COMMUNITY INVESTMENT CORPORATION OF THE CAROLINAS
P. O. Box 19999 / Raleigh, NC  27619-9916 / 919-781-7979 / FAX:  919-781-2155

 

May 14, 2009

 

Alfred M. Pollard

General Counsel

Attention: Comments/RIN 2590-AA25

Federal Housing Finance Agency

Fourth Floor

1700 G Street, NW

Washington, DC 20552

RegComments@fhfa.gov

 

Dear Mr. Pollard:

 

The nation’s leading nonprofit lenders play a significant role in financing affordable rental housing in the United States.  The ongoing credit crunch has unfortunately hindered lenders’ ability to finance additional rental housing, right when such housing is most needed.  Your proposed rollback of the GSEs’ multifamily Special Affordable goals undermines economic recovery.

 

Fannie Mae and Freddie Mac – still the largest sources of mortgage finance capital in the United States – should be part of the solution to stabilizing communities by purchasing the performing, seasoned multifamily mortgages now held in portfolio by conventional lenders.  With a new supply of capital, the lenders could finance thousands more affordable rental units.  Your proposal to reduce the enterprises’ 2009 affordable housing goals to their 2004-2006 levels only exacerbates the lenders’ liquidity crisis, limiting their ability to meet the housing needs of a growing number of families.    

 

Our nonprofit lenders are blue-chip multifamily CDFIs serving areas as diverse as New York, Alabama, Massachusetts, California, and the Carolinas.  For decades they have made mortgages on buildings that low and moderate income (LMI) families are proud to call home.  With no troubled assets and most never suffering a loss on a loan, the lenders have very successful track records of pooling private capital to finance affordable rental housing.

 

Over $50 billion of these performing “community development loans” were originated annually in 2005, 2006, and 2007.  The proposal to set the enterprises’ 2009 bar at only $9 billion in affordable multifamily loans is a significant step backward.

 

We urge you to reconsider your proposal regarding the enterprises’ 2009 affordable housing goals, and look forward to working with you to increase the flow of private capital to low- and moderate-income individuals and underserved communities, on fair terms. 

 

Sincerely,

 

Cindy Wiggins-Tiede

Executive Vice President

Community Investment Corporation of the Carolinas (CICCAR)

 

 

Cindy Wiggins-Tiede

Executive Vice President

CICCAR

P.O. Box 19999

Raleigh, NC 27619-9916

800-662-7044

cindy@ncbankers.org