On March 17, 2016 NAR submitted comments in response to the Federal Housing Finance Agency’s proposed "Duty to Serve" rule. The rule is intended to facilitate a secondary market for mortgages on residential properties in specified underserved markets. NAR's comments Support a Duty to Serve objective to support manufactured housing financing that by having Fannie Mae and Freddie Mac provide leadership in bringing standardization to the manufactured housing finance space. Additionally, NAR supports the GSEs contributing to the preservation of affordable rental housing by ensuring a strong secondary mortgage market for affordable rental housing to meet the high demand across the country and development continues to lag behind. NAR reiterated comments that preserving affordable homeownership opportunities should also recognize the Enterprises disposition strategies by ensuring that institutional investors aren’t given an advantage over potential owner occupant families through the bulk sale of properties or sale of loans. The comment letter also stated that Fannie and Freddie’s responsibilities under the Duty to Serve rule should include revising their fee structure to match the risk of their book of business. The fees [Gfees and loan level price adjustments or LLPAs] charged by the Enterprises are pushing many borrowers to FHA. The Enterprises can both have robust underwriting guidelines without pricing out many borrowers from the conventional financing space. Finally, supported the proposed guidelines for the GSEs to make a broader push to the serve rural housing market.
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