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Hello,

I am writing today to provide feedback regarding federal rental protections, generally referred to as the federal tenants bill of rights. I work as a property manager in Washington State, and also own several rental homes of my own. Washington State has some of the most progressive renter protections in the country yet we still have an affordable housing crises. I firmly believe that many of the proposed protections and restrictions will have a chilling effect on the stock of affordable housing.

We in the industry have seen again and again that well-intentioned renter protections such as rent control can often have a negative impact on the stock of available and affordable homes for rent. The root cause of the issue is that the population is growing faster than new dwellings are being constructed. More and more people are competing for very few rentals. What we fundamentally need is more homes being built and brought into the market. However investors who develop large multifamily complexes aren’t going to invest in places where there are stringent rent controls that prevent them from seeing a return on their investment. Time and again we’ve seen that where rent control and extreme renter protections pass, new development comes to a standstill. Investors take their dollars elsewhere.

I have a few suggestions on how to help folks in need of affordable housing, without risking adverse outcomes. The single most effective program I have seen that was keeping people in their homes was the federal ERAP and TRAP rental assistance. In my area the non-profit in charge of distributing the funds did an outstanding job, and by the end of the eviction moratorium, all of my tenants were caught up on their rent. This program was a win for tenants, and a win for housing providers. Unfortunately that program ended June 30th 2023. I urge legislators to make it a permanent program.

Additionally, Housing Choice Vouchers (also known as Section 8) are something I as a landlord already proudly accept. However, we are rarely able to work with this program because the way HUD calculates Fair Market Rent is terribly out of date, and typical rents in the city center are far above the voucher limit. Additionally, my city has a university and two colleges, so there are many students competing with voucher holders for inexpensive housing. So even if someone in my city can get a voucher, they find it almost impossible to find a rental that fits within the limits of the voucher. I would urge the government to readjust how they calculate Fair Market Rent, and invest in building more dedicated public housing. I would also urge you to consider the sort of tax incentives that would encourage private investors to build tax credit complexes.

Finally, I would urge that any renter protections apply equally to all. The fundamental principle of Fair Housing law is that everyone should be treated the same. It is not reasonable to have different rules for different people depending on what kind of mortgage the owner has. It makes things more confusing to the tenants. Additionally, as a small time landlord myself, I don’t control who holds my mortgage. Mortgages for properties with four or fewer dwellings are frequently sold as commodities. How can tenants determine what sort of mortgage their landlord holds? Using this standard doesn’t resolve an issue, it merely creates confusion.

Even if these all of the proposed restrictions do go into effect, it doesn’t resolve the fundamental issue that as a nation, we simply need more housing. I urge you to please focus your efforts on increasing the stock of public housing, which already has robust tenant protections in place. I urge you to update the way HUD calculates the limits of Housing Choice Vouchers. I urge you to renew the temporary rental assistance programs, which helps people experiencing temporary hardship to stay in their homes. And I urge you to develop programs to help low and middle income folks transition into housing that they own.