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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 Agencyโ€™s (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 Agencyโ€™s (FHFA) June 11 Request for Input (RFI) on the government-sponsored enterprises (GSEs) Fannie Maeโ€™s and Freddie Macโ€™s 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 Agricultureโ€™s (USDA) Section 514 and 515 programs, promoting rural homeownership, and affordable home improvement financing.

Preserving Rural Investments Act

This legislation would amend the tax code to clarify that Government Sponsored Enterprises (GSEs) Fannie Mae and Freddie Mac are not tax-exempt controlled entities (TECEs) and, thus, are eligible for tax benefits that are not available to TECEs. This would allow Fannie Mae and Freddie Mac to invest in multi-investor Housing Credit funds without jeopardizing those benefits for other investors in the funds.ย 

Press Release: Sen. Moran, Sen. Warner, Sen. Young, Rep. LaHood & Rep. Kildee Introduce Legislation to Increase Rural Housing Investment

U.S. Senators Jerry Moran (R-Kan.) Mark Warner (D-Va.)and Todd Young (R.-Ind) and U.S. Representatives Darin LaHood (IL-16) and Dan Kildee (MI-08) introduced legislation on August 1, 2024, to amend the Internal Revenue Code to clarify that Government Sponsored Enterprises (GSEs) Fannie Mae and Freddie Mac are able to participate in partnerships that are crucial for low-income housing investments.

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 Agencyโ€™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) programsโ€™ purchase price safe harbors from the Federal Housing Administrationโ€™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 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 Maeโ€™s and Freddie Macโ€™s 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.