Comment Detail
Date: 08/31/22 First Name: Carlie Last Name: Petrus Organization: N/A City: N/A State: N/A Attachment: N/A Number: RIN-2590-AB21 Comment
After reviewing the 2023-2024 Multifamily Enterprise Housing Goals Proposed Rule, I am in total support of the proposed switch of methodologies of measuring Enterprise performance on multifamily housing goal. As a resident of Northwest Indiana and recently deciding to move out of my parent’s home for the first time, I have seen first-hand how hard it can be people of lower socioeconomic status to obtain affordable, quality, housing. It seems that having your own apartment or home has become less and less obtainable and more indicative of wealth.
The housing market fluctuates by nature and in the past couple of years alone, we have seen historic highs and are now slowing down; the status of current market cannot possibly be represented by a (numeric) goal that was set the previous year. If the multifamily Enterprise housing goal were to be measured by percentages rather than a fixed rate, it not only would be more representative of the market but would prevent Enterprises from deprioritizing affordable multifamily housing once their goal has been met. I also believe that by basing goals on percentages and setting minimum percentages, Enterprises will be forced to gather more detailed information on the properties financed through them. If Enterprises neglect to gather information on multi-family housing affordability, it counts towards the total number of houses but not toward the percentage that they are aiming to achieve to stay in compliance with the Safety and Soundness Act of 1992, thus negatively affecting them in the long run.