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Date:
01/25/2023
Name:
Deborah Thompson
City:
Eden
State:
North Carolina
Zip Code:
27288
Email Address:
djst25@grmail.com
Telephone Number:
Submitter Type:
Fannie Mae
Organization:
Organization Type:
Federal Agency:
State or Local Government Agency:
Submitter Item:

Submission

Can a credit union that is a CDFI institution, but not considered a "small financial institution" (assets under $304M) originate mortgage loans in designated rural areas under the Duty to Serve initiative? What all in included in "assets" to determine the $304M? The definition I found from 1271.1 CFR - Assets includes furniture and equipment, leasehold improvements, and capitalized start-up costs. If the goal is to lend in under served areas within the Duty to Serve criteria, why is the size of a financial institution in that area an issue? I understand about the consolidation of banks and the loss of bank branches and the economic impact on those areas, but the goal is still to increase home ownership in those rural communities. Thank you



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