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  • Comment Detail

  • Date: 08/22/24
    First Name: John
    Last Name: Smith
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB34

  • Comment

    Dear FHFA:

    I am writing to express my concerns regarding the recent proposal by the FHFA to reduce the Low-Income Small (5-50 units) Multifamily Subgoal from 2.50% to 2.00% for the 2025-2027 period. While I understand the complexities involved in setting these targets, I believe this reduction could have unintended negative consequences for an already underserved segment of the housing market.

    The Critical Role of Small Multifamily Properties:
    Small multifamily properties (5-50 units) play a crucial role in providing affordable housing, especially in urban and suburban areas where large-scale developments may not be feasible or desirable. These properties often serve as workforce housing, offering affordable rents to low- and moderate-income families who might otherwise struggle to find suitable housing. By supporting these properties, the FHFA helps ensure that affordable housing options remain available in a variety of communities, preventing the concentration of low-income housing in only a few areas.

    Impact on Affordable Housing Availability:
    Reducing the subgoal could lead to a decline in the availability of financing for these small multifamily properties, which in turn could reduce the number of affordable units available in the market. This is particularly concerning at a time when the demand for affordable housing far outstrips supply. By lowering the subgoal, the FHFA risks exacerbating the affordability crisis, making it even more difficult for families to find housing that fits their needs and budgets.

    Supporting Economic Diversity and Stability:
    Small multifamily properties are often naturally affordable, meaning they do not rely on government subsidies to keep rents low. By maintaining or even increasing the current subgoal of 2.50%, the FHFA can support the preservation of these naturally affordable units, promoting economic diversity within communities. This is vital for creating stable, resilient neighborhoods where individuals and families of varying income levels can coexist and thrive.

    Request for Reconsideration:
    Given the critical role that small multifamily properties play in the housing market, I strongly urge the FHFA to reconsider the proposed reduction in the Low-Income Small Multifamily Subgoal. Instead of lowering the target, I encourage the FHFA to maintain the current level of 2.50% or even consider increasing it. Doing so would send a strong signal of support for affordable housing and help address the ongoing affordability challenges facing our communities.

    Thank you for your attention to this matter.