February 20, 2024
The Honorable Janet L. Yellen
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220
Re: Request for Information on Financial Inclusion
TREAS-DO-2023-0014
Dear Secretary Yellen,
The National Fair Housing Alliance® (NFHA™)1 appreciates the opportunity to respond to the U.S. Department of Treasury’s (Treasury) Request for Information (RFI) on Financial Inclusion.2 Through this RFI, Treasury is taking a step toward implementing the Financial Services and General Government Appropriations Act of 2022, which requires Treasury to develop a national strategy that should “establish national objectives for financial inclusion, set benchmarks for measuring progress, and offer recommendations for how public policy, government programs, financial products and services, technology, and other tools and infrastructure can advance financial inclusion.”3 For the reasons described below, we urge Treasury to:
- Implement the Fair Housing Act’s obligation to promote inclusive communities and embed fair housing in Treasury’s housing programs,
- Ensure fair housing principles are integrated into the Homeowner Assistance Fund, and
- Promote Responsible AI to support financial inclusion.
We commend Treasury for seeking input on this important topic and we hope that our comments will help inform Treasury’s views.
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BACKGROUND
A robust housing market cannot exist in the absence of financial inclusion and access to mortgage credit on fair and equal terms for all creditworthy borrowers. America’s history of unfair housing laws and policies has produced a dual market—a separate and unequal housing system that has benefitted White households while simultaneously debilitating Black, Latino, Asian American/Pacific Islander (“AAPI”), and Native American households. Because future housing demand will be driven by people of color, the safety and soundness of the future housing market depends on ensuring all consumers can access fair, safe, and responsible credit. Acting now to increase financial inclusion and housing opportunities among underserved communities is a cost-effective solution to strengthen the middle class and grow the economy. Increasing financial inclusion helps strengthen family wealth, spurs economic growth, improves health and educational opportunities for children, and promotes racial justice. Before turning to recommendations to increase financial inclusion, below is a discussion of the current landscape, which highlights the dire need for proactive initiatives and interventions.
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1 The National Fair Housing Alliance® (NFHA™) is the country’s only national civil rights organization dedicated solely to eliminating all forms of housing and lending discrimination and ensuring equal opportunities for all people. As the trade association for over 170 fair housing and justice-centered organizations and individuals throughout the U.S. and its territories, NFHA works to dismantle longstanding barriers to equity and build diverse, inclusive, well-resourced communities.
2 U.S. Department of Treasury, Request for Information on Financial Inclusion, 88 Fed. Reg. 88702 (Dec. 22, 2023), https://www.govinfo.gov/content/pkg/FR-2023-12-22/pdf/2023-28263.pdf.
3 U.S. Congress, Joint Explanatory Statement for Financial Services and General Government Appropriations Bill, 117th Congress (2023), https:// www.congress.gov/117/cprt/HPRT50347/CPRT117HPRT50347.pdf.
