Testimony, Comments, Correspondence
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.
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.Ā
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.
ACTION Campaign Comments on IRS/Treasury 2023ā24 Priority Guidance Plan
This June 9, 2023, letter provides the ACTION Campaignās 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 2023ā24 Priority Guidance Plan
This June 9, 2023, letter provides NCSHAās 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.Ā
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 Macās 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.
NCSHA Comment Letter on FHFA’s Proposed Amendments to GSE Capital Standards
On May 12, 2023, NCSHA sent this letter to the Federal Housing Finance Agency (FHFA) in response to its proposed rule modifying several provisions of the Enterprise Regulatory Capital Framework (ERCF) for Fannie Mae and Freddie Mac. NCSHA expressed strong support for a provision of the proposed rule that would reduce by 40 percent the risk multiplier for multifamily mortgages backed by properties receiving government subsidies, including the Housing Credit. NCSHA urged FHFA to consider reducing the risk multiplier further and also to apply it to properties receiving funding through the HOME Investment Partnership program and from tax-exempt multifamily housing bonds. Additionally, the letter expressed support for FHFAās proposals to reduce the risk weighting for commingled mortgage-backed securities that contain loans guaranteed by both Fannie Mae and Freddie Mac and to change how the firms determine a home buyerās representative credit score for the purposes of the ERCF.
NCSHA Comment Letter on the Greenhouse Gas Reduction Fund Implementation Framework
NCSHA submitted these comments to the U.S. Environmental Protection Agency on its Greenhouse Gas Reduction Fund Implementation Framework.
