Comment Detail

Comment

P.O. Box 104, Blue Mountain Lake, New York 12812 – Ruraladvocates@gmail.com
RE: Comments/RIN 2590 – AA27
New York State Rural Advocates appreciates this opportunity to comment on Federal Housing Finance Agency’s proposed rulemaking regarding 12 CFR Part 1282 Enterprise Duty to Serve underserved markets. We believe that the regulator is correct in identifying manufactured housing, affordable housing preservation and rural markets as underserved markets deserving of special efforts.
Rural Advocates is a membership organization made up of community based not for profits, CHDOs and small private developers committed to meeting the affordable housing needs of rural communities. We work with communities, policy makers and funders to identify appropriate and promising approaches to meeting needs in rural communities. We welcome the attention and resources of FHFA and the Enterprises and we stand ready to support these efforts in any way we can.
Question # 12: As is pointed out, mobile homes continue to be an important form of housing for lower income, rural residents. We think that the Enterprises should be provided with Duty to serve credit for the broadest possible range of real estate lending possible and should not be limited to borrowers with specific needs.
Questions # 13 and 14: We would encourage FHFA to consider the pilot program now being undertaken by USDA to provide mortgage financing for energy efficient mobile homes located in mobile home parks in Vermont and New Hampshire. Provided with long term leases by park operators, these housing units have attributes similar to those units located on privately owned land and under the proper circumstances may qualify as mortgage loans rather than chattel loans. As a matter of public policy, it seems to us that it is important that we develop the means to provide permanent financing for mobile homes located in parks.
Question # 68: Access to appropriate credit continues to be a serious challenge for home buyers in many rural markets. The continuing trend of bank consolidations results in fewer lenders in many rural communities and small towns and relatively lower values in rural communities tend to discourage large lenders and realtors alike from participating in rural markets.
The rule correctly recognizes the difficulties of valuing real estate in rural markets where the number of sales, wide variation in local market conditions and large numbers of “unconventional” properties make the appraisal process particularly difficult. We agree that allowing qualified appraisers discretion in identifying and evaluating comparable sales is important to supporting the purchase of single family homes by lower income residents of rural areas.
Question # 69: In the past, cooperation between the Enterprises, community based not for profits and community banks has been one mechanism that has had some success in overcoming the specific challenges of mortgage lending in rural places. Small towns and rural places often lack the experience and expertise necessary to address unique aspects of financing in rural markets. Technical and product related support by the Enterprises can help to address these shortcomings in capacity. These communities often rely on the smallest of commercial lenders including institutions without ongoing relationships with the Enterprises. Aggressive outreach and technical assistance can help overcome the isolation which often exists in rural communities.
Question # 70: NYS Rural Advocates considers an appropriate definition of “rural” to be a daunting question and we find some shortcomings in each of the four definitions offered. Defining rural areas in complex urbanized States like New York present genuine operational issues for our member organizations. We find that many small, low population municipalities within MSAs are faced with challenges similar to those of other rural communities. Both private and public investment is drawn to larger communities within the MSA and this “competition” with larger, more politically significant communities leaves these places with much reduced access to credit, investment activity and public grant making.
While of the four choices, we prefer the USDA definition of rural , as it comes the closest to identifying those communities within the MSAs which tend to be functionally rural. That being said, we would encourage the regulators to look at the work of the Housing Assistance Council (HAC) regarding this issue. HAC has developed a sophisticated and generally satisfying approach to identifying “functionally” rural communities.