Policy Focus
NAAHL serves as an “honest broker” in public policy debates related to the flow of private capital to underserved areas. We provide strong representation for our industry in Washington, enjoying excellent relationships with Congress, the Administration, and Federal Banking regulators.
Enacted in 1977, the Community Reinvestment Act requires banks to help meet the credit needs of their communities, including low- and moderate-income neighborhoods, consistent with safety and soundness. CRA considers: consumer service; home mortgage, small business, and small farm loans; and loans and investments for affordable housing and other community development activities. NAAHL strongly supports CRA and updating its implementing regulations. NAAHL’s comment on the Federal Reserve Board, FDIC, and OCC’s notice of proposed rulemaking is available here.
Low Income Housing Tax Credits have generated equity investment in building and preserving 3.6 million affordable rental apartments since 1986 – equal to more than one-third of all U.S. apartments with similar rents. NAAHL member banks provide most LIHTC-based equity investments. NAAHL supports bipartisan legislation to expand LIHTC resources and preserve affordability. More information on LIHTC and legislation is available at https://rentalhousingaction.org/
The Neighborhood Homes Investment Act is proposed, bipartisan legislation (S. 98 and H.R. 2143) that would provide tax credits for investments in the construction and rehabilitation of owner-occupied homes in economically distressed urban, rural and suburban neighborhoods. In these neighborhoods, homes are in poor condition and property values are too low to support new construction or substantial renovation. The lack of move-in ready homes makes it difficult to attract or retain homebuyers, causing property values to decline. Neighborhood Homes would break this stalemate by creating a federal tax credit that covers the gap between the cost of building or renovating homes and the price at which they can be sold. More information is available at https://neighborhoodhomesinvestmentact.org/
The multifamily housing financing partnership between the HUD/FHA’s multifamily risk sharing program and Federal Financing Bank (FFB), a government corporation supervised by the Treasury Department, offers an excellent platform to support the development and preservation of affordable rental housing with significant opportunities for expansion. FHA’s risk sharing program provides underwriting flexibility and efficiency for lenders, currently state and local housing finance agencies (HFAs). FFB funding offer a low, market-based interest rate comparable to a Ginnie Mae security and an inexpensive, timely, and reliable execution. In 2021, the Biden administration restarted FFB funding through FY 2024. More information is here.
Naturally occurring affordable housing is the older housing that is unsubsidized but affordable for low- and middle-income renters. This housing is often found in urban and older suburban neighborhoods. It is at risk of physical decline, rent increase, redevelopment, or gentrification. Ensuring that NOAH is affordable and in good condition is essential to an overall affordable housing strategy.
