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 FHA to strengthen language access for borrowers with limited English proficiency.
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 Letter in Response to OSTP’s RFI on Equitable Data Engagement and Accountability
AFREF joined a letter responding to a request for information from the White House Office of Science and Technology Policy about how federal agencies can better support collaboration with other levels of government, civil society, and the research community regarding the production and use of equitable data.
Letters to Regulators: Response to Request for Comment on Proposed Changes to the Uniform Standards of Professional Appraisal Practice
AFREF joined civil rights and consumer advocacy organizations in responding to the Appraisal Standards Board’s request for comment on the proposed changes to the Uniform Standards of Professional Appraisal Practice that would add nondiscrimination language to USPAP’s Ethics Rule. The letter recognizes the history and persistence of racial discrimination in appraisals and makes several specific recommendations for fighting discrimination in the appraisal process.
AFREF sent a letter to FHFA on their Duty to Serve plans.
Americans for Financial Reform Education Fund (AFREF) and partners submitted comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation on their proposed revision to the regulations that implement the Community Reinvestment