First, we note that the affordable housing goals are part of the FHFA’s clearly laid out mission to reach underserved communities and that increasing access to mortgage credit in these communities is essential to the housing recovery. Second, we recommend that the FHFA maintain the two-part test, and strongly urge that the FHFA set a higher benchmark standard and require that both standards be matched or surpassed.

Third, we contend that how FHFA addresses findings of failure to meet a metric is critical and recommend the FHFA act more assertively to enforce procedures in the Housing and Economic Recovery Act when housing goals are not met. In recent years, the Enterprises have done a poor job of meeting their home purchase goals. Fourth, we recommend that FHFA establish higher benchmarks than those proposed, as warranted by prior historical performance. Specifically, we recommend setting the LowIncome Borrower Home Purchase Goal at 27%, the same level as the benchmark for 2010-2012.

Fifth, we recommend that FHFA continue to monitor and analyze the way that the lowincome areas purchase subgoal may contribute to gentrification and potential displacement of lower-income families and people of color. Sixth, we note that FHFA and the Enterprises’ pricing policies act as a barrier to the Enterprises’ ability to purchase loans to meet its affordable housing goals, and recommend the elimination of the loan-level price adjustments and excessive risk based pricing.