The best way to manage climate change and natural disaster risk is to mitigate it by improving resiliency in the housing stock of the United States, CUNA wrote to a House Financial Services Subcommittee hearing on housing resilience in the face of climate change Tuesday.

“As climate change leads to natural disasters of increased frequency and intensity, it is likely that Americans and the housing finance system will see increased damages and losses as a result,” the letter. “It is imperative that the housing finance system does not mitigate its risk of these losses in ways that will leave vulnerable Americans to fend for themselves.”

“Improving the resiliency in our housing stock is the only method of managing climate risk in our housing system long-term that will not ultimately harm less wealthy and non-white Americans,” it adds.

CUNA believes mitigating the risk of climate change and its attendant natural disasters must be accomplished through a package of mutually reinforcing policies executed by the Federal Housing Finance Agency, the regulated entities, the Department of Housing and Urban Development, the Environmental Protection Agency, the Federal Emergency Management Administration, and the entire housing sector.

These mitigation strategies include:

• Encouraging compliance with up-to-date building codes;
• Financing the retrofitting and improved resiliency of existing housing stock; and
• Ensuring that those financial institutions who are able and willing to assist Americans most at risk have access to lending liquidity and support.

“This is the only sustainable way to manage this risk that does not ultimately abandon low- and moderate-income Americans,” the letter reads. “These combined mitigation efforts, supported by interlocking policies, would improve the resilience of housing against increasingly intense and frequent natural disasters and reduce losses to the regulated entities.”

CUNA also reiterated its concerns related to Property Assessed Clean Energy Program loans, and urged the FHFA to work with the Consumer Financial Protection Bureau to “quickly promulgate a PACE financing rule that subjects PACE programs to the Truth in Lending Act requirements.”