Comment Letter: Enterprise Duty To Serve Underserved Markets Amendments Proposed (FHFA)

The Partners for Rural Transformation (PRT) thank you for the opportunity to comment on the proposed amendment to FHFA’s Enterprise Duty to Serve Underserved Markets regulation. The Partners for Rural Transformation (known as the “Partners”) seek to strengthen local economies – generating local wealth that sticks – and build power among those living Native communities, communities of color, and persistently poor rural areas. By drawing on our collective voice and shared experiences, we’re working toward a reimagined future for rural America. The Federal Housing Finance Agency and the Partners for Rural Transformation have a similar objective: to ensure the regulated entities fulfill their mission and promoting equity in equitable accessibility to affordable and sustainable housing. Our partnership is led by a steering committee of Community Development Financial Institutions (CDFIs) serving three-quarters of the country’s persistent poverty counties, with headquarters in the Mississippi Delta, Appalachia, Native American Communities, the Deep South, the Rio Grande Valley and farming regions in the Rural West.

come dream. come build. (cdcb), a PRT partner, is located in Brownsville, Texas and serves the colonias along the U.S./Mexico Border. cdcb is devoted to utilizing collaborative partnerships to create sustainable communities across the Rio Grande Valley through quality education, model financing, efficient home design, and superior construction. Colonias are one of the designated geographies that the GSE’s are responsible for investing in via the Duty to Serve (DTS) program. With a lack of clear understand of what and where a colonia is, there is less capital investment from DTS and less accountability to address this gap in service. The potential amendment to Duty to Serve’s regulation will structurally incentivize the GSE’s to do more for hundreds of communities along the U.S. Mexico border and greater southwest. We hope to further bolster the FHFA’s proposed changes and make a wider call for other federal agencies to adopt such clear, functional definitions for the purposes of colonia investment.

 

See PRT’s full comment letter here to read more on PRT’s recommendations to eliminate persistent poverty.

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