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  • Comment Detail

  • Date: 03/17/16
    First Name: Bill
    Last Name: Druliner
    Organization: GreenPath, Inc
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA27

  • Comment

    March 17, 2016
    Mr. Alfred M. Pollard
    General Counsel
    Federal Housing Finance Agency
    400 7th Street SW, Eighth Floor
    Washington, DC 20219
    Re: Comments/RIN 2590-AA27

    Dear Mr. Pollard,
    GreenPath applauds the Federal Housing Finance Agency (FHFA’s) proposed duty-to-serve rules that were released in
    December 2015. As a nationwide non-profit housing counseling and financial education organization, we recognize that
    this initiative will help focus efforts of the Enterprises on three critical areas – manufactured housing, affordable housing
    preservation, and rural communities.

    In 2015, GreenPath served over 115,000 low- and moderate-income families across the nation. Access to affordable
    housing is a key issue for many of these families, and less attention is paid to the needs of manufactured home owners and
    rural communities that we serve.

    In particular, we applaud the focus on the manufactured housing market. Encouraging and refining high-quality financing
    options for low- and moderate-consumers could have a significant impact on the financial capability of hundreds of
    thousands of Americans each year.

    We also encourage the FHFA and the Enterprises to consider the value of access to high-quality consumer financial
    education and counseling when developing their Underserved Markets Plans. By requiring or incentivizing participation in
    such programs, FHFA and the Enterprises can significantly improve the subsequent performance of loan portfolios. Broader participation in such programming by low- and moderate-income families results in those consumers having the Financial Capability tools needed to improve their resiliency, which improves their quality of life, the stability of their communities, and the performance of loan portfolios for lenders and investors.

    GreenPath proactively partners with hundreds of lenders and community-based organizations across the country to offer
    housing counseling and financial wellness programming. Please let us know if we can be of assistance as the organizations
    develop their Underserved Markets Plan.

    Sincerely,
    Bill Druliner
    Community Engagement Manager
    GreenPath Financial Wellness
    414.477.8749
    bdruliner@greenpath.org

    About GreenPath
    GreenPath is a nationwide, non-profit financial counseling and education organization that assists consumers with credit
    card debt, housing debt, student loan debt and bankruptcy concerns. The organization currently partners with over 700
    organizations, including community-based organizations, workforce development boards, employers and credit unions. Our goal is help groups incorporate and deliver high-quality financial education and counseling to the communities that they serve.