AFREF joined the National Fair Housing Alliance and local, state, and national organizations to submit comments in response to HUD’s “Request for Information Regarding Small Mortgage Lending.” Our comments focus on the importance of residential small-dollar lending (SDL), which is essential to building wealth and family opportunity for communities of color and low- and moderate-income families throughout the nation. For too long, homes in lower-priced markets have been starved of quality, sustainable, mortgage credit, both subject to and contributing to a history of residential segregation, neighborhood disinvestment, and lost wealth-building opportunity. This comment letter makes a number of suggestions to the FHA regarding how it can better promote small mortgage loans.
AFREF joined a letter calling on President Biden to extend the payment pause on student loans.
AFREF joined a letter calling on FHA to strengthen language access for borrowers with limited English proficiency.
Letters to Regulators: Letter in Response to the Department of Commerce’s RFI on the Implementation of the CHIPS Incentives Program
AFREF led thirteen partners in submitting a comment letter in response to a Department of Commerce request for information on the implementation of the CHIPS incentives program. The letter describes how stock buybacks and outsized executive compensation packages undermine innovation and inclusive economic growth, and details the semiconductor industry’s track record of massive spending on stock buybacks and CEO compensation. It then recommends bright-line rules to restrict stock buybacks and executive compensation, as well as pro-worker policies that would promote innovation and inclusive economic growth.
AFREF sent comments calling on the Federal Home Loan Banks to substantially increase funding for the Affordable Housing Program, and enact executive compensation reform if the banking system is going to continue to benefit from significant public subsidies.
AFREF joined experts in the field in submitting comments calling on the FHFA Office of Financial Technology to ensure that new applications of fintech to housing finance do not violate consumer protections or fair housing violations. Specific recommendations are made to avoid algorithmic bias and e-signature fraud, along with a general principle of caution when approving new fintech practices.
AFREF joined a letter calling on HUD to increase the affordability of FHA insurance mortgages by lowering the FHA Mortgage Insurance Premium by 25 to 35 basis points and ending the life of loan requirement on the FHA Mortgage Insurance Premiums.
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.
Letters to Regulators: Comment in Response to Proposed Amendment to Prohibited Transaction Class Exemption 84-14
AFREF led a letter to the Department of Labor in response to their proposed amendment to prohibited transaction class action exemption 84-14.
AFREF led a letter to President Biden calling on him to adopt contracting standards to: 1) narrow the gaps between CEO and worker pay; 2) reduce wasteful spending on stock buybacks; and 3) support workers’ rights to freedom of association and collective bargaining.