Comment Letter to the Federal Housing Finance Agency Urging Them to Strengthen 2015-2017 Affordable Housing Goals

This letter to the Federal Housing Finance Agency affirms the importance of creating strong affordable housing goals for Fannie Mae and Freddie Mac to promote access to mortgage credit for lower-wealth borrowers. It urges the FHFA to strengthen the affordable housing goals by adopting recommendations from the National Community Reinvestment Coalition regarding the legality of FHFA’s three proposed evaluation methods, the Agency’s estimated size of the low- and moderate-income (LMI) mortgage market and market for communities of color, the absence of demographic considerations in the financial model used to calculate FHFA’s market projections for LMI communities and communities of color, and FHFA’s conclusion that LMI borrowers and borrowers in communities of color will significantly decline over the next three years.