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  • Comment Detail

  • Date: 07/25/23
    First Name: Youth Alliance for Housing
    Last Name: (YAH)
    Email: hello@youthalliance4housing.com
    Organization Type: N/A
    Organization: YAH

  • Comment

    Thank you to the Federal Housing Finance Agency (FHFA) and Director Thompson for issuing a Request for Information (RFI) on tenant protections in properties with federally-backed mortgages.

    We are writing on behalf of Youth Alliance for Housing, whose mission is to build the power of young people within the broader tenants movement.

    Housing costs are American households’ single biggest monthly expense, and the rental crisis is threatening people’s ability to live safely. Our current housing market fails to meet the affordability needs of many Americans. In 2023, the average hourly wage needed to afford a one-bedroom apartment in the US was $23.67. With a shortage of truly affordable housing, tenants are left with few options. Meanwhile, the housing market is more consolidated than ever before, landlords are left unregulated in most communities, and the federal government has failed to pass meaningful housing legislation in years.

    Young people throughout the country are being displaced from the neighborhoods they have grown up. High rents and lack of tenant protections are forcing us to move constantly, denying us the opportunity to grow up with stability and meaningful connections with our communities.

    Government Sponsored Enterprises like Fannie Mae and Freddie Mac work with banks to offer $150 billion to landlords in financing every year, without any strings attached. Their portfolios encompass over half of the rental market. As the regulator of these agencies, the FHFA should intervene to protect tenants and condition federal financing on a basic set of protections. With that in mind, we recommend that FHFA make the following policy changes as a result of this rulemaking process:
    Rent regulations: Protect tenants from and limit egregious rent hikes.The FHFA should limit annual rent hikes to 1.5 times the Consumer Price Index or 3%, whichever is lower, in Enterprise-backed properties. These rent increase limits should be applied universally and as a requirement. Limits on rent increases will protect tenants from eviction and/or homelessness by creating a schedule for reasonable and gradual rent increases.
    Good cause eviction: Prohibit evictions without good cause, ensuring every tenant has the right to a lease renewal. Good cause is defined as serious and repeated lease violations provable in a court of law.
    Ban source of income discrimination: Prohibit landlords from discriminating against tenants based on their source of income including federal housing assistance (i.e., vouchers).
    Freedom from discrimination: Enforce existing laws that prohibit landlords from denying a tenant rental housing based on race, physical or mental ability, and family make-up, and expand protections to prohibit discrimination based on sexual orientation, gender expression or identity, immigration status, conviction and/or arrest history, bankruptcy history, eviction history, or credit score.
    Safe, quality, accessible housing standards: Require all landlords to keep their properties in good condition, and to ensure homes are accessible for people with disabilities. No renter should have to live in an inaccessible home or in housing conditions that put their health and safety at risk.
    Landlord registry: Tenants should have access to information about their landlord including their name and phone number.
    Tenant right to organize: Tenants have the right to form tenants’ unions or resident councils free from fear of retaliation from the landlord or managing agent. Ownership and management representatives must not interfere with the creation or actions of tenant organizations.
    Fair leases: Landlords must use standardized and clearly defined leases free of abusive terms.
    Office of Tenant Protections: A team charged with protecting tenants and enforcing their rights in properties with federally backed mortgages.
    In addition, we encourage the FHFA to prioritize the needs of tenants in any subsequent rulemaking process, and to co-develop any policy resulting from this process alongside those most impacted by the housing crisis. This will help ensure that the impact is most effective and equitable.
    Again, thank you for your attention to this matter. If you have any questions or would like to follow up, you can reach us at hello@youthalliance4housing.com

    Sincerely,
    YAH