Testimony, Comments, Correspondence
NCSHA Comment Letter on HUD Small Mortgage Lending RFI
On December 5, 2022, NCSHA submitted these comments to HUD in response to its Request for Information Regarding Small Mortgage Lending.ย NCSHA agreed with HUD's conclusion that a primary barrier to small balance mortgage loan lending is the cost to originate and service small mortgage loans in relation to the limited potential compensation afforded by them. NCSHA proposed three recommendations for HUD to consider during any rule-making process surrounding small mortgage lending.
NCSHA Comment Letter on EPA Greenhouse Gas Reduction Fund RFI
On December 5, 2022, NCSHA submitted this letter to the Environment Protection Agency (EPA) in response to its Request For Information on the Greenhouse Gas Reduction Fund (GHGRF). NCSHA urged the EPA to prioritize the use of GHGRF for affordable housing, where such assistance could significantly reduce greenhouse gas emissions and significantly improve the lives of the residents of affordable housing properties and the communities in which they are located.
HOME Coalition Letter to Appropriators for FY23
On November 28, 2022, the HOME Coalition sent this letter to appropriators in both congressional chambers urging them to provide robust funding for the HOME Investment Partnerships program for the remainder of fiscal year 2023. The letter requested no less than $1.9 billion for the program, which is the amount included in the Presidentโs FY23 Budget Request.
ACTION Letter on Housing Credit Priorities in the Lame Duck Session
This November 21, 2022, letter, organized by the ACTION Campaign and signed by more than 2,500 businesses, nonprofits, and organizations from across the nation, urged Congress to pass legislation during the 2022 lame duck session that would expand production of affordable housing by increasing Housing Credit authority by 50 percent and enhancing the use of Private Activity Bond authority for rental housing production by lowering the bond financing threshold from 50 to 25 percent. NCSHA and Enterprise Community Partners co-chair the ACTION Campaign.ย
NCSHA’s 2022 Election Analysis
NCSHA offers these analyses of the 2022 election results.
NCSHA Comment Letter on FHFA Review of Federal Home Loan Banks
On October 31, 2022, NCSHA submitted comments to the Federal Housing Finance Agency (FHFA) as part of FHFAโs recently announced comprehensive review of the Federal Home Loan Banks (FHLBs). Reflecting feedback from HFAs, including those who work closely with their FHLB, NCSHA asked FHFA to maintain the FHLB systemโs regional structure, which helps to ensure that the FHLBs better address the nationโs diverse housing needs. NCSHA also urged FHFA to consider ways the FHLBs can better pair their affordable housing activities with important federal, state, and local government programs, particularly those administered by HFAs, and to recommend to Congress that each FHLB's contribution level for their Affordable Housing Programs be increased from 10 to 15 percent.
NCSHA Comments on HUD Green Retrofit RFI
On October 27, 2022, NCSHA submitted comments to the Department of Housing and Urban Development in response to a Request for Information about HUD's new Green and Resilient Retrofit Program (GRRP). In its letter, NCSHA urged HUD to provide as much flexibility as possible in how eligible applicants and recipients may use and structure GRRP funds.
NCSHA, HPC Letter on HAF and FHA Loss Mitigation
On October 20, NCSHA and the Housing Policy Council (HPC) sent a letter to FHA Commissioner Gordon, urging for an extension on eligibility for COVID-19 Recovery Home Retention Options to homeowners who have received assistance through the Homeowner Assistance Fund (HAF).
NCSHA Letter to Treasury on Tax Status of GSEs
This October 18, 2022, letter from NCSHA urges the U.S. Treasury Department to clarify in writing that the Government Sponsored Enterprises, Fannie Mae and Freddie Mac, are not Tax Exempt Controlled Entities under Section 168(h)(6)(F)(i) of the Internal Revenue Code.
