Testimony, Comments, Correspondence
NCSHA Comments to FHFA on Application Process for Federal Home Loan Banksโ Affordable Housing Programs
On August 19, 2024, NCSHA submitted the attached letter in response to the Federal Housing Finance Agencyโs (FHFA) Request for Input on potential changes to the application process for the Federal Home Loan Banksโ (FHLBs) Affordable Housing Programs (AHP). The letter recommends that each FHLB consult with HFAs and other bank members when setting the timeline and other policies for its AHP application process so as to maximize the potential for AHP fund to be used in conjunction with financing from the Housing Credit and other federal and state housing programs.
NCSHA Comments to FHFA on GSE Duty to Serve Plans for 2025-2027
On August 12, 2024, NCSHA submitted the attached letter responding to the Federal Housing Finance Agencyโs (FHFA) June 11 Request for Input (RFI) on the government-sponsored enterprises (GSEs) Fannie Maeโs and Freddie Macโs Underserved Markets Plans for years 2025-2027. The letter encourages FHFA and the GSEs to continue to explore potential partnerships with HFAs to meet their Duty to Serve obligations. The letter advances several specific suggestions for potential GSE-HFA collaborations, including expanded activity in the Credit market, funding and equity for preserving affordable housing properties financed through the U.S. Department of Agricultureโs (USDA) Section 514 and 515 programs, promoting rural homeownership, and affordable home improvement financing.
HOME Coalition Comments on HUD HOME Investment Partnerships Program: Program Updates and Streamlining Proposed Rule
The HOME Coalition, led by NCSHA, sent a letter to the US Department of Housing and Urban Development on the proposed rule, HOME Investment Partnerships Program: Program Updates and Streamlining.
NCSHA Comments on HOME Investment Partnerships Program: Program Updates and Streamlining Proposed Rule
NCSHA submitted comments to the US Department of Housing and Urban Development on the proposed rule, HOME Investment Partnerships Program: Program Updates and Streamlining.
NCSHA Comments on FHFA RFI on Federal Home Loan Bank System Mission
On July 11, 2024, NCSHA submitted this letter responding to the Federal Housing Finance Agencyโs May 16 request for input on the mission of the Federal Home Loan Bank System. In its comments, NCSHA urged FHFA to establish an explicit affordable housing mission for the FHLB System and encourage more FHFA-HFA partnerships.
NCSHA Letter on IRS Revenue Procedure 2024-21
On June 14, 2024, NCSHA submitted comments to the Internal Revenue Service on Revenue Procedure 2024-21, which proposes to change the data set used to establish the Mortgage Revenue Bond (MRB) and Mortgage Credit Certificate (MCC) programsโ purchase price safe harbors from the Federal Housing Administrationโs loan limits to median home price data collected by the U.S. Department of Housing and Urban Development. NCSHA urged the IRS not to go forward with the proposed change.
NCSHA Letter to FHFA on GSE Equitable Housing Finance Plans for 2025 โ 2027
On June 7, 2024, NCSHA sent this letter to the Federal Housing Finance Agency (FHFA) in response to its request for information on Fannie Maeโs and Freddie Macโs Equitable Housing Finance Plans for 2025 โ 2027. In the letter, NCSHA thanks FHFA for its continued focus on establishing an equitable housing finance market and for recently acting to codify the Equitable Housing Finance plans into federal regulations. NCSHA also suggests two specific opportunities for Fannie Mae and Freddie Mac partnerships with HFAs that can help them to better serve minority communities: fully restoring the pricing advantage for the firmsโ HFA products and facilitating acquisition, development, and construction financing through HFAs.
NCSHA Recommendations to IRS on 2024-2025 Priority Guidance Plan
On May 31, 2024, NCSHA sent the Internal Revenue Service and U.S. Department of Treasury recommendations on the 2024โ2025 Priority Guidance Plan. These recommendations encompassed various enhancements and modifications to the Housing Credit and Housing Bond programs, all aimed at ensuring ongoing efficient state management of these initiatives.
ACTION Campaign Letter to IRS on 2024โ2025 Priority Guidance Plan
On May 31, 2024, the ACTION Campaign, which is co-led by NCSHA and Enterprise Community Partners, sent a letter to the Internal Revenue Service and U.S. Department of the Treasury regarding the 2024โ2025 Priority Guidance Plan. The letter made several recommendations to the plan including implementing Violence Against Women Act protections for Housing Credit tenants, providing more flexibility for properties suffering casualty loss, including relocation expenses in rehabilitation expenditures, and better restricting of planned foreclosures.
