Testimony, Comments, Correspondence
Qualified Contract Letter to HUD
This September 25, 2023, letter, sent by NCSHA and other Housing Credit advocacy organizations to Secretary Marcia L. Fudge, urges the Department of Housing and Urban Development to take actions to mitigate qualified contract early terminations of Housing Credit units that benefit from HUD financing and FHA 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 Developmentās proposed rule on Modernization of Engagement with Mortgagors in Default.Ā 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 āreasonable effortā and āverifiable attemptā as broadly as possible. Upon implementation of the final rule, form HUD-2008-5-FHA Save Your Home: Tips to Avoid ForeclosureĀ 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 Agencyās May 15 request for input on Fannie Mae and Freddie Macās 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 GSEsā HFA-specific products, as well as other loans for low- and moderate-income home buyers, from upfront mortgage fees.
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 FHFAās 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 directingĀ R-PACE financiers to report R-PACE financings to credit bureaus and to a homeownerās mortgage loan servicer. The letter also requests the CPFB require more explicit homeowner disclosures and expand its study of the R-PACE financing industry.Ā
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 Maeās proposed changes to its Duty-to-Serve Underserved Markets Plan for 2022ā24. The letter expresses NCSHAās opposition to Fannie Maeās 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 ā Fannie Mae, Freddie Mac, and the Federal Home Loan Banks (FHLBs) ā from providing financing to Housing Credit properties for which the owner has not and will not waive its qualified contract rights.
