Rural Recap – Promoting Prosperity

Rural communities need—and deserve—a coherent, national policy strategy that promotes prosperity. For such a strategy to move the needle, it must end the housing affordability crisis and build the capacity of rural communities to make the most of every opportunity.

Our homes are part of the foundation of thriving families and communities—they are pathways to realizing America’s full potential. With decent, healthy, and affordable homes, kids can succeed at school, seniors can age in place, and families can build wealth. Economics, health, education, and many more components of prosperous communities are all intimately tied to our homes.

The capital needed for a housing market to function is a lot like water: it flows down the path of least resistance, and it pools. For over 50 years—whether intentionally or not—public policy has channeled capital’s flow into sprawling metropolitan regions and allowed it to pool in suburbs and downtown commercial centers. This has deepened inequality and stifled opportunity in the communities that have been left out.

Building rural prosperity will happen one nail and one funding application at a time. Turning those into a national renaissance for rural America will take strategy. If we want investment to flow to a broader set of places and especially to the people and places which need it most, then we need public policy specifically designed to drive resources in their direction. To make the most of that capital, we must also build the capacity of those communities.

HAC builds the capacity of small towns and rural places to create thriving, prosperous communities. If you share our mission, please advocate on behalf of public funds for capacity building programs. We also hope you will consider making a gift to HAC to help us do more in rural America.

Policy News town

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.


Building on Two Decades of Partnership: HAC & the New Mexico Mortgage Finance Authority

In the summer of 2022, the New Mexico Mortgage Finance Authority (MFA) faced a difficult challenge. Several state legislators and farmworker groups asked the organization to help meet the housing needs of migrant and seasonal farmworkers. Since farms employ farmworkers with the shifting seasons, many farmworkers only stay in a community for a few months before needing to move elsewhere in search of work. Affordable housing development is complex in the best of cases. Underwriting a project that would have a near complete turnover of residents every four or five months seemed almost impossible.

So, MFA called the Housing Assistance Council (HAC). This wasn’t the first or second time that HAC helped MFA address challenges in its programs. In fact, HAC and MFA have a working relationship well over two decades old. Because of this extensive engagement, MFA Executive Director and CEO Izzy Hernandez knew he could rely on HAC Housing Consultant Eugene (Gene) Gonzalez to help find a solution to this challenge.

Gene connected MFA with groups across the southwest working on similar projects housing migrant farmworkers. With HAC’s help and advice from peers, MFA was able to identify a developer and line up alternate financing options for a project that meets this critical housing need. The development is in its initial phase, but for Hernandez, this is just the latest example of HAC’s reliable, ongoing partnership.

HAC began working with MFA in the early 2000s. A few years earlier, MFA was selected to administer all of New Mexico’s housing programs. Many of the on-the-ground housing organizations who needed MFA funding the most were struggling to obtain designation as community housing development organizations (CHDOs). CHDO designation is a prerequisite to accessing the federal and state programs MFA administered. So, HAC helped eight organizations identify their capacity needs, provided technical assistance to meet those needs, and guided them through the process to obtain CHDO designation.  As a result, each of the eight organizations was able to access MFA funds, which allowed MFA to turn those program dollars into homes in communities that desperately needed them.

While the specifics of HAC and MFA’s collaboration has evolved over time to meet the unique needs of each project, the core challenge HAC helps MFA address remains the same. Like all state housing authorities, MFA relies on the success of its client housing organizations. If they do not succeed, MFA cannot make the most of federal and state programs and cannot meet, as Hernandez puts it, “the extraordinary need for affordable housing.” HAC has long helped and continues to help build the capacity of MFA clients. This not only helps to build more affordable homes in rural New Mexico; according to Hernandez, HAC’s work helps MFA “reach communities we couldn’t reach before.”

When HAC began working with Tierra Del Sol Housing Corporation, one of MFA’s clients, the organization was rehabbing nearly 100 homes per year and building only about nine units per year. HAC provided training and technical assistance to help Tierra Del Sol with land acquisition, green building, energy efficiency, and more. With HAC’s help, the nonprofit expanded its self-help program, began building entire neighborhoods of farmworker housing, and grew to become the largest housing rehabber in the state of New Mexico. In addition, TDS accomplished all this development while focusing work in colonias, communities near the U.S.-Mexico border characterized by high poverty rates and substandard living conditions. Looking back on this incredible success, Hernandez is quick to say that “HAC has played a big role in that.”

Nowadays, MFA frequently refers struggling clients to HAC. Once referred, HAC often includes these organizations in our capacity building and technical assistance cohorts, where they receive one-on-one technical guidance and capacity building assistance. According to Hernandez, whenever HAC receives a new round of funding for technical assistance, he receives a call from Gene asking which groups in New Mexico need help. “We have some groups that were on the bubble of surviving or not,” says Hernandez, “but we have never had one group go out of business. HAC kept them in the game.”

The three hundred plus housing organizations in New Mexico all play an important role in meeting the state’s housing needs. In 2021, they collectively assisted more than 25,000 families in finding quality affordable housing. HAC capacity building assistance helps to ensure that these groups can build homes, effectively implement housing assistance programs, and remain in compliance.

Click here to learn more about HAC’s training and technical assistance. 

Policy News field

HAC’s Research Director Testifies on Persistent Poverty on Capitol Hill

On Tuesday, November 15, 2022 at 10:00 am EST the Subcommittee on Housing, Community Development and Insurance convened a hybrid hearing entitled, “Persistent Poverty in America: Addressing Chronic Disinvestment in Colonias, the Southern Black Belt, and the U.S. Territories.” Lance George, HAC’s Director of Research and Information, provided testimony during the hearing.

Watch the Hearing

For more information on Persistent Poverty, read The Persistence of Poverty in Rural America.

AYUDA Proves Impact of Holistic Rural Housing Support

Almost every local housing nonprofit begins with a vision: meeting the housing needs of their community. Unfortunately, the path from recognizing that need to meeting it can be difficult. Labor shortages, increasing construction costs, and the complexity of financial transactions and government programs can all make it challenging for housing non-profits to succeed. 

That’s why the Housing Assistance Council (HAC) works with housing organizations across rural America to help them overcome both financial and technical challenges. HAC’s goal, as Director of Training and Technical Assistance Shonterria Charleston puts it, is to “create a pipeline for capacity building that allows our partners to get many of their needs met by one organization.”  

For thirty years, Adults and Youth United Development Association (AYUDA) has worked to improve housing conditions and increase access to public services in the colonias in and around San Elizario, Texas. According to AYUDA’s Housing and Community Services Director Miguel Chacon, the group was established to advocate for running water and septic tanks in colonias but has grown to providing home repair, rental assistance, vaccine outreach, food distribution, and more.  

As AYUDA has grown, it’s turned to HAC for support. For twelve years, HAC Housing Specialist Anselmo Telles and Housing Development Consultant Eugene Gonzales have provided technical assistance to help AYUDA navigate the hurdles of managing new and expanded housing programs. “I didn’t know anything about housing back then,” remembers Miguel. But, with HAC’s help, AYUDA has developed deeply impactful housing programs. Between 2016 and 2021, AYUDA built or rehabbed over 200 homes. Despite this track record, AYUDA ran into a problem in early 2021.  

“We were having trouble with our cash flow,” Miguel explains. AYUDA’s home repair and construction programs are financed by the Texas Department of Housing and Community Affairs (TDHCA). Still reeling from the COVID pandemic, the Department was taking months to reimburse AYUDA for the costs of rehab and construction. This put AYUDA in a difficult position. They could stop work while waiting for payments from TDHCA or they could keep their projects moving forward while struggling to pay their contractors on time.  

“As I do the organizational assessment, I look to see if they need money for construction, staffing, or anything like that,” Eugene explains. It was during an organizational assessment of AYUDA that he saw that cash flow was the largest bottleneck in AYUDA’s construction process. So, Eugene reached out to Kristin Blum, HAC’s Senior Loan Officer, to see if our Loan Fund could help. Kristin notes that we wanted to be creative and find a solution that worked for AYUDA. As HAC’s Director of Lending Eileen Neely points out, HAC doesn’t try to fit organizations into boxes. Instead, we focus on understanding each group’s unique needs and tailoring financing to help them achieve their goals.  

After meeting with both AYUDA and HAC’s technical assistance team, the Loan Fund came up with a creative financing option. The plan was to establish a $367,000 revolving line of credit. When AYUDA would complete a new home or rehab project, it could draw on this line of credit to bridge the funding gap until TDHCA issued grant reimbursements.  

In July 2021, the loan was approved, and AYUDA began to draw on its new line of credit just two months later. According to Miguel, this capital ensured that AYUDA was able to keep building and keep moving forward. Pointing to the 25 homes AYUDA has built or rehabbed in the last year, Miguel explains that “we were able to accomplish that because of the line of credit.” 

The upshot of HAC’s holistic approach to capacity building is, according to Eugene, “that groups get the money they need, and then TA comes in to make sure they’re on track.” Ultimately, this means groups can build more affordable homes. Miguel shared that when AYUDA was weighing whether to halt construction at the beginning of the pandemic, his clients urged AYUDA to find a way to keep going. With HAC’s help, AYUDA kept building throughout 2020 and 2021. “That gave our community hope,” says Miguel.  

The collaboration between HAC’s lending and technical assistance made both more effective. Our Loan Fund would have never known about AYUDA’s challenges without Eugene. As Kristin notes, collaboration is what made this loan possible in the first place. Plus, as Eugene explains, the on-going technical assistance relationship gave the Loan Fund a sense of confidence that this financing solution would work.  

By pairing technical assistance and lending, HAC also helped AYUDA expand its capacity as an affordable housing non-profit. Miguel says that AYUDA never had a line of credit before. Now, his staff have experience as borrowers, with more knowledge about how to navigate the financing process and manage tasks like fulfilling reporting requirements. The financial stability afforded by this line of credit and the support of technical assistance make it easier for the organization to expand the programs it offers. In fact, the State of Texas has tapped AYUDA to manage American Rescue Plan rental assistance across a four-county service area. His organization’s growing capacity gives Miguel the confidence to say that there’s nothing they can’t learn. 

The story of HAC’s work with AYUDA isn’t an isolated example—it’s how HAC operates. HAC regularly includes borrowers in our technical assistance rounds and makes loans to current TA recipients. As Shonterria notes, “the Loan Fund is our first stop when we work with a group that needs capital.” The years-long relationships built by HAC housing specialists make it easier to craft lending products to fit each group’s needs. “The more we know about a potential borrower and their mission, the better we are at what we do,” explains Eileen.  

HAC is committed to building the capacity of our local partners, expanding their ability to meet their neighbors’ housing needs. No organization faces only technical challenges or financial hurdles—every organization grapples with both, at one point or another. By working with groups holistically, we help them overcome whatever challenges come their way.  

Click here to learn more about HAC’s lending products, and click here to learn more about HAC’s training and technical assistance.  

Policy News field

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

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.

HAC in the News

Rural Veterans and Local Nonprofits Receive Critical Housing Support

Contact: Dan Stern,
AHRV Team,
(202) 842-8600

Rural Veterans and Local Nonprofits Receive Critical Housing Support

Funded by The Home Depot Foundation

Washington, DC, June 7, 2022 – Veterans and their families in thirteen rural communities will have better lives, thanks to The Home Depot Foundation and the Housing Assistance Council. The Foundation is awarding grants totaling $375,107 to thirteen local nonprofit housing agencies around the country to preserve housing for veterans in rural America.

The grants are part of The Home Depot Foundation’s mission to improve the homes and lives of U.S. veterans and invest $500 million in veteran causes by 2025. Many veterans and their families face major housing challenges, often exacerbated by issues related to unemployment, age, and service-related disabilities. The Home Depot Foundation and the Housing Assistance Council (HAC) are dedicated to giving back to those who have answered the highest call of service to our nation.

As part of its Affordable Housing for Rural Veterans (AHRV) Initiative, HAC works with The Home Depot Foundation to administer grants that bolster and support the work of rural nonprofit housing agencies to deliver critical housing support to veterans. “HAC’s partnership with The Home Depot Foundation continues to be a vital factor in our ability to strengthen the capacity of local rural organizations in their efforts to build and preserve homes of veterans across rural America,” said David Lipsetz, HAC’s CEO. “Growing nonprofit capacity empowers communities and serves as an impact multiplier, enabling nonprofits to expand their services and assist more veterans with overcoming housing challenges.”  As rural America is home to a disproportionately high number of service women and men, HAC remains deeply committed to supporting our nation’s service women and men by uplifting local nonprofits and their work to house and ensure the safe habitability of their homes and rural communities.

The grantee organizations – described below – provide a range of programs. With the grants, veterans who own homes in Arkansas, Arizona, Louisiana, Mississippi, North Dakota, New York, Pennsylvania, South Dakota, Texas, Wisconsin, and West Virginia will obtain critical repair assistance. Altogether, 65 veterans and their families will benefit from these grants.

About The Home Depot Foundation 

The Home Depot Foundationworks to improve the homes and lives of U.S. veterans, support communities impacted by natural disasters and train skilled tradespeople to fill the labor gap. Since 2011, the Foundation has invested more than $400 million in veteran causes and improved more than 50,000 veteran homes and facilities. The Foundation has pledged to invest half of a billion dollars in veteran causes by 2025 and $50 million in training the next generation of skilled tradespeople through the Path to Pro program.

To learn more about The Home Depot Foundation visit HomeDepotFoundation.organd follow us on Twitter @HomeDepotFound and on Facebook and Instagram @HomeDepotFoundation.

About the Housing Assistance Council

The Housing Assistance Council (HAC) is a national nonprofit that supports affordable housing efforts throughout rural America. Since 1971, HAC has provided below-market financing for affordable housing and community development, technical assistance and training, research and information, and policy formulation to enable solutions for rural communities.

About the Grantees

  • Adults and Youth United Development Association, Inc., San Elizario, TX, will utilize $30,000 to provide needed critical repairs for ten (10) veterans in the Border Colonia area of the state of Texas. For additional information on Adults and Youth United Development, Inc., visit their Facebook page at
  • Bethlehem Farms, Inc., Alderson, WV, will utilize $30,000 to support rehabilitation and modification of eight (8) veteran homes, prioritizing critical repairs to remove unsafe living conditions. For additional information on Bethlehem Farms, Inc., visit their website at
  • Eureka Christian Health Outreach, Eureka Springs, AR, will utilize $28,350 to support the development of one (1) “small home” which will become part of the Echo Village community, which serves veteran residents with temporary housing together with access to critical counseling, medical, skills training, social services, and “best life possible” supportive services. For additional information on Eureka Christian Health Outreach, visit their website at
  • Good Works, Inc., Coatesville, PA, will utilize $14,891 to provide critical health and safety repairs to one (1) home of an elderly veteran. For additional information on Good Works, Inc., visit their website at
  • GROW South Dakota, Sisseton, SD, will utilize $30,000 to provide critical home repairs for six (6) veterans. For additional information on GROW South Dakota, visit their website at
  • Habitat for Humanity Wisconsin River Area, Baraboo, WI, will utilize $30,000 to support critical repairs and accessibility modifications for five (5) rural low-income disabled veterans. For additional information on Habitat for Humanity Wisconsin River Area, visit their website at
  • Hope for All, Mountain Home, AR, will utilize $31,866 to support the renovation and structural repairs to a seventy (70) year old home, used as a homeless shelter to assist four (4) rural veterans. For additional information on Hope for All, visit their website at
  • Mississippi Center for Police & Sheriffs, Raymond, MS, will utilize $30,000 to assist in the construction of one (1) veteran cottage, which will become part of a fifteen (15) unit “Warrior Cottages” housing complex meeting the need for emergency and transitional housing for veterans. For additional information on the Mississippi Center for Police & Sheriffs, visit their Facebook page at
  • Rebuilding Together Fargo-Moorhead Area, Fargo, ND, will utilize $30,000 to support the rehabilitation and ADA modification of three (3) veteran owned units. For additional information on Rebuilding Together Fargo-Moorhead Area, visit their website at
  • Rebuilding Together Saratoga County, Ballston Spa, NY, will utilize $30,000 to support the rehabilitation and modification of four (4) veteran owned units. For additional information on Rebuilding Together Saratoga County, visit their website at
  • Red Feather Development Group, Flagstaff, AZ, will utilize $30,000 to assist six (6) Native American veteran homeowners with critical roof replacements and ADA modifications. For additional information on Red Feather Development Group, visit their website at
  • Southern Appalachian Labor School, Kincaid, WV, will utilize $30,000 to construct ADA accessible ramps and address critical adaptation or safety issues for twelve (12) veterans. For additional information on Southern Appalachian Labor School, visit their Facebook page at
  • Tangi Community Development, Amite, LA, will utilize $30,000 to support rehabilitation and ADA modifications on four (4) disabled veteran homes. For additional information on Tangi Community Development, visit their website at

The Persistence of Poverty in Rural America

Persistently poor counties are classified as having poverty rates of 20 percent or more for three consecutive decades. Using this metric, the Housing Assistance Council estimates there were 377 persistently poor counties in 2020 using data from the Census Bureau’s recently released 2016-2020 American Community Survey, the 2006-2010 American Community Survey and the 2000 Decennial Census of Population and Housing.

Download Research Brief (PDF)

House on Native American Land, ND

Self-Determination in Tribal Housing: Reflections on NAHASDA’s Impact

Twenty-five years ago, the Native American Housing Assistance and Self-Determination Act (NAHASDA) overhauled federal housing policy for tribal lands. One of its primary goals was to respect the sovereignty of tribes by giving them more power to determine how their federal housing funding is spent. Reauthorizing NAHASDA and making targeted improvements to build upon its first twenty-five years of achievements is one of HAC’s 2022 Rural Housing Policy Priorities.

We asked four experts on housing in Indian Country to reflect on NAHASDA and its impact.


Tony Walters

Tony Walters

Tony Walters, Executive Director, National American Indian Housing Council

Washington, DC

Tony Walters explains that NAHASDA “definitely has been a success.” By expanding the capacity of tribal housing authorities to meet the needs of their communities, the act has improved the quality and quantity of tribal housing.

Under NAHASDA, tribal housing authorities receive dedicated, reliable funding. As Walters points out, this steady stream of funds has “put tribes into a position where they can build homes quickly.” It has also increased their capacity, making other federal housing programs (like the Low-Income Housing Tax Credit) more accessible. While tribes undoubtedly need increased resources to offset thirty years of flat funding, NAHASDA has put many tribal housing authorities closer to their goal of being “one stop shops” for all the housing needs of Tribe members. Simply put, there’d be fewer homes without NAHASDA, Walters explains.

Additionally, self-determination has given tribes more ability to tailor housing development to their specific needs. Unlike the former system of federally built homes, the current system allows tribes the flexibility to include important “cultural elements” like community centers and to decide the specific number and location of new homes.

“Housing is the foundation of any community,” Walters notes. While NAHASDA has helped strengthen the foundations of many communities, Walters cautions that increased funding, capacity, and cooperation between government programs are needed to prevent tribal housing projects from “falling through the cracks.” The solution, as Walters sees it, is to expand on the work of NAHASDA by strengthening capacity building and increasing resources.


Twila Martin-KeKahbah

Twila Martin-KeKahbah

Twila Martin-Kekahbah, Turtle Mountain Band of Chippewa Indians and HAC board member

Belcourt, ND

Twila Martin-Kekahbah opposed NAHASDA when it was proposed, and still believes that the law has failed to live up to its intentions. While the homes built under the law are successes, they’re nowhere near what is needed.

As she explains, the law recognizes the importance of tribal sovereignty, but it doesn’t provide the level of financial support or assistance necessary to help tribes build their capacity. In other words, NAHASDA’s model of self-determination doesn’t work if tribes don’t have the funding or capacity to act on it. Martin-Kekahbah noted that under NAHASDA, federal experts withdrew from areas where they’d been running housing programs, leaving tribal housing authorities unprepared for the responsibilities before them.

While the intentions of the act were noble, she is left asking a challenging question: “Why would housing be so bad right now if NAHASDA was so great?”


Rebecca Patnaude-Olander

Rebecca Patnaude-Olander

Rebecca Patnaude-Olander, Executive Director, Turtle Mountain Housing Authority

Belcourt, ND

Rebecca Patnaude-Olander explained that NAHASDA’s self-determination only allows her housing authority to “be self-determining within guidelines” established by the statute. The Turtle Mountain Housing Authority spends 90% of its budget on operations and upkeep of existing units, with very little left over for new development. While the choice of how to spend federal funds is useful, with so little funding, it’s a “moot point.”

Patnaude-Olander also noted concerns over the structure of funding under NAHASDA. Funding is tied to the homes in a housing authority’s portfolio, which in the case of the Turtle Mountain Housing Authority is “basically the housing stock built under the Housing Act of 1937.” When homes leave the portfolio for any reason—including when they are paid off by tribal families under previous home ownership programs or when it’s no longer feasible to continue to rehab an older unit—funding is affected and may decrease. This makes it even harder to maintain existing units, let alone develop new ones. Additionally, she noted that the law creates a “Catch 22”: many units are vacant because they are too expensive to repair, but vacant units may be subject to losing their federal funding, leaving even fewer resources to address tribal housing needs.

Still, Patnaude-Olander doesn’t have an entirely negative view of NAHASDA. As she explains, without NAHASDA, her community wouldn’t have the ability to maintain its current housing. Plus, the law’s built-in consultation mechanisms give tribes “a seat at the table” for new federal regulations. Still, the model is far from true self-determination. After all, NAHASDA’s housing programs, like all programs, “need the necessary funding allocated to effectively run them.”


Dave Castillo

Dave Castillo

Dave Castillo, CEO, Native Community Capital and HAC board member

Tempe, AZ

Dave Castillo began his career the year after NAHASDA was signed into law. As he explains it, his colleagues held the expectation that this law would open a new era in tribal housing. “NAHASDA created opportunity,” he explains, but it required tribes to seize it.

The opportunity created by NAHASDA hasn’t yet been fully actualized, in Castillo’s view. With a “severe lack of precedent” developing new properties, instead of just maintaining them, and without the necessary capacity building, many tribal housing authorities were unable to take full advantage of the opportunities before them.

Additionally, NAHASDA hasn’t completely succeeded at bringing more funding to tribal housing. Under the law’s “regressive” funding formula, housing authorities lose funding when homes leave their portfolio. Also, since there is an expectation that tribes will leverage their NAHASDA allocation with other grants or private investment—which has been difficult if not impossible to attract—many innovative tribal housing initiatives have stalled. To make matters worse, the legislation’s goal of stimulating mortgage lending on tribal trust lands has been undercut by a loophole which gives banks credit for loans made to tribal members living off-reservation.

While Castillo has seen little “recognition of [NAHASDA’s] shortcomings,” (reauthorization of the law has failed every year since 2013) the law still contains valuable opportunities. For example, it requires federal agencies to negotiate new housing rules with tribes, a process known as “negotiated rulemaking.” In the end, Castillo takes a nuanced view on NAHASDA’s legacy. It provides an incredible opportunity, yet “we are failing” to meet Indian Country’s housing needs, even with NAHASDA.

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