Comment Detail

Comment

My name is Seth Holloway and I have been a provider of safe and affordable rental housing for several years. This letter is in response to the FHFA’s Request for Input on tenant protections for properties using federally-backed financing.

As a rental housing provider, I am committed to complying with Equal Housing laws as well as state and local tenant protection laws which are tailored by and for individual jurisdictions. For landlord-tenant law, the needs of one particular city or state may not apply to another. Attempting to develop and then impose national standards will bring disparate and unreasonable results. Imposing unworkable requirements can only complicate regulations that each locality has judged to adequately protect residents. Therefore, there can be no “one-size-fits-all” approach to tenant protections in an industry that fundamentally operates at a local level. Please recall the first rule of real estate: Location, Location and Location.

Fannie Mae- and Freddie Mac-backed financing is an important tool to keep housing costs affordable for low- and moderate-income renters and to provide affordable, safe housing in underserved markets. However, if accepting these loans would limit control of my operations, that could ultimately hurt my ability to make mortgage payments. I may also look to other means of financing in the future to maintain operational and financial viability. Any increases in the cost of providing housing in my community contribute to the affordability crisis we see today. Insurance costs, real estate taxes and limited availability of materials to properly maintain my properties are all making housing more expensive.

In order to better manage these houses and continue to supply safe, affordable housing to my customers (tenants), it is important to verify the ability of each new applicant to be able to pay the rent on time. Nonpaying tenants are an expensive proposition which increases costs to other customers, just like shoplifting.

Rather than impose unneeded, one-size-fits-all tenant protection requirements on federally-backed properties that will ultimately harm the marketplace, I respectfully urge FHFA to focus on policies that would increase the supply of affordable housing and expand utilization of Fannie Mae and Freddie Mac. Fannie Mae’s Expanded Housing Choice Initiative, which incentivizes acceptance of Housing Choice Vouchers with lower pricing and flexible loan terms, and its Rent Payment Reporting Program, are examples of more balanced and sustainable solutions that help us collectively get to our shared goal of keeping renters stably housed.

Thank you for considering my views,

Seth Holloway