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Comment

Director Thompson,

Being a New York State landlord I can tell you the overreaching laws to "Protect" tenants have done just the opposite. Extending the time for a tenant to stay in their home prior to eviction, not being able to request multiple months rent up front, not being able to collect additional security deposits, and the looming "Good Cause Eviction" is not helping tenants everywhere. The unintended consequence of these items are that I am now a much more thorough screener and I have denied more applications because of it. In the past, I would look at an application that didn't check all of the boxes and I would consider an additional months rent/ larger deposit but since I cannot do that I am going to deny an application. If someone has a pet I am almost always going to deny the application because our security deposits are capped/ equal one month's rent. One cat or one dog can cause thousands of dollars in damage. I have identified multiple tenants that I would want to get rid of before something like Good Cause Eviction comes to fruition. These "Tenant Protections" are short term protections for a tenant at a given time but long term it is hurting other tenants from getting good quality housing. The question should be "what is the government doing to make being a landlord easier and less expensive?" If there were more landlord protections and more capital available to landlords we could increase housing units and increase the number of landlords. This would affect the supply curve drastically making it more competitive for landlords to compete. When there is an increase of competition on the Supply side the Demand side wins!!!!

Thank you for the opportunity to respond to your Request for Input (RFI) on how the Federal Housing Finance Agency (FHFA), in its oversight of Fannie Mae and Freddie Mac, can best provide affordable housing opportunities for renters. Approximately 40% of the National Association of REALTORS®'s (NAR) 1.5 million members own at least one rental housing unit, playing a vital role in providing safe, quality, and affordable housing in neighborhoods nationwide.

As the FHFA examines ways to improve access to affordable housing, it is critical to acknowledge the most significant driver of housing unaffordability is the limited supply of available housing. According to NAR data, the United States has an underproduction gap of over 5.5 million units – a key underlying reason housing costs have increased. On top of this, inflation has increased the prices of goods and services for all Americans. As housing providers strive to provide affordable housing opportunities in their communities, they also contend with rising mortgage rates and increased costs for supplies, services, and maintenance. When inflation is high, the prices of materials increase. That means it becomes exceedingly more expensive for construction teams to build new homes or renovate existing ones. Ultimately, these high costs spill into the housing market and lift home prices for new builds and existing housing.

As REALTORS®, we are committed to upholding the very specific provisions of our contracts with residents, and we often go above and beyond what is required to ensure residents have safe, quality, and affordable places to live. Rental housing is a deeply complex issue that is unique to every community. Creating additional layers of policies to a space that is already heavily regulated by state and local governments will have severe unintended consequences for renters as housing providers are leaving the market in communities where affordable housing is sorely needed.

Affordable housing is pivotal to creating paths to upward mobility for people across the country. I appreciate your commitment to ensuring we achieve this goal without impeding the creation of much-needed housing supply. Andrew Castine