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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 Colonia Census Tract Definition

HAC submitted comments in response to the October 5, 2022 Notice of Proposed Rulemaking (NPRM) on the Enterprise Duty to Serve Underserved Markets Amendments published by the Federal Housing Finance Agency (FHFA). HAC has conducted significant research on housing finance, including numerous aspects of Fannie Mae’s and Freddie Mac’s statutory Duty to Serve Underserved Markets. The regulatory change under consideration, in fact, is based on HAC research for Fannie Mae. Thus HAC is well positioned to comment on this proposal.

HAC generally supports FHFA’s proposed definition and use of “colonia census tracts” to target efforts by Fannie Mae and Freddie Mac (the Enterprises) to meet the credit needs of these high-poverty rural areas. As the NPRM explains, the colonia census tract model is based on Colonias Investment Areas, a concept developed by HAC for use by Fannie Mae in meeting its Duty to Serve the colonias. HAC’s research makes clear that using census tracts containing colonias as a basis for identifying and evaluating colonias activities would not only provide clarity, but would also meet the goals of the Duty to Serve statute and regulations.

Key Takeaways

  1. Census tracts are the best available geography for a revised colonia definition, as HAC’s research has demonstrated, and HAC supports FHFA’s proposal to base its definition on tracts.
  2. Focusing activities in the places FHFA identifies as colonias census tracts would meet the goals of the Duty to Serve requirement.
  3. Alternative definitions have proven to be too broad or too difficult to use.
  4. HAC recommends providing greater weight to Duty to Serveactivities incolonia census tracts in rural areas than to those in urban or suburban places, because rural tractshave greater needs.
  5. The colonias census tract database should be updated more often than every ten years if interim changes warrant.

To learn more about HAC’s full recommendations, read our full comment letter.

HAC Final Comments on the Colonias Definition
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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

 

Policy News field

HAC Submits Community Reinvestment Act Comments

 

The Community Reinvestment Act is essential to communities across the nation. Through CRA, financial services have been made available to many places that might otherwise be overlooked. In spring 2022 the three federal agencies that regulate banks and other lenders – the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation – jointly issued a proposed new CRA rule. This proposal, and the many efforts which will follow, are critically important to ensure not only that current CRA-related activities and investments continue but that they expand to reach populations and communities for which access to affordable finance is still elusive.

This is especially important in rural communities across the country as many are considered high credit need areas. CRA modernization will help incentivize more lending in these areas and increase community development activities. As rural communities continue to change, the CRA must adjust as well to reflect modern lending practices. The proposed rule has the potential to further increase lending in high need rural areas, but HAC has a number of recommendations to optimize CRA’s impact.

HAC believes a final rule could further increase CRA’s impact on underserved rural communities if it:

  1. includes activities in rural communities as an additional impact factor, informed by the most precise, density-based definitions already used by policymakers and the research community;
  2. ensures uniform treatment of all CDFIs and supports the most transformative CDFI activities in underserved rural communities;
  3. modifies the definition of affordable housing to enable housing providers to respond effectively to the unique income demographics and constraints on government capacity of rural communities;
  4. clarifies how consequential the impact factors can be for a bank’s community development test performance and overall rating; and
  5. prevents banks with a substantial number of rural assessment areas from “gaming” the NPR’s performance benchmarks under the retail lending test.

To learn more about HAC’s full recommendations, read our full comment letter.

Other comments submitted to OCC are posted online and can be reviewed here.

Rural Placemaking: Making the Most of Creativity in your Community

This issue of Rural Voices examines Creative Placemaking as it is practiced in rural communities. The term “creative placemaking” is only about a decade old, but rural community organizations have long taken on community-building endeavors that have included the arts. Creative placemaking offers the explicit recognition that arts and artists, when fully engaged with local stakeholders, are often a gel or a catalyst toward sustained community betterment and economic growth.

VIEW FROM WASHINGTON

Illuminate, Connect, Energize, and Imagine: The Arts in Rural America
by Jen Hughes

The National Endowment for the Arts offers funding and technical assistance for rural creative placemaking across the United States.

FEATURES

A Tool for Economic Development in the Mississippi Delta
by Chris Masingill

The Delta Creative Placemaking Initiative encourages communities to engage more deeply with the region’s arts and culture sectors.

Housing Developers Come Together with Arts Groups and Artists
by Bob Reeder

An expert advises rural community developers to keep their placemaking work inclusive, culturally relevant, and economically equitable.

Bridging Boundaries: Contributing to Quality of Life on the Reservation
by Joseph Kunkel

A collaborative process encompassing community, culture, and the environment contributes to the success of a tribal development project.

Kentucky Communities Use Their Creative Assets
by Sandi Curd

Placemaking, at its core, is fostering what is abundant in rural Kentucky: a strong sense of place coupled with people dedicated to making their communities stronger.

Placemaking Grants Support Rural Communities

The smART Kinston City Project Foundation in Kinston, NC and the Woodlands Development Group in Elkins, WV will implement rural creative placemaking initiatives during summer and fall 2017.


Rural Voices would like to hear what you have to say about one, or all, of these issues. Please feel free to comment on this story by sending a tweet to #RuralVoicesMag, discuss on the Rural Affordable Housing Group on LinkedIn, or on our Facebook page.

National Catholic Rural Life Offers Consulting for National Grant Opportunity

HAC would like to share the following announcement from the Catholic Campaign for Humand Development about its grant program. For more information, visit www.NCRLC.com or email beth@ncrlc.com.

usccb-logoNCLRC_logo

We are working with the Catholic Campaign for Human Development (CCHD) to offer outreach and complimentary consulting to rural community groups to address poverty. CCHD was created 40 years ago by the U.S. Conference of Catholic Bishops to provide funding to groups of low-income people who are empowered to address the causes of poverty in their communities. CCHD has provided nearly 8,000 grants to community groups that to seek justice and create lasting change for people in poverty. CCHD local and national grants have supported legal advocacy to enforce fair wages, community development lending, environmental justice, affordable housing in low-income neighborhoods, parish based social action organizing, micro-enterprise development, and marketplaces or cooperatives for small businesses, artisans, and growers.

Target applicants are nonprofit groups (501©3) serving low income people. Government and academic institutions are not eligible for this grant. Visit www.NCRLC.com to learn more about CCHD grant guidelines, success stories, and grant writing resources. Have a grant idea or know of a group fighting poverty or injustice? Call 651-962-5955 or email beth@ncrlc.com.

Asset Management Training

To have an event posted on our calendar*, please e-mail Dan Stern. Or send event description or brochure to:

Housing Assistance Council
Attn: Dan Stern
1025 Vermont Avenue, NW
Suite 606
Washington, DC 20005

Or fax to (202) 347-3441
Attn: Dan Stern

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*Calendar Posting Guidelines:

HAC’s calendar posts announcements about periodic conferences, training sessions, audioconferences, and the like. Topics must be relevant to professionals in the rural housing and community development arena. HAC reserves the right to accept or decline any request to post an item. We do not include sessions provided by entities (for-profit or nonprofit) that offer numerous regularly scheduled training events; links to such entities are provided below.

Community Connections
IPED

HUD Calendar
NeighborWorks
Novogradac and Compan

Back to Trainings

Asset Management Training

Start: March 20, 2013
End: March 21, 2013
Location: Jackson, MS
Registration Fee: $75

REGISTER ONLINE

Join the Housing Assistance Council on March 20-21 in Jackson, MS for Asset Management Training. This two-day training is an interactive and highly participatory, hands-on workshop designed for asset managers, property managers, supervisors and Board members with a wide range of professional experience. The curriculum is a required class for the Certified Housing Asset Manager (CHAM) Certification and includes an overview of key property asset management concepts and theories and a review of the responsibilities of key asset management participants, including:

  • Introduction to the Double Bottom Line concept of affordable property ownership – the theory of steering properties toward both business and mission based goals and outcomes.
  • Review of the Life Stages of a Property – review of key asset management functions and responsibilities through the various planning, construction, lease up, operational and disposition phases, with a focus on the critical interrelationship between development and asset management tasks through these stages.
  • Analysis and review of property performance standards, including extensive basic numbers crunching designed to increase understanding of key performance indicators and their relationship to financial and operational health and long-term viability.
  • Analysis of key performance standards analyzed includes Revenue Analysis (occupancy, collections, turnover and turnaround), Expense Analysis (operating costs, benchmarking and trending analysis) and Property Financial Analysis (cash flow, debt coverage).
  • Introduction and review of property financial reports and audits as well as best practices in tracking, measuring and assessing progress toward key operational and financial performance goals.
The registration fee for this course is $75. Unfortunately, HAC is unable to confirm registration for this event without receipt of full payment of the prescribed course fee.
For organizations that are participants in HAC’s RCDI 9, 10, 12 and THRIVE programs, there is no registration fee for this course.

Questions? Contact Shonterria Charleston, (202) 842-8600 Ext. 227.