Testimony, Comments, Correspondence
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 Agency’s 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) programs’ purchase price safe harbors from the Federal Housing Administration’s 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 – 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 Mae’s and Freddie Mac’s Equitable Housing Finance Plans for 2025 – 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 firms’ 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 2024–2025 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 2024–2025 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 2024–2025 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.
Congressional Letter to Treasury on VAWA Housing Credit Guidance
On May 23, 2024, members of the House of Representatives, led by Representatives Gwen Moore (D-WI) and Claudia Tenney (R-NY), sent a letter to Treasury Secretary Janet Yellen and IRS Commissioner Daniel Werfel urging the U.S. Department of the Treasury and the Internal Revenue Service to promulgate guidance on the application of protections under the Violence Against Women Act for Low Income Housing Tax Credit allocators and other Housing Credit program participants, such as owners, property managers, investors, and syndicators.
NCSHA Comments on Freddie Mac Single-Family Closed-End Second Mortgages
NCSHA submitted comments to the Federal Housing Finance Agency in response to a request for comment on the proposed Enterprise product entitled "Freddie Mac Single-Family Closed-End Second Mortgages."
Underserved Mortgage Markets Coalition Press Release on FHFA Fair Lending Final Rule
On May 1, 2024, NCSHA signed onto a press release by the Underserved Mortgage Markets Coalition (UMMC) regarding the Federal Housing Finance Agency’s April 29 Final Rule on Fair Lending, Fair Housing, and Equitable Housing Finance Plans. The press release applauds FHFA for publishing the rule, which codifies into federal regulations the requirement that Fannie Mae and Freddie Mac publish and maintain Equitable Housing Finance Plans. The plans outline how each firm will support equitable and sustainable housing opportunities. UMMC also urges FHFA to adapt several policies to increase transparency and accountability regarding Fannie Mae and Freddie Mac’s equitable housing activities.
