Comment Detail

Comment

Honorable Sandra L. Thompson
Director
Federal Housing Finance Agency
400 7th St SW
Washington, DC 20024
Dear Director Thompson,
I am writing on behalf of the Hood Properties, LLC, representing multiple rental units in Oregon. I am writing to share our views on the Federal Housing Finance Agency
(FHFA) Request for Input (RFI) on Tenant Protections for Enterprise-Backed Multifamily Properties.
My state is suffering from a shortage of rental housing like many parts of the country. Chronic
underproduction has led to higher costs for consumers, especially in affordable and underserved
markets. While the factors causing this undersupply are numerous and complex, this is a moment when
the availability of reliable and competitively priced capital is essential for the health of the rental
housing industry.
The supply gap cannot be met without the necessary capital for development and rehabilitation in all
markets, especially those that may not meet the credit or return standards required by many private
capital debt providers. To bring down rental costs in the underserved markets of my state, the FHFA and
Fannie Mae and Freddie Mac (the Enterprises) should be focused on supply and facilitating a secondary
mortgage market which helps create more affordable housing stock.
Specific tenant protections are better decided by the communities they impact rather than the
imposition of federal regulations which circumvent or conflict with leases that have been carefully
crafted to comply with the laws applicable to that property. These laws are unique to individual
communities and state and local lawmakers are best suited to respond to the needs of their
constituents.
The rental property owners and operators in my state must comply with existing local, state and federal
tenant protection laws. As such, the FHFA and Enterprises’ consideration of adding more regulations to
the already complex housing regulatory system is a major concern for my members. Any additional
requirements associated with Enterprise-backed financing would impact rental housing providers’ ability
to comply with existing laws, adding uncertainty to a market already subject to intense scrutiny and
regulation across all levels of the government.
There is also significant concern about the types of tenant protections that the FHFA and Enterprises are
considering; rent regulation, source of income mandates and restrictions on eviction, to name a few
examples, all impact a rental property operator’s ability to comply with the economic terms of their
loans and meet their additional mandatory operational expenses. If these requirements prove
burdensome enough, I expect many of our members will turn away from financing options facilitated by
the Enterprises or, even worse, exit the rental housing market altogether.
Fannie Mae- and Freddie Mac-backed financing is a critical tool to keep housing costs affordable for low-
and moderate-income renters. However, increased regulation would only increase the cost of providing
housing and contribute to the affordability gap we see today. The FHFA and Enterprises should instead

look to programs which can increase housing production and supply by making Enterprise products
more competitive to help us meet our collective housing needs.
Thank you for soliciting these comments and considering our views,
Sincerely,
Tonya Davis
Small Business Owner