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  • Comment Detail

  • Date: 06/14/23
    First Name: James
    Last Name: Clark
    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 strong opposition to the proposed Equitable Housing Finance Plan rule. As an experienced professional in the housing finance industry and a concerned citizen, I firmly believe that it is crucial to take responsible action to uphold the chartered purpose of the Government-Sponsored Enterprises (GSEs) in order to ensure a reliable and affordable supply of mortgage funds nationwide. Unfortunately, the current proposed rule creates a framework that will lead to financial distress within the housing finance system, introduces discriminatory practices, and follows a path that could potentially lead to a housing recession reminiscent of the 2008 crisis.
    Addressing the affordable housing crisis in our community requires an approach that differs from past failed strategies. Two key steps must be prioritized, which seem to be lacking in the proposed rule. Firstly, we need to establish a framework that promotes financial education and encourages sound financial management practices, including personal budgeting and saving. Secondly, we should focus on implementing local-level planning initiatives that increase the availability of affordable housing. Additionally, providing funding incentives to states and local housing agencies, such as savings match or grant programs aimed at first-time homebuyers with incomes below the area median income, will help level the playing field and ensure equal access to the American dream of homeownership. It is imperative that we pursue these initiatives without jeopardizing the stability of the US banking and housing finance system.
    Furthermore, it is crucial to emphasize that promoting access to government programs based on preferential treatment, be it race, religion, marital status, national origin, or gender preference, directly violates existing Fair Housing and Fair Lending regulations. It is essential to treat all individuals fairly and equitably, without any form of discrimination. Creating a new framework that perpetuates discrimination is not a lawful solution to address past housing disparities.
    Moreover, I strongly oppose any relaxation of underwriting guidelines or the implementation of reduced pricing or lower loan level price adjustments for borrowers with less creditworthiness. History has shown that such policies have been ineffective in addressing the housing access gap and have, in fact, resulted in significant financial consequences, as evidenced by the 2008 housing recession.
    In conclusion, I firmly believe that the proposed Equitable Housing Finance Plan rule lacks an adequate framework to address the housing access imbalance, risks cementing a failed system, and neglects the importance of maintaining financially sound underwriting guidelines necessary for the GSEs to fulfill their chartered mission. I urge you to carefully consider my comments and refrain from adopting the proposed rule.

    Thank you for your time and thoughtful consideration.

    JC