July 31, 2023
The Honorable Sandra Thompson
Federal Housing Finance Agency
Washington, DC
RE: National Housing Law Project’s Response to FHFA’s Request for Input on Multifamily Tenant Protections
Dear Director Thompson:
The National Housing Law Project (NHLP), members of the Housing Justice Network, and the undersigned organizations engaged in housing justice advocacy submit this comment letter in response to the Federal Housing Finance Agency’s (FHFA) Request for Input on Multifamily Tenant Protections.
NHLP’s mission is to advance housing justice for people living in poverty and their communities. NHLP achieves this by strengthening and enforcing the rights of tenants and increasing housing opportunities for underserved communities. Our organization also provides technical assistance and policy support on a range of housing issues to legal services and other advocates nationwide. NHLP hosts the national Housing Justice Network (HJN), a vast field network of over 2,000 community-level housing advocates and resident leaders. HJN member organizations are committed to protecting affordable housing and residents’ rights for low-income families across the country.
To inform this RFI response, NHLP surveyed 185 housing advocates from its Housing Justice Network (HJN) and other networks. Together, these advocates come from more than 40 states, and they have shared their experiences helping tenants navigate their state and local landlord/tenant system.1 Their perspectives appear throughout this response in both qualitative and quantitative form.
I. FHFA & TENANTS IN MULTIFAMILY PROPERTIES WITH FEDERALLY-BACKED MORTGAGES………………………………………………………………………………………………………………. 4
A. Strengthening tenant protections falls within FHFA’s statutory mandate and the GSEs’ charters……………………………………………………………………………………………………………………4
B. Strengthening tenant protections falls within FHFA’s duty to affirmatively further fair housing…………………………………………………………………………………………………………………… 5
C. Tenants, especially low-income tenants, need a federal floor of minimum protections on the private rental market………………………………
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- For a more detailed breakdown of survey respondents, analytical methodology, and complete results, please see Quantitative Appendix. 1
See the complete document pdf here.
