Testimony, Comments, Correspondence
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 Maeโs proposed changes to its Duty-to-Serve Underserved Markets Plan for 2022โ24. The letter expresses NCSHAโs opposition to Fannie Maeโs 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.
NCSHA Joins Letter to FHFA Urging GSE Policies to Mitigate Qualified Contract Losses
On July 13, 2023, NCSHA joined 14 other Housing Credit stakeholder organizations on a letter to Federal Housing Finance Agency (FHFA) Director Sandra Thompson urging FHFA to adopt policies prohibiting the government sponsored entities โ Fannie Mae, Freddie Mac, and the Federal Home Loan Banks (FHLBs) โ from providing financing to Housing Credit properties for which the owner has not and will not waive its qualified contract rights.
NCSHA Comments on HUD Budget PBCA Proposal
NCSHA sent this letter to HUD regarding the proposed Budget Request for Fiscal Year 2024 (FY24) Budget Request (Section 237), related to the Performance-Based Contract Administrator (PBCA) program. NCSHA offered suggestions to strengthen the proposal, including establishing criteria that prioritize the selection of applicants with certain experience and the use of cooperative agreements.ย
NCSHA Comments on Payment Supplement Partial Claim Draft Mortgagee Letter
This June 30, 2023, letter provides comments to the Department of Housing and Urban Development on its draft mortgagee letter regarding the Payment Supplement Partial Claim.
NCSHA Letter to FHFA on Proposed Rule Codifying GSE Fair Housing, Equitable Housing Finance Plans Requirements
On June 26, 2023, NCSHA submitted the attached letter in support of a Federal Housing Finance Agency (FHFA)ย proposed ruleย that would codify into regulation many of FHFAโs existing policies and practices for supporting fair housing and an equitable housing finance market.ย The letter expresses NCSHAโs strong support for a provision in the proposed rule to codify FHFAโs directive requiring each of the GSEs to develop Equitable Housing Finance Plans that outline what efforts they intend to take over a three-year period to increase equity in housing finance and includes several provisions for improving transparency about plan implementation and evaluation.
ACTION Campaign Comments on IRS/Treasury 2023โ24 Priority Guidance Plan
This June 9, 2023, letter provides the ACTION Campaignโs comments to the Internal Revenue Service and the U.S. Department of the Treasury on their Priority Guidance Plan for the period beginning July 1, 2023, through June 30, 2024.
NCSHA Comments on IRS/Treasury 2023โ24 Priority Guidance Plan
This June 9, 2023, letter provides NCSHAโs comments to the Internal Revenue Service and the U.S. Department of the Treasury on their Priority Guidance Plan for the period beginning July 1, 2023, through June 30, 2024.
NCSHA Comment Letter on Title V of McKinney-Vento Homeless Assistance Act
On May 19, 2023, NCSHA submitted this letter to the U.S. Department of Housing and Urban Development on proposed regulations governing Title V of the McKinney-Vento Homeless Assistance Act.ย
NCSHA Comment Letter on FHFA’s RFI on Single-Family Social Bonds
On May 17, 2023, NCSHA sent this letter to the Federal Housing Finance Agency (FHFA) in response to its February 16 Request for Input on Fannie Mae and Freddie Macโs policies toward social bonds. In the letter, NCSHA argued that the Government Sponsored Enterprises (GSEs) issuing single-family mortgage securities classified as social bonds under the framework for Environmental, Social, and Governance (ESG) securities could help to increase liquidity in the single-family market and expand access to affordable homeownership loans for working families and other underserved communities. NCSHA urged FHFA to work with the GSEs to explore issuing single-family ESG bonds and suggested HFAs would be ideal partners with the GSEs as they develop and expand ESG programs.
