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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’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.

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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.

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.

White Mountain Apache Housing Authority Serves its Veterans

The White Mountain Apache Housing Authority (WMAHA) helps the members of the White Mountain Apache Tribe to overcome their individual housing needs. Of these, almost 500 are U.S. military veterans. Working in the Fort Apache Indian Reservation located in eastern central Arizona, WMAHA serves the 16,000 enrolled members of the White Mountain Apache Tribe and strives to ensure that every tribal member has safe housing they can afford. The Housing Assistance Council (HAC) is proud to be a partner of WMAHA and their amazing work. In 2018, we awarded a $30,000 grant through The Home Depot Foundation‘s Veteran Housing Grants Program to WMAHA to help support their veterans. In celebration of Veterans Day and Native American Heritage Month, we’d like to highlight just a few of the many ways the White Mountain Apache Housing Authority serves the veterans of the White Mountain Apache Tribe.

Before rehab of a veteran’s home completed by WMAHA in 2018 

Before rehab of a veteran’s home completed by WMAHA in 2018

After rehab of a veteran’s home completed by WMAHA in 2018 

After rehab of a veteran’s home completed by WMAHA in 2018

Before and after of a rehab of a veteran’s home completed by WMAHA in 2018 


As many veterans know, service doesn’t end when you’re discharged. It’s a value that is carried for a lifetime. For WMAHA, service is key to the mission. The Veteran Home Rehabilitation Program serves those who have served our country. Many of the low-income Apache veterans the Housing Authority assists are in desperate need of multiple, expensive repairs to make sure their homes are safe, accessible, and livable. But without the ability to make these repairs themselves, many veterans need help.

Over the last eight years, the White Mountain Apache Housing Authority has rehabilitated (or in one case built!) 19 homes for their veterans, each of which required multiple major repairs for health, safety, and accessibility. All of this was performed at no cost to the veteran or their family. Last year WMAHA was able to set a record with 5 rehabilitations.

Making sure their veterans have safe and healthy homes is a point of pride for WMAHA and for the entire White Mountain Apache community. After all, WMAHA doesn’t work alone: each rehabilitation is made possible by scores of volunteers. As the team from WMAHA explains, “the number of volunteers who come and help with demolition and construction cleanup during the projects” is a testament to the rehabilitation program’s “impact on the community.” From the Housing Authority to everyday members, including community partners, the White Mountain Apache Tribe takes care of its veterans. By taking care of those who took care of us, WMAHA is serving both its community and the broader community of veterans nationwide.

The COVID pandemic has hit many Native communities particularly hard, and tragically, the White Mountain Apache are no exception. During the pandemic, unemployment, which usually runs 80% according to WMAHA, has far surpassed that amount, and food insecurity is “at a critical level.” Many of the low-income veterans WMAHA assists don’t have a way to pick up food from the local food bank, so the Housing Authority is starting to deliver the food boxes itself. Not content to just help house their veterans, WMAHA is committed to improving their quality of life.

Caring for veterans extends outside the home, too. For WMAHA, ensuring their veterans have access to the Veterans Affairs benefits they deserve is a critical mission. With 1.67 million acres, the Fort Apache Indian Reservation is large and rural. This creates challenges for many of the Tribe’s low-income veterans. Many of the nearest VA hospitals are hundreds of miles away, which makes even getting to routine appointments incredibly difficult. This distance makes it so challenging to receive disability ratings, see specialists, and make necessary appointments that, according to Barb Connerley, a consultant who works with WMAHA, “many of the veterans…do not know what VA benefits are available to them.”

This veteran’s home was in such disrepair the team from WMAHA decided to tear it down and start from scratch.

This veteran’s home was in such disrepair the team from WMAHA decided to tear it down and start from scratch.

This veteran’s home was in such disrepair the team from WMAHA decided to tear it down and start from scratch.

This veteran’s home was in such disrepair the team from WMAHA decided to tear it down and start from scratch.

This veteran’s home was in such disrepair the team from WMAHA decided to tear it down and start from scratch.

The White Mountain Apache Housing Authority has created a solution to help connect their veterans to the VA medical care they earned through their service. Since 2017, the White Mountain Apache Tribe Department of Transportation has operated Fort Apache Connection Transit (FACT), a 2-route bus system serving 12 stops across the Reservation. While this system doesn’t provide access to the nearest VA hospitals, the Housing Authority recently began repurposing one of their buses to transport veterans to their VA appointments. Multiple times a month, WMAHA will be providing veterans with a bus ride to their appointments and back home. They even take the time to help the veterans complete their paperwork to file for VA benefits.

For the trip, WMAHA provides their veterans with water, snacks, masks, and COVID safety information. They hope that this program can also serve as a teaching event, helping their veterans learn more about COVID safety as well as how to access their VA benefits. The program’s strength is its ingenuity—bringing together transit, healthcare, and informational services—in solving a critical problem for the Tribe’s veterans. Thanks to the White Mountain Apache Housing Authority, veterans living on reservation now have access to the critical VA healthcare they’ve earned through their service.

Many veterans return from their service to find it difficult to access the resources of their communities, including housing. Tragically, Native communities are overrepresented among persistent poverty counties, making these resources even harder to access. The Housing Assistance Council is committed to helping build community resources for housing where they’re needed most. Partners like WMAHA help us give back to our veterans and uplift Native communities. As Barb Connerley puts it, the Tribe’s veterans “have a proud tradition of military service and sacrifice.” The work of the White Mountain Apache Housing Authority pays respect to that service and sacrifice through service, care, and ingenuity of its own.

Rural Voices: Meeting Native American Housing Needs

This issue of Rural Voices focuses on the progress being made in improving the housing conditions of Native Americans. Considerable challenges, including substandard conditions, overcrowding, insufficient funding, and persistent poverty, face Indian Country, but tribes and their housing organizations are equally persistent in working to overcome them. Rural Voices authors share what readers need to know when working with tribes, highlight innovative projects, discuss funding opportunities, and further describe challenges for a diverse population of Native American tribes across the country. The Wells Fargo Housing Foundation has provided generous support for this issue of Rural Voices, and for HAC’s other work on Native American housing needs and solutions.


Building a Stronger Indian Country: The BUILD Act and Indian Housing
by Senator John Hoeven

The BUILD Act aims to improve the development of tribal housing projects and reauthorize critical Indian housing programs.


Creating Sustainable Homelands through Homeownership on Trust Lands
by Patrice H. Kunesh

A multifaceted approach can help leverage resources to improve housing and economic development in Indian Country.

Partnering with Tribes to Address Housing Needs
by Deana Around Him and Yvette Roubideaux

Open communication, cultural humility, and respect go a long way when working together with tribes.

Important Considerations for Working with Tribes
by Twila Martin Kekahbah

Understanding tribal governance,sovereignty, and the barriers to tribal development is critical to doing business with American Indian tribes.

Housing Solutions that Work for Native Americans
by Anthony Walters

The Native American Housing Assistance and Self-Determination Act is an important tool in meeting tribal housing needs.

Helping Native Americans Become Homeowners through Section 184
by Jeff Bowman and Tanya Krueger

This Native-owned bank has what it takes to successfully use HUD’s Section 184 program to meet tribal members’ housing needs.

Native Community Finance Serves Native Americans in New Mexico
by Marvin Ginn

Native CDFIs provide funds and services to improve Native American housing conditions.

Housing for Holistic Rez Living
by James “JC” Crawford

Sisseton Wahpeton Oyate has had major success in integrating housing and community needs.


American and Alaska Native (AIAN) Communities at a Glance InfographicAmerican and Alaska Native (AIAN) Communities at a Glance

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.

HUD Releases Native American Housing Studies

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.