The Language Access Task Force of Americans for Financial Reform (AFR) submits the following comments in strong support of the Federal Housing Finance Agency (FHFA)’s Notice of Proposed Rulemaking on Fair Lending Oversight and Equitable Housing Finance.
AFR submitted this letter in opposition to H.R. 3564, which would make mortgages more expensive for many middle-class American families. H.R. 3564 would rescind the FHFA’s more equitable mortgage pricing framework and instead require the FHFA to increase fees for many first-time home buyers and those who do not have a 20% down payment.
AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.
Letter to Regulators: Silicon Valley Bank Failure Demonstrates the Need to Implement Key Executive Pay Rule, Dodd-Frank Section 956
AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011. Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.
Letters to Regulators: Letter Telling Fannie and Freddie to Finance Affordable Housing, Not Displacement
AFREF and 34 allies sent a letter regarding the Safety and Soundness Act, which requires FHFA to establish annual housing goals for mortgages purchased by Fannie Mae and Freddie Mac (the Enterprises). This letter supports the proposal’s move towards a methodology that focuses on the percentage, not number, of affordable housing units financed by the Government Sponsored Enterprises (GSEs). However, the proposal fails to hold the GSEs to adequate lending standards and refine what counts as affordable housing units.
This letter seeks policy reforms that will prevent GSEs from financing loans that contribute to displacement and substandard living conditions for low income tenants and tenants of color. It also objects to FHFA goals being set at levels that are below recent performance by the Enterprises.
AFREF sent a letter to FHFA on their Duty to Serve plans.
Letters to Regulators: Letters to Agencies on Pausing Foreclosures When There is a HAF Application in Progress
AFREF joined two letters, one to the CFPB and one to HUD, FHFA, VA and USDA, both calling on the agencies to halt foreclosure for 60 days when a homeowner has submitted an application for HAF funds and the servicer has been notified by the HAF administrator.
AFR joined a letter to Congress in support of Sandra Thompson’s nomination to be director of FHFA.
AFREF joined a letter to FHFA calling on the agency to rededicate itself to improving language access in mortgage origination and servicing.
Letters to Regulators: Letter to FHFA in Response to Request for Comment on Policy Statement on Fair Lending
AFREF joined several other civil rights, consumer advocacy and housing organizations in sending a letter a comment letter to the Federal Housing Finance Agency (“FHFA”) in response to their request for comment on their Policy Statement on Fair Lending (“Policy Statement”). The letter emphasizes that FHFA’s fair lending oversight of Fannie Mae and Freddie Mac must ensure access to mortgage credit on fair terms for all creditworthy borrowers, regardless of their race, gender, national origin, disability, familial status, or other protected characteristics, which is essential to closing the homeownership and wealth gaps created by exclusionary federal housing policies and ongoing discrimination in the housing marketplace.