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  • Comment Detail

  • Date: 05/03/23
    First Name: Alan
    Last Name: Blood
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB29

  • Comment

    Dear Federal Housing Finance Agency,

    I am writing to express my opposition to the proposed Equitable Housing Finance Plan rule. As a concerned citizen and long time worker in the housing finance industry, I believe that it is imperative that we take responsible action to uphold the chartered purpose of the GSE’s to help ensure a reliable and affordable supply of mortgage funds throughout the country. The rule as currently proposed creates a framework that will cause financial distress to the housing finance system, puts in place a discriminatory rule, and is a large step down the same path that lead to the 2008 housing recession.

    The goal of addressing the affordable housing crisis in our community won’t be met by using the same strategy that has failed in the past. This will be much more effectively addressed by taking two steps that don’t seem to be a primary focus of the proposed rule. First, creating a framework that will promote financial education, sound financial management including personal budgeting and saving. Second, promote planning steps at the local level to increase affordable housing and provide funding incentives to states and local housing agencies to participate in programs like a savings match or grant programs geared towards first-time homebuyers with incomes below the area median income. These initiatives would help to level the playing field and ensure that everyone has a fair shot at the American dream of homeownership without creating a rule that once again jeopardizes the US banking and housing finance system.

    In addition to not being sound fiscal policy, promoting access to government programs based on preferential treatment of any group based on race, religion, marital status, national origin or gender preference is a direct violation of the existing Fair Housing and Fair Lending regulations. It is important to ensure that all individuals are treated fairly and equitably without discrimination; creating a new discriminatory framework is not a legal way to address previous housing discrepancy.

    Furthermore, I am strongly opposed to relaxing underwriting guidelines or using reduced pricing or lower loan level price adjustments for less creditworthy borrowers. We have seen in the past that such policies have not been effective in addressing the discrepancy in housing access, and as noted, have in fact led to significant financial consequences culminating in the 2008 housing recession.

    I believe that the proposed Equitable Housing Finance Plan rule fails to provide a framework that will adequately address imbalance in housing access, opens the door to more permanently ensconce a framework that has failed in the past, and does not concentrate on maintaining financially sound underwriting guidelines that are necessary for the GSE’s to accomplish their chartered goal. I urge you to consider my comments do not adopt the proposed rule.

    Thank you for your time and consideration.

    Sincerely,

    Alan Blood