NCSHA Comments on Fannie Mae Proposed Changes to 2023 Duty-to-Serve Housing Credit Investments
On July 21, 2023, NCSHA submitted the attached comments to the Federal Housing Finance Agency (FHFA) on Fannie Mae’s proposed changes to its Duty-to-Serve Underserved Markets Plan for 2022–24. The letter expresses NCSHA’s opposition to Fannie Mae’s sole proposed change, which would reduce its 2023 baseline for Housing Credit investments for properties in rural areas from 70 to 20 to 40. NCSHA urged FHFA to request the Treasury Department issue written guidance clarifying that Fannie Mae and Freddie Mac are not Tax-Exempt Controlled Entities under the Federal Tax Code. Such a clarification would allow Fannie Mae to continue participating in multi-investor Housing Credit funds and continue making substantial Housing Credit investments that support rural housing.
