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Comment

Director Thompson,

We operate apartment properties in Portland, Oregon, which recently passed a slate of new rental housing regulation intended to protect tenants. While well intentioned, the effect has been to dramatically increase regulatory complexity facing landlords in the city. This has caused investors to shift their preferred target areas outside city boundaries. The City also passed a tax on apartments several years ago to fund a tenant protection office. This tax has increased the cost of providing housing and had a dampening effect on new development.

Our industry is already heavily regulated at federal, state and local levels. Oregon recently tightened its statewide rent control law to prohibit annual rent increases over 10%, regardless of how high general inflation is running. All these regulations increase risks to landlords and dissuade investment in housing. I would hate to see the federal government further burden rental housing with more regulation. If anything, we need to move toward less regulation to spur supply of much needed rental housing.

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. Malcolm McIver