CUNA remains strongly supportive of the Federal Housing Finance Agency’s efforts to ensure the Government-sponsored enterprises (GSEs or the Enterprises) meet their public mission, it wrote to the agency Tuesday in response to a proposal outlining affordable housing goals for 2021. The FHFA states that both single-family and multifamily housing goals for 2021 will remain the same as the 2018-2020 levels, but the agency will engage in a new rulemaking next year to establish new levels for 2022 and beyond.

“[W]e acknowledge the constraints that the COVID-19 crisis has currently placed on FHFA’s ability to analyze and project reasonable changes to the existing housing goals and support the continuation of those goals at their current levels for 2021,” the letter reads. “We applaud FHFA’s decision to re-engage with this rulemaking in a year to establish housing goals for subsequent years.”

FHFA’s proposal also requested comment on factors to consider in determining whether a GSE that fails to meet a housing goal must submit a housing plan, including forbearance actions, loss mitigation efforts, loan modifications and other market support activities.

CUNA stated that the rulemaking “should not set a precedent that equates forbearances, loan modifications or other loss mitigation efforts with the Enterprises’ affirmative obligation to meet housing goals.”