housing, safe havens, and places not intended for human habitation. Data for every state and Continuum of Care are also posted.

CONCENTRATION OF POVERTY GROWING IN NONMETRO AREAS, ERS REPORTS. An analysis of American Com-munity Survey data by USDA’s Economic Research Service found that many counties with newly high poverty rates are adjacent to those that had high poverty rates in 2000. ERS’s findings are similar to HAC’s in Taking Stock (see next article below) and HAC’s accompanying poverty map; the two analyses were conducted independently and use different definitions of rural.

RURAL POVERTY AND HOUSING NEED PERSIST, HAC REPORT SAYS. HAC’s decennial analysis of data from the Census and other sources describes demographic changes such as growth in the elderly and Hispanic populations, economic challenges like the foreclosure crisis, and ongoing housing problems including high housing costs, homelessness, and housing quality issues. HAC also looked in depth at five high needs regions and populations including the colonias near the U.S.-Mexico border, Central Appalachia, the Mississippi Delta, Native American lands, and farmworkers. Taking Stock: Rural People, Poverty, and Housing in the 21st Century is free on HAC’s site or $30 from HAC, including shipping and handling.

HAC HONORS SIX FOR RURAL HOUSING WORK. At the National Rural Housing Conference last week, HAC presented the Skip Jason Community Service Award to John David, founder and director of the Southern Appalachian Labor School in West Virginia; Owyne Gardner, T&MA Regional Manager at Little Dixie Community Action Agency in Oklahoma; Al Gold, Executive Director of Community Resources and Housing Development Corporation in Colorado; and Patty Griffiths, Housing Program Manager for the Community Action Commission of Fayette County in Ohio. The Cochran/Collings Award for Distinguished Service in Housing for the Rural Poor went to Shirley Sherrod, founder of the Sherrod Institute in Georgia. Rep. Barney Frank of Massachusetts, retiring after more than 20 years in Congress, received the Henry B. Gonzáles Award.

HAC Submits Comments on Proposed Duty to Serve Modifications

December 6, 2022/in Advocacy, Federal Register Comments, News, Policy CDFI, Duty to Serve, Native American Lands

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

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.
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.

HAC’s Comments on Duty to Serve for Native American Communities

July 13, 2022/in Advocacy, Policy Duty to Serve, High Need Regions, Native American, Native American Lands, Vulnerable Populations

The FHFA requested comments on Fannie Mae and Freddie Mac’s Duty to Serve plans for Native American communities. Dave Castillo, CEO of Native Community Capital and a HAC Board Member, provided oral comments, accompanied by longer written comments, on behalf of HAC. 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 for decades. If implemented robustly, Duty to Serve has the potential to improve the lives of people living in the most underserved communities. HAC has several improvements that we think should be made to best serve Native communities’ need:

Key Takeaways

Allow GSE Equity Investments for Native CDFIs
Equity investments would allow CDFIs serving Native communities to strengthen their capital structures, leverage additional debt capital, and, as a result, increase lending and investing in their communities.
Increase purchase goals for mortgages on Native lands
Fannie Mae has no set goal and Freddie Mac’s is very modest. Increasing these would show the Enterprises’ commitments to Native housing and help Native communities house more people adequately.
Establish Native lending teams
These teams would focus on Native communities and help ensure that these communities are treated equitably and with cultural competency.
Create Native-tailored mortgage products
Tribal lands have unique property ownership structures and creating loan structures that can meet Native communities’ specific needs would help increase investments and economic growth.
Increase LIHTC investment in Native communities
Despite how successful LIHTC has been in many communities, rural and Native communities have not been able to benefit equitably from these tax credits. The Duty to Serve plans have goals to invest in rural communities but adding goals for Native communities specifically would ensure that they are served as well.

Read HAC’s Comments

HAC DTS Rural Native Housing Listening Session Comments 07.13.22

Housing Assistance Council

The United States is Becoming More Racially Diverse – And So is Rural America

September 28, 2021/in Information Products, Rural Research Briefs Rural Data, Rural Demographics

Race and ethnicity are central and often complex components of our national identity, history, and struggles. Racial dynamics also manifest themselves in our geographies and communities. Rural communities across the United States are comprised of many races, ethnicities, and cultural histories that have been essential to the story of the nation. Contrary to the long-standing narrative of racial and ethnic homogeny across rural America, many racial and ethnic groups are represented in rural communities.

Using the Census Bureau’s recently released P.L. 94-171 Redistricting data, the Housing Assistance Council (HAC) presents an initial review of characteristics, trends, and issues related to race and ethnicity in rural America.

HUD Releases Native American Housing Studies

January 23, 2017/in News Native American, Native American Lands, U.S. Department of Housing and Urban Development

American Indian tribes are building more housing units after enactment of the Native American Housing Assistance and Self-Determination Act of 1996 (NAHASDA) but housing conditions are substantially worse among American Indian households than other U.S. households. These are some of the findings of three new comprehensive reports of tribal housing needs just released by the U.S. Department of Housing and Urban Development (HUD) and the Urban Institute.

Special circumstances on tribal areas — remoteness, lack of infrastructure, complex legal issues and other constraints related to land ownership — make it extremely difficult to improve housing conditions in some areas, according to the reports. Based on the assessments of doubled up households and the number of severely distressed housing units in tribal areas, it is estimated that 68,000 more units are needed to replace severely inadequate units and to eliminate overcrowding in tribal areas. While tribes have been able to use NAHASDA funds effectively, their purchasing power has been eroded by inflation.

Key findings from the Housing Needs of American Indians and Alaska Natives in Tribal Areas report:

Housing conditions vary by region but are substantially worse overall among American Indian and Alaska Native households in tribal areas than among all U.S. households, with overcrowding being especially severe.
Physical deficiencies in plumbing, kitchen, heating, electrical, and maintenance issues were found in 23 percent of households in tribal areas, compared to 5 percent of all U.S. households.
Overcrowding coupled with another physical condition problem was found in 34 percent of households in tribal areas, compared to 7 percent of all U.S. households.
The percentage of households with at least one “doubled-up” person staying in the household because they have nowhere else to go was 17 percent, estimated to be up to 84,700 people.

Key findings from the Mortgage Lending on Tribal Land report:

While Native Americans value homeownership as much as other Americans, mortgage lending is limited in Indian Country because reservation land is held in trust and cannot be used to secure a mortgage loan.
Since 1994, nearly half of mortgage loans originated on tribal lands were in Oklahoma (45 percent by number and 37 percent by dollar value). The entire state of Oklahoma is considered an ‘eligible area,’ the state has no tribal trust areas, there are several participating lenders in the state, and many Native Americans live in Oklahoma.

Key findings from the Housing Needs of American Indians and Alaska Natives in Urban Areas report:

Native Americans are becoming more urban but are still less likely to live in a city than other Americans. Even within urban areas, these households often live in census tracts within or near a village or reservation.
American Indian and Alaska Native households are more likely to occupy worse housing than the rest of the population and more likely to be overcrowded.
American Indian or Alaska Native individuals leave their village or reservation due to lack of opportunities and some people cycle back and forth between their tribal home and a nearby primary city.
For Native Americans who struggle to transition from a village or reservation to an urban area, there are a specific set of challenges, including lack of familiarity with urban life and urban housing markets, lack of employment, limited social networks, insufficient rental or credit history, and race-based discrimination.