Comment Detail

Comment

The National Association of Real Estate Brokers (NAREB), the oldest professional minority real estate trade association in the United States, greatly appreciates the spirit and intent of the Federal Housing Finance Agency’s (FHFA) proposed Amendments to Regulations on Minority and Women Inclusion issued in the October 27, 2016 Federal Register.
Based on NAREB’s review of the proposed Amendments, clearly FHFA’s objectives are to strengthen and expand the range of opportunities that minorities, women, and individuals with disabilities have available within FHFA, Fannie Mae, Freddie Mac, and the Federal Home Loan Banks.
Diversity and inclusion, as described in the proposed Amendments, fortify FHFA’s establishing mission to create avenues for all Americans to own a home regardless of race, creed, gender or disability. FHFA, by proposing to institute a more definable, actionable, measurable and internally-supported plan throughout its regulated entities, codifies its intent to increase homeownership for minorities and other identified affected groups.
It appears that FHFA has recognized implicitly that lack of diversity in their workplace and throughout the financial services industry in general, continues to thwart, or at the very least impede, minorities’ access to mortgage capital – the essential element needed to own a home and build an asset base for their families.
NAREB understands the interconnectedness among and between the financial services industry, FHFA and its regulated entities. By taking a stronger, more transparent stand that recognizes and addresses potential systemic bias, we believe FHFA is not only enabling homeownership growth for minorities, but it also is putting in place internal employment and business development strategies that foster inclusiveness and diversity.
As FHFA moves forward with the Amendments to “expand the scope of outreach to improve conditions…” , NAREB recommends that FHFA, the GSEs and the FHLBs confer and work with organizations such as NAREB that have been and continue to be the trusted advisors in their respective communities that consistently create pathways to homeownership. These organizations are positioned to provide reservoirs of diverse talent which can be resources feeding the FHFA diversity pipeline.
This can be accomplished through collaboration between minority community-based, service and trade organizations (such as NAREB) and the GSEs to create academic and professional development training curricula in mortgage finance and asset disposition management for career, employment and government contractor opportunities that support promotion of homeownership. NAREB envisions that such collaborative events targeted at minority professionals and focused upon career opportunity, job placement, professional development, certification activities, and events would enhance FHFA’s intent to strengthen diversity within the GSEs and the FHLBs. At the same time, this approach if it is to be successful requires the development of an effective, multi-level outreach and marketing strategy designed to attract a larger diverse pool of qualified minority candidates to these events. This mutually beneficial approach not only supports FHFA’s strategic goals to ensure greater diversity and inclusion, but also increases participation at NAREB and other minority organizational events.
NAREB stands ready and welcomes the opportunity to be positioned in the employment and contracting funnel as a contributing source to increase diversity and inclusion within FHFA and its regulated entities. Since 1947, NAREB has served as subject matter experts on all issues related to increasing homeownership and advocating for more professional, executive level, minority talent in the financial industry and in government. We continue to advocate for inclusion in both areas. As a nationally-recognized real estate trade organization, NAREB offers its services, meetings, and vast network to FHFA and the GSEs to augment outreach efforts designed to identify diverse executive level talent for positions within FHFA and the regulated entities. Numerous credible studies report, as is widely known, that it is good business to embrace fully, the principles of inclusion and diversity within a work culture. In addition, NAREB offers a platform for FHFA and its regulated entities to interact with a plethora of diverse and competent real estate and ancillary industry practitioners to establish dialogue designed to break down systemic barriers to homeownership for minorities and other identified classes.
In summary, NAREB applauds the rationale and the strategic approach outlined in the proposed Minority and Women Inclusion strategy. We see these strategic objectives as FHFA’s solid commitment to increasing business contracting opportunities and executive level employment that, together, serve as a linchpin that facilitates increasing homeownership through equitable access to credit and mortgage financing by Black Americans, other ethnic minorities, women and persons with disabilities. NAREB looks forward to working with FHFA and its regulated entities to ensure that the Amendments are fully implemented.