The undersigned civil rights organizations do not believe the mandatory July 1 compliance date extension for the General QM Final Rule until October 1, 2022 is necessary since the new General QM definition and the Patch overlap so thoroughly. Please download the letter to continue reading.
The Center for Responsible Lending, the National Community Stabilization Trust (NCST), the Consumer Federation of America, the National Housing Conference, and the Leadership Conference on Civil and Human Rights, appreciate the opportunity to comment on the proposed rule to amend the Enterprise Regulatory Capital Framework (ERCF) by refining the prescribed leverage buffer amount (PLBA) and the credit risk transfer (CRT) securitization rules for Fannie Mae and Freddie Mac (the Government-Sponsored Enterprises (the GSEs)). Overview and Executive Summary We support the Federal Housing Finance...
Congress cannot miss this once-in-a-generation opportunity to expand homeownership and create racial justice and equity. Targeted DPA is one of the most cost-effective strategies to shrink disparities in wealth and narrow the homeownership gap.1 More than half a million Black and Latino families could become first-generation homeowners thanks to this program even if funded at $30 billion over ten years. In this case, DPA would help 288,208 Black families; 223,649 Latino; 88,000 Native American, Asian American, and Pacific Islander families; and 249,398 white families achieve homeownership.
The Center for Responsible Lending, Americans for Financial Reform Education Fund, and the National Community Stabilization Trust support FHFA’s proposed affordable housing goals for the GSEs and would support a higher subgoal for the GSEs buying mortgages for homes in minority tracts where borrower income was not above 100 percent of AMI. Encouraging the GSEs to provide more families with access to homeownership, and particularly those of color to close the related racial homeownership and wealth gaps, through aggressive yet achievable goals is the right thing to do.
Read the full comment for a: Summary of the current racial disparity in homeownership caused by longstanding and continuing discrimination; Discuss of the challenges and opportunities in redressing these disparities; Suggested steps to maximize the role of the GSEs in this endeavor.
From the opening paragraph of the letter : On behalf of the undersigned civil rights, consumer protection, and housing policy organizations, we write to urge your continued prioritization of the housing-related provisions in the upcoming reconciliation package. These provisions are a down payment on this Administration's commitment to addressing long-standing inequities in our housing system and addressing the worsening racial wealth gap exacerbated by the nation's housing crisis.
The Center for Responsible Lending, Self-Help Credit Union, and Self-Help Federal Credit Union submitted this public comment letter to the Department of Housing and Urban Development in support of its proposed rule to recodify its previously promulgated rule titled, “Implementation of the Fair Housing Act’s Discriminatory Effects Standard” (2013 Rule). The comment supports restoring the power of the “disparate impact” standard, a crucial legal tool used to identify and eliminate discrimination.
The undersigned fair housing, affordable housing and civil rights organizations write to you in response to the proposed Interim Final Rule entitled “Restoring Affirmatively Furthering Fair Housing Definitions and Certifications.” We are heartened to see HUD moving toward restoring a meaningful Affirmatively Furthering Fair Housing (AFFH) rule to better implement the letter and spirit of the Fair Housing Act (“the Act”). This provision of the Fair Housing Act has largely gone unenforced, continuing the harms that have resulted from this nation’s legacy of government-sponsored residential...
From the letter to Acting Director Shalanda Young, Office of Management and Budget We the undersigned civil rights and consumer advocacy organizations are writing in response to the Office of Management and Budget’s May 5, 2021, Request for Information on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government. We applaud the OMB for seeking input on the critically-important topic of advancing equity in government. Our organizations believe that the responses below will help inform the OMB’s policies.
From the letter to Secretary Marcia L. Fudge : On behalf of the clients and communities we represent, the 155 undersigned organizations are writing regarding the FHA foreclosure moratorium and the deadline for FHA borrowers to access COVID-19 forbearance plans, both of which expire on June 30, 2021, pursuant to Mortgagee Letter 2021-05. We urge HUD to extend the foreclosure moratorium and the deadline to access forbearance plans to August 31, 2021, for forward mortgages, and to extend this deadline to December 31, 2021, for Home Equity Conversion Mortgages (HECMs, or reverse mortgages).