Comment Detail

Comment

FHFA Request for Information on Tenant Protections
Sample Comment Letter
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The Honorable Sandra Thompson
Federal Housing Finance Agency
Washington, D.C.
Director Thompson,
Thank you for the opportunity to provide feedback on the Federal Housing Finance Agency (FHFA)
Request for Information on tenant protections. My name is Phil Prehn and I am an advocate with ARISE Independent Living Center. organization. I am writing this comment in my role as the systems change advocate at ARISE, the designated Center for Independent Living (CIL) for Central New York. ARISE is dedicated to removing barriers to full community integration of people with disabilities.
In existence since 1979, we currently serve more than 8,000 people each year from our offices located in the counties of Onondaga, Oswego, Madison, and Cayuga. ARISE currently employs over 800 people and we offer over 50 programs—all of which are consumer-directed, maximizing choice and opportunity for the people we serve.
I am writing to share my experience and to urge FHFA to take bold action to create
clear, strong, and enforceable renter protections for households living in rental properties with federally
backed mortgages. Given the broad reach of FHFA’s work, any renter protections created by FHFA should
cover a significant share of renters across the nation and put America on a pathway towards stronger
protections for all renters.
Federal renter protections are critically needed to address the power imbalance between landlords and
renters that puts renters at greater risk of housing instability, harassment, and homelessness and fuels
racial and gender inequity.
To help ensure greater housing stability, FHFA should create new renter protections for households living
in properties with federally backed mortgages, including:
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, so that families can have greater choice about
where to live.
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.
I have seen what happens in communities without strong, enforceable tenant protections. In Syracuse, rent has increased so much that the majority of apartments are being rented for above HUD's Fair market Rents. The waiting list for affordable units can be as long as two years.

We urge FHFA to take bold action to implement mandatory, standardized protections – paired with
strong enforcement – for all households living in properties with federally backed mortgages, including
larger developments and smaller properties. FHFA must continue to engage tenants and directly
impacted people throughout its process of establishing and implementing renter protections, and
protections must be centered on racial and social equity as explicit goals. These protections– along with
to large-scale, sustained investments and anti-racist reforms – are necessary to ensure that everyone,
including the lowest-income and most marginalized renters, have a safe, quality, affordable, and
accessible place to call home.
Sincerely,
Phil Prehn
ARISE Independent Living Ceter