- Congress has finally passed the much awaited Tax extender’s legislation, H.R 2029 The Consolidated Appropriations Act, included is a win for affordable housing advocates – the nine percent minimum Low Income Housing Tax Credit was made permanent.
- The Federal Housing Finance Agency (FHFA) has proposed a Duty to Serve Underserved Markets Rule, required by the Housing and Economic Recovery Act of 2008, which requires Fannie Mae and Freddie Mac (GSEs) to serve three underserved markets: Manufactured Housing, Affordable Housing Preservation and Rural Housing. The GSEs would be required to establish and implement plans to serve each market and would receive duty to serve credits for success. The proposal is open for comment until March 17, 2016.
Tag Archives: manufactured housing
Thurday’s Advocacy & Think Thank Round-Up
- Federal Reserve Bank of NY Study Insolvency after the 2005 Bankruptcy Reform finds that the decline in bankruptcy filings resulted in a rise in the rate and persistence of insolvency as well as an increase in the rate of foreclosure.
- Harvard’s Joint Center for Housing Studies’ Eradicating Substandard Manufactured Homes: Replacement Programs as a Strategy, this paper aims to make recommendations for the design of nonprofit-based programs for the replacement of older, substandard manufactured housing and its potential as an affordable housing solution.
- The Technical Assistance Collaborative (TAC) and the National Low Income Housing Coalition (NLIHC) released Creating New Integrated Permanent Supportive Housing Opportunities for ELI Households: A Vision for the Future of the National Housing Trust Fund. This report highlights important innovations in affordable housing financing policy designed to benefit Extremely Low Income (ELI) households, including people with significant and long term disabilities who need Permanent Supportive Housing (PSH). According to the authors, PSH approach is a highly cost-effective best practice housing strategy that combines ELI housing with voluntary community-based support services.
Good Data Makes Good Mortgages
The CFPB issued a proposed rule about increasing the quality of information that lenders report about mortgage applications. The press release regarding the proposed rule states that these changes will ease the reporting burden on lenders, and that may very well be true. But the contested part of these rules relate to the type of information to be collected:
- Improving market information: In the Dodd-Frank Act, Congress directed the Bureau to update HMDA regulations by having lenders report specific new information that could help identify potential discriminatory lending practices and other issues in the marketplace. This new information includes, for example: the property value; term of the loan; total points and fees; the duration of any teaser or introductory interest rates; and the applicant’s or borrower’s age and credit score.
- Monitoring access to credit: The Bureau is proposing that financial institutions provide more information about underwriting and pricing, such as an applicant’s debt-to-income ratio, the interest rate of the loan, and the total discount points charged for the loan. This information would help regulators determine how the Ability-to-Repay rule is impacting the market, and would also help the Bureau monitor developments in specific markets such as multi-family housing, affordable housing, and manufactured housing. The proposed rule would also require that covered lenders report, with some exceptions, all loans related to dwellings, including reverse mortgages and open-end lines of credit.
Lenders are not going to like this, because this new information may be used against them in a variety of ways — in Fair Housing lawsuits, by the CFPB in enforcement actions, by members of Congress seeking to increase credit access to various constituencies.
I like this because regulators and academic researchers have been hamstrung by limited and stale data on the fast-moving mortgage market. The mortgage market is often driven by the short-term profit-seeking of private actors and by special interests pushing their agendas with the Executive and Legislative Branches. Good data can inform good decision-making that can ensure that the housing finance system is vibrant and provides sustainable credit for households over the long term.
Comments on the proposed rule are due by October 22, 2014.