Testimony, Comments, Correspondence

Qualified Contract Letter Sent to USDA

This October 25, 2023, letter, sent by NCSHA and other Housing Credit advocacy organizations to Secretary Vilsack, urges the Department of Agriculture to take actions to mitigate qualified contract early terminations of Housing Credit units that benefit from Section 538 multifamily housing loan guarantees.

NCSHA Letter to HUD on Early Termination of Qualified Contracts

This September 25, 2023, letter, sent by NCSHA and other Housing Credit advocacy organizations to Secretary Marcia L. Fudge, urges the U.S. Department of Housing and Urban Development (HUD) to take actions to mitigate qualified contract early terminations of Housing Credit units that benefit from HUD financing and Federal Housing Administration insurance.

184 Local Leaders Sign Onto Letter Supporting the Affordable Housing Credit Improvement Act

184 local government officials, representing cities, counties, and other municipalities of all sizes across the country, sent a letter to Congressional leadership supporting the Affordable Housing Credit Improvement Act (AHCIA) of 2023.

NCSHA Letter to HUD on Modernization of Engagement with Mortgagors in Default

On September 5, 2023, NCSHA responded to the U.S. Department of Housing and Urban Development’s proposed rule on Modernization of Engagement with Mortgagors in Default. NCSHA commended HUD's efforts to expand communication methods between mortgagees and defaulted homeowners, suggesting this expansion will improve loss mitigation efforts and home retention. Additionally, NCSHA encouraged HUD to define ‘reasonable effort’ and ‘verifiable attempt’ as broadly as possible. Upon implementation of the final rule, form HUD-2008-5-FHA Save Your Home: Tips to Avoid Foreclosure will be updated to include the expanded modes of communication.

Local Government Leaders’ Letter Supporting the Affordable Housing Credit Improvement Act

The ACTION Campaign, which NCSHA co-leads, is partnering with the National League of Cities, the National Association of Counties, and Mayors & CEOs for U.S. Housing Investment to circulate this letter in support of the Affordable Housing Credit Improvement Act of 2023 (AHCIA, S. 1557 | H.R. 3238).

NCSHA Letter to FHFA on Fannie, Freddie Single-Family Loan Pricing Framework

On August 14, 2023, NCSHA responded to the Federal Housing Finance Agency’s May 15 request for input on Fannie Mae and Freddie Mac’s framework for pricing single-family mortgages. The letter urged FHFA, when adjusting the pricing framework, to balance the need for the government-sponsored enterprises (GSEs) to maintain adequate capital with their public missions to support a liquid housing finance market, including for underserved markets. The letter also asked FHFA to continue to exempt loans originated through the GSEs’ HFA-specific products, as well as other loans for low- and moderate-income home buyers, from upfront mortgage fees.

NCSHA Comment Letter on FHFA’s Request for Input on Tenant Protections for Enterprise-Backed Multifamily Properties

In response to a request for input from the Federal Housing Finance Agency on tenant protections for enterprise-backed multifamily properties, NCSHA submitted these July 31, 2023, comments encouraging FHFA to protect tenants against displacement, rent increases, and possible evictions and to consider the potential impact of such protections on tenants, housing providers, lenders, and the government sponsored enterprises.

NCSHA Letter to FHFA on Tenant Protections for Enterprise-Backed Multifamily Properties

On July 31, 2023, NCSHA responded to the Federal Housing Finance Agency's request for input on tenant protections for multifamily properties with mortgages backed by Fannie Mae and Freddie Mac. The letter highlighted the work state housing finance agencies are doing to address the issues tenants face with respect to the FHFA’s investigation to establish whether further tenant protections are needed. The letter urged FHFA to center preservation as a focus on protection efforts, while also considering data and analysis as the means of rolling out any new measures.

NCSHA Letter to CFPB on R-PACE Proposed Rule

On July 26, 2023, NCSHA sent a letter to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra regarding the proposed rule on Residential Property Assessed Clean Energy Financing (R-PACE). The letter urges the CFPB to add a requirement to the rule directing R-PACE financiers to report R-PACE financings to credit bureaus and to a homeowner’s mortgage loan servicer. The letter also requests the CPFB require more explicit homeowner disclosures and expand its study of the R-PACE financing industry.