Pursuant to the Safety and Soundness Act of 1992, the U.S. Federal Housing Finance Agency creates annual housing goals for mortgages purchased by Fannie Mae and Freddie Mac. These include separate goals for single-family and multifamily mortgages on housing that is affordable to low-income families. Setting housing goals are important because government programs intended to help low- and moderate-income families purchase homes have too often in the past excluded families of color.

When the FHFA sought to establish new housing goals and subgoals for 2022 through 2024, the agency proposed creating a single-family housing subgoal for Fannie Mae and Freddie Mac purchases of mortgages in minority census tracts (MCTs). A MCT is one with a minority population of at least 30% and a median family income of less than 100% of the area family median income. Democracy Forward submitted this comment in response, affirming the importance of the MCT subgoal to ensuring Fannie Mae and Freddie Mac fulfill their statutory duty to facilitate the financing of affordable housing for all low- and moderate-income families, including families of color.

Democracy Forward’s comment explains that the MCT subgoal is an essential step toward closing the racial homeownership gap and slowing gentrification and displacement. It also presents a constitutional analysis of the proposed subgoal for FHFA’s consideration. Our comment further encourages the FHFA to consider including the evidence it reviewed showing a need for the MCT subgoal, as well as the analysis of the subgoal’s constitutionality, in its final rule.

Read the entire comment here.