Comment Detail

Comment

Firstly, the Rent is Too Damn High! Sadly, that includes housing funded by the Enterprises. While it is beyond the purview of the FHFA, there should be support for legislation like the bill proposed by Rep. Yvette Clark’s Affordable Housing and Area Median Income Fairness Act. I am an ELI or even below that and am ineligible for most affordable housing complexes where I live because my income is too low, regardless of the fact my rent is now 70% of my income. I’m currently negotiating with my Dr. to allow me, despite minor health issues, to give plasma for money in order to be able to continue to live in my apartment.

The median income in the lower wards of Holyoke, MA, where I live, is purported to be between $14K - $19K, but the low-income limits set on a high-quality building which received CBDG funding requires that one make 32K a year, which is nearly double the income of the people living in the neighborhood. Mass Development has given monies to Wxxx Developers to build a 55+ building in the lower wards. Again, a single person would have to have an income of $32K in order to live there. However, couples would be able to live there if their combined income were a little over $40K making it more affordable for couples. Most of the new affordable housing in the Pioneer Valley of Western Massachusetts has rent that is ‘too damn high” for actual poor people.

The quality, safety, and dignity of affordable housing in my region, and across the country, is subpar, which is unacceptable. I've heard stories of Section 8 inspections that disqualify units with minor issues, such as a cracked tile on the floor or a loose microwave handle, while passing units with major problems like water damage and mold. Given that post-COVID area rents exceed the amount determined to be Fair Market Rent by the Section 8 program, concerns about Section 8 disqualifying viable rental units are immaterial at this point. To provide adequate housing for people, we need to increase the Section 8 Fair Market Rent levels, and the government needs to enforce the rules against source of income discrimination. Unfortunately, there are currently few enforcements of the laws against Section 8 voucher discrimination, which is unacceptable. It is unconscionable that the American Government will spend an unlimited amount of money to satisfy the greed of the investment class while ignoring the needs of the people who need affordable housing.

Rent regulation is necessary to protect affordable housing, especially when the people’s money, in the form of a $200 billion bailout, is involved in the process of securing or creating the units. One problem with the Enterprises” voluntary multi-family units tenant protections program is that the protections are not permanent and can be ended prematurely by paying off the loan. Low income people are human beings, whose state of being housed should not have to depend on the temporary terms of a loan agreement, nor the whims of individuals or REIGs. Unregulated rent increases under any circumstance are onerous, but in the current state of housing, cost burden, and homelessness that exist in the US, unregulated rent increases are insufferable.

One would think that there would be no need to take public comment to require the Enterprises to have a standard of habitability for housing they fund, or to mandate apartments be inspected for habitability, or that there should be standards and consequences when the standards of living are not met. There ought not be a need to mandate that evictions must be for cause, and not because you want higher income renters, or tenants should have rights, and an easy avenue to make sure any violation of their rights is speedily addressed. And it’s common knowledge that sexual abuse by people in positions of power over tenants is not an isolated event, it should not be said that the management company should be held accountable for the violence of their employees, and significant consequences should be meted out.

It's surprising that public comment is necessary to require the Enterprises to have a standard of habitability for the housing they fund, or to mandate apartment inspections for habitability. There should be universal standards for all landlords with federally-backed mortgages and all rental properties, including larger multi-family properties and smaller one-to-four unit properties, and consequences when the standards of living are not met. Evictions should only be for cause, not because management wants higher income renters, and tenants should have rights with an easy avenue to address any violation of their rights..The best way to ensure tenants are protected is to establish an office of tenant protections, a landlord registry, a requirement for standardized leases, an enforced ban on source of income discrimination, and an enforcement of laws against discrimination on the basis of race, physical or mental ability, and family make-up, and expand prohibition of discrimination based on sexual orientation, gender expression or identity, immigration status, conviction of arrest history, bankruptcy history, eviction history or credit score. It is common knowledge amongst long-time housing advocates that abuse, including sexual abuse, by people in positions of power over tenants is not an isolated event .It's clear that management companies should be held accountable for the violence of their employees, and they should be found in technical default and should not be eligible for future loans. Any violation of tenants rights should lead to the landlord being found in technical default and they should never be eligible for a future loan.

The best way to make sure to have a safe just and equitable housing policy at the FHFA and HUD is to have poverty class and working class tenant at the decision-making table as equals.