Testimony, Comments, Correspondence
NCSHA Comments on Federal Banking Regulators’ Review of CRA Regulations
On October 22, 2025, NCSHA sent the attached comments to the federal banking regulators — the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — in response to their review of Community Reinvestment Act (CRA) regulations conducted under the Economic Growth and Regulatory Paperwork Reduction Act. In the letter, NCSHA stresses that regulatory certainty is critical to ensure CRA meets its vital mission. To this end, NCSHA urges the agencies to quickly finalize their July 2025 proposed rule to rescind their 2023 rule to overhaul the CRA regulations, which is facing legal challenges, and return to the previous CRA framework.
NCSHA Letter to FHFA on Repeal of GSE Fair Lending, Fair Housing, and Equitable Housing Finance Plan Rule
On September 26, 2025, NCSHA sent the attached comments to the Federal Housing Finance Agency (FHFA) on FHFA’s proposed rule to repeal its May 2024 rule codifying the Fair Lending, Fair Housing, and Equitable Housing Finance Plan requirements for Fannie Mae and Freddie Mac and the Federal Home Loan Banks. In the letter, NCSHA encouraged FHFA to instruct Fannie Mae and Freddie Mac to continue certain efforts and pilots that have been effective and to make additional efforts to reach underserved markets and communities. NCSHA noted state HFAs would be good partners for FHFA, Fannie Mae, and Freddie Mac in these endeavors.
NCSHA Letter to HUD on Impact of Buy Now Pay Later Loans on Mortgage Lending
On August 21, 2025, NCSHA submitted comments to the U.S. Department of Housing and Urban Development (HUD) on its request for information regarding the impact of Buy Now Pay Later (BNPL) debt on mortgage lending.
NCSHA Letter to Federal Banking Regulators on Proposed CRA Revisions
On August 18, 2025, NCSHA sent the attached letter to federal banking regulators — the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — commenting on their July 18 proposed rule to repeal their October 2023 final rule revamping the Community Reinvestment Act (CRA) regulations and restore the previous CRA regulatory framework finalized in 1995. In the letter, NCSHA expressed support for the proposed rule because it will provide banks with the certainty they need to continue fulfilling their CRA obligations and incentivize bank investments in Housing Credit and Housing Bonds.
HOME Coalition Letter to Senate to Preserve Program Funding in FY26
The HOME Coalition, led by NCSHA sent this letter to the Senate Appropriations Committee, urging them to fund the HOME Investment Partnerships Program at no less than $1.5 billion in Fiscal Year 2026, warning that the House’s proposed elimination of the program would severely undermine local efforts to address the nation’s affordable housing crisis.
ACTION Letter to Senate Appropriations Committee to Protect HOME Funding in FY26
The ACTION Campaign sent this letter to the Senate Appropriations Committee on July 17, 2025, urging them to protect funding for the HOME Investment Partnerships Program in fiscal year 2026. This letter comes in response to the House Appropriations Committee’s FY26 Transportation, Housing and Urban Development, and Related Agencies bill, which eliminates all funding for HOME, a critical gap-filling resource in developments that utilize the Housing Credit.
NCSHA Comments on IRS 2025-2026 Priority Guidance Plan
NCSHA submitted a letter to the Internal Revenue Service outlining its recommendations for the 2025–2026 Priority Guidance Plan.
NCSHA Comment Letter to OMB on Deregulation
This May 12, 2025, letter provides NCSHA’s comments to the Office of Management and Budget in response to its Notice of Request for Information on deregulation. NCSHA’s comments outline proposals for regulatory streamlining of housing programs at HUD, Treasury, and USDA’s Rural Housing Service.
ACTION Campaign Sign-On Letter to Congress Advocating for AHCIA
The ACTION Campaign sent this May 9, 2025, letter signed by more than 2,600 organizations to the House and Senate leadership urging Congress to strengthen and expand the Low-Income Housing Tax Credit by passing the Affordable Housing Credit Improvement Act.
