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  • Comment Detail

  • Date: 06/22/23
    First Name: Heather
    Last Name: Lusk
    Email: hlusk@hhhrc.org
    Organization Type: other
    Organization: Hawai'i Health & Harm Reduction Center
  • Comment

    Federal Housing Finance Agency Washington, D.C.

    Director Thompson,

    Thank you for the opportunity to provide feedback on the Federal Housing Finance Agency (FHFA) Request for Infomration on tenant protections. My name is Heather Lusk, the Executive Director of Hawai'i Health & Harm Reduction Center (HHHRC). HHHRC’s mission is to reduce harm, promote health, create wellness and fight stigma in Hawaii and the Pacific. We focus our efforts on those disproportionately affected by social determinants of health, including but not limited to: people living with and/or affected by HIV, hepatitis, substance use, and the transgender, LGBQ and the Native Hawaiian communities. I am writing to share my experience and to urge FHFA to take bold action to create clear, strong, and enforceable renter protections for households living in rental properties with federally backed mortgages. Given the broad reach of FHFA’s work, any renter protections created by FHFA should cover a significant share of renters across the nation and put America on a pathway towards stronger protections for all renters.

    Federal renter protections are critically needed to address the power imbalance between landlords and renters that puts renters at greater risk of housing instability, harassment, and homelessness and fuels racial and gender inequity.

    To help ensure greater housing stability, FHFA should create new renter protections for households living in properties with federally backed mortgages, including:
    1. Source of income protections to prohibit landlords from discriminating against households receiving rental housing assistance such as Section 8 Housing Choice Vouchers, or Supplemental Security Income (SSI), or local rental assistance, so that families can have greater choice about where to live.
    2. “Just cause” eviction standards, which limit the causes for which a landlord can evict a tenant or
    refuse to renew a tenant’s lease when the tenant is not at fault or in violation of any law.
    3. Rent gouging protections to stop landlords from dramatically and unreasonably raising rents.
    4. Requirements to ensure housing is safe, decent, accessible, and healthy for renters and their families.
    We urge FHFA to take bold action to implement mandatory, standardized protections – paired with strong enforcement – for all households living in properties with federally backed mortgages, including larger developments and smaller properties. FHFA must continue to engage tenants and directly impacted people throughout its process of establishing and implementing renter protections, and protections must be centered on racial and social equity as explicit goals. These protections– along with large-scale, sustained investments and anti-racist reforms – are necessary to ensure that everyone, including the lowest-income and most marginalized renters, have a safe, quality, affordable, and accessible place to call home.

    Sincerely,

    Heather Lusk, LCSW, MSW
    Executive Director
    Hawai’i Health & Harm Reduction Center