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  • Comment Detail

  • Date: 07/05/21
    First Name: Wesley
    Last Name: Stefanick
    Email: wes@delawarerealtor.com
    Organization Type: other
    Organization: Delaware Association of REALTORS®

  • Comment

    Sandra Thompson
    Acting Director, Federal Housing Finance Agency
    Office of Housing and Regulatory Policy
    400 7th Street SW, 9th Floor
    Washington, DC 20219

    RE: Request for input: Short Term Rental Units in Condominium, Cooperative, and Planned Unit Development Projects

    Dear Acting Director Thompson:

    The Delaware Association of REALTORS® appreciates the opportunity to provide information and comments in response to the recent Request for Input on Short Term Rental Units in Condominium, Cooperative, and Planned Unit Development Projects. On October 7, 2020, Fannie Mae modified its lending rules to tighten parameters on whether or not the GSE will lend in properties with significant short-term rentals and hotel-like amenities, known as condo-tels.

    The Delaware Association of REALTORS® has several concerns about these modifications to Fannie Mae’s condo-lending protocols, including:
    • The modified requirements contain ambiguous and undefined language that could complicate Fannie Mae’s designation process, such as what constitutes “seasonal rental” and how long an owner needs to reside in the property.
    • The modifications to the single-family guides that could limit and restrict financing options in markets with large numbers of second homes or projects with high shares of second homes, even though these specific properties may have excellent underlying loan values.
    • By leaving the determination of eligibility of projects up to lenders who may not have the skill or expertise to review all relevant information relating to a designation of a specific property, further harm is imposed on potential buyers and the communities through inaccurate or incomplete eligibility determinations.
    • Condo boards and Homeowners Associations (HOAs) do not have a way to appeal Fannie Mae’s designation of their property, examine their lender review, or provide additional input that could change Fannie Mae’s decision or assessment of their project.

    Fannie Mae should carefully review all comments received in response to this RFI and make changes necessary to ensure these modifications help manage Fannie Mae’s portfolio risk without unduly harming the economies that rely on resort and second-home real estate activity.

    Sincerely,

    Wesley T. Stefanick
    Chief Executive Officer