Comment Detail

Comment

Thank you for the opportunity to respond to the Federal Housing Finance Agency’s Request for Input on Multifamily Tenant Protections. I am writing on behalf of Legal Services of Northern Virginia, which provides services in a number of civil legal areas including housing law. Please see the attached letter for our complete response to the RFI; however, we have summarized our recommendations below.

Based on trends in our local and national housing market which has shown a decrease in access to affordable housing, we make the following recommendations to the FHFA:

-Provide model lease agreements to owners which include definitions of all legal terms and a summary of all estimated one-time and monthly fees (mimicking disclosure requirements from the Truth in Lending Act)
-Establish a National Statement of Tenants Rights and Responsibilities
-Compel owners to submit justification for any rent increases greater than the percentage increase in Area Median Income (AMI)
-Mandate that owners use clear language in notices regarding the timing for reconciliation or legal action
-Require owners to maintain translations of their leases in at least the five most common foreign languages spoken in their area
-Good cause requirements for lease termination and eviction, similar to standards of the Low-Income Housing Tax Credit program

For more detail on why these recommendations are necessary to protect tenants, please review the attached letter.