Comment Detail

Comment

July 21, 2023

The Honorable Sandra Thompson
Federal Housing Finance Agency
400 7th Street, SW
Washington, D.C. 20024

Re: Feedback on the Federal Housing Finance Agency (FHFA) Request for Information on Tenant Protections

Dear Director Thompson:

Thank you for the opportunity to provide this feedback from our organization regarding the need for strong enforceable tenant protections in rental properties with FHFA mortgages.
I am writing on behalf of the Housing and Community Development Network of NJ (the Network). We are New Jersey’s statewide association of more than 275 community development corporations, individuals and other organizations that support the creation of affordable homes, economic opportunities, and strong communities. A number of our members own and/or manage rental properties with federally backed mortgages. Most represent tenants living in rental properties with FHFA mortgages. The conditions in these buildings affect quality of life in the surrounding neighborhoods.

We urge the FHFA to take strong action to create strong, clear renter protections, and enforce those protections for renters living in buildings with FHFA mortgages. Your actions will help put the nation on a pathway towards greater protection for all renters. It is needed to enforce the contract between landlords and tenants, so that in exchange for the rent that renter pay, they will receive a safe and decent place to live. In addition, there will be clear communication on how to report issues and the time frame within which they will be addressed.

As we have seen with the COVID pandemic, housing is health care. Renters get sick because of building conditions, lack of heat, mold, lead paint, etc. and sometimes become homeless, unprotected from the elements. This is an issue of racial and gender equity as poor housing conditions are experienced most often by people of color, families who do not speak English as their first language, and single mothers.
We strongly urge FHFA to create the following protections for families living in properties with federally backed mortgages, including but not limited to:

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.
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.

Although New Jersey has source of income protection and just cause eviction, it is important to have these protections nationally. Lack of housing that is safe, decent, accessible, and healthy for renters and their families continues to be a major problem for renters in living in properties with federally backed mortgages.

Let me share a few concrete examples as to why these protections are needed in buildings with federally backed mortgages in the City of Newark, New Jersey’s largest city. Georgia King Village – 250 Georgia King Court, with over 200 assisted apartments – has been under the threat of receivership by the City of Newark because of poor conditions. In February 2023, the City of Newark moved to rescind a property tax break for the complex if property owners do not address conditions in the building. The building is plagued by rat infestation, mold, and other long-standing problems that tenants say have persisted for seven years. The issue is in court. The owner apologized to tenants and replaced unresponsive employees and ineffective contractors to resolve the problem. If FHFA had enforceable renter protections in place, tenants would not have to have lived with these deplorable conditions for years.

Another example is the city’s largest complex for seniors and people with disabilities, St. Mary’s Villa, on 425 Sanford Avenue. Poor communication with the complex’s largely Haitian community has led to people not knowing their rights and, according to tenant leaders, residents feeling intimidated.
Maintenance issues continue to be a problem for tenants in Garden Spires, 175-195 First Street. In 2021, after new owners put millions of dollars into repair, the city’s code enforcement officers inspected Garden Spires and found violations that included roach and mice infestation, bathroom leaks, defective stoves, and overloaded dumpsters. The entry doors for buildings were defective and several units in needed to be repainted due to water leakage. According to tenant leaders, maintenance issues persist.
We urge FHFA to implement strong enforceable tenant protections in all rental properties with federally backed mortgages. These protections are essential for very low-income renters including seniors and people with disabilities, to live with dignity and safety.

Sincerely,

Staci Berger,
President and CEO, Housing and Community Development Network of NJ
Affordable Housing Alliance Belmont Homes
Bergen County United Way Better Community Housing of Trenton, Inc.
Bridges Outreach, Inc.
Camden Coalition of Healthcare Providers

Camden Community Development Association Camden County Habitat for Humanity

Camden Lutheran Housing, Inc. Catholic Charities, Diocese of Metuchen

Catholic Charities, Diocese of Trenton Central Jersey Housing Resource Center

Clinton Hill Community Action Coastal Habitat for Humanity

Collaborative Support Programs of NJ Coming Home Middlesex

Community Access Unlimited, Inc. Community Affairs and Resource Center

Community Hope, Inc. Consumer Credit and Budget Counseling, Inc.

The Corporation for Supportive Housing Cumberland County Habitat for Humanity

East Brunswick Community
Housing Corporation
Elizabeth Coalition to House the Homeless
Elizabeth Development Company Family Promise of Burlington County

Family Promise of Morris County

Garden State Episcopal Community Development Corporation Family Promise Union County

Garden State Home
Gateway Community Action Partnership Habitat for Humanity of Bergen County
Habitat for Humanity Cape May County Habitat for Humanity of Salem County
Habitat for Humanity of South Central NJ HANDS, Inc.

Holly City Development Corporation Homefront
Homeless Solutions Homes For All

Housing Initiatives of Princeton Housing Partnership NeighborWorks HomeOwnership Center

Housing Us Ironbound Community Corporation Isles, Inc.

Isles, Inc. Jewish Community Housing Corporation of Metropolitan NJ
Jewish Family Service of Atlantic &
Cape May Counties Jewish Renaissance Foundation
La Casa de Don Pedro Lincoln Park Coast Cultural District
Leviticus 25:23 Alternative Fund, Inc. Lutherans Engaging in Advocacy Ministry NJ
Mission First Housing Group Monarch Housing Associates
Moorestown Ecumenical Neighborhood Development Inc. (MEND) Morris Canal Community Development Corporation

Morris Habitat for Humanity New Brunswick Tomorrow

New Community Corporation NJ Coalition to End Domestic Violence

NJ Community Capital NJ Community Development Corporation

NJ HIV Housing Collaborative New Jersey Urban Mayors Association

NewBridge Services, Inc. Northern Ocean Habitat for Humanity

Northwest New Jersey Community Action Program, Inc.
Operation HOPE Inc.
Parkside Business and Community in Partnership
Passaic Affordable Housing Coalition
Passaic County Habitat for Humanity Paterson Task Force

PennReach Premier Community Development Corporation

Princeton Community Housing Project Freedom Inc.
Project Live, Inc. Puerto Rican Association for
Human Development, Inc.

Raritan Valley Habitat for Humanity, Inc.
Reformed Church of Highland Park Affordable Housing Corporation
Region Nine Housing Corporation Rescue Mission of Trenton
Saint Joseph’s Carpenter Society Sierra House

Stand Up for Salem Inc. The Community Builders, Inc.

The Community Preservation Corporation The Heart of Camden, Inc.

The Supportive Housing Association of NJ The Waterfront Project, Inc.

Town Clock Community Development Corporation Triple C Housing

Unified Vailsburg Services Organization Urban League of Essex County

Visions and Pathways Women Rising, Inc.
Women’s Center for Entrepreneurship York Street Project