Comment Letter to HUD: Affirmatively Furthering Fair Housing
October 17, 2018
Dear Sir/Madam:
Re.: Affirmatively Furthering Fair Housing: Streamlining and Enhancements
Thank you for the opportunity to comment on HUD’s Advance notice of proposed rulemaking, Affirmatively Furthering Fair Housing: Streamlining and Enhancements. I believe revising the Affirmatively Furthering Fair Housing rule has the potential to significantly improve the existing standard. The author of this comment has many years of experience in housing finance, both as operating executives and as students of housing finance systems and their policy issues.
My comments are in particular directed to your Questions:
- #7: Should the rule specify certain levels of effort on specific actions that will be deemed to be in compliance with the obligation to affirmatively further the purposes and policies of the Fair Housing Act (i.e., “safe harbors”), and if so, what should they be?
- #8: Are there any other revisions to the current AFFH regulations that could help further the policies of the Fair Housing Act, add clarity, reduce uncertainty, decrease regulatory burden, or otherwise assist program participants in meeting their AFFH obligations?
It has been reported in the media that HUD Secretary Ben Carson “plans to focus on restrictive zoning codes,” as these have “limited home construction, thus driving up prices and making it more difficult for low-income families to afford homes.”
But the federal government has limited control over state and local land-use policy. So what should HUD do to increase supply?
Read the full comment letter here.