FINAL COMMENT: PRT Speaks on FHFA Fair Lending Oversight

Rural America has been largely disinvested over the past decades, especially in areas of persistent poverty. We are seeing the impacts of this disinvestment across federal and state agencies in almost every sector of life. Of the 395 persistent poverty counties, eight out of ten are nonmetro (rural). Most (60%) of people living in persistent poverty counties are people of color. In fact, 4 out of 10 (42%) persistent poverty counties are majority people of color. The FHFA’s oversight has been essential in upholding accountability of the Enterprises’ mandates to serve underserved markets. This includes the FHFA’s annual scorecard, ensuring that Fannie and Freddie have reached their minimum thresholds of promoting affordability, fair lending, and equity within the underserved markets they are mandated to address.


FHFA’s New Proposed Rule that codifies the oversight of the regulated entities is a step forward in ensuring historically underserved and unserved markets receive equitable investments. Many of the underserved communities overlap with PRT Partner service areas, regions of higher concentrations of persistent poverty counties, of which the majority are communities of color. There is no dispute that there is a racial wealth gap and racial homeownership gap, in large part due to barriers established by policies and programs over past decades. With the codification of FHFA’s oversight of the regulated entities, there will be increased accountability to serve these areas and increased transparency to the public of where improvements still need to be made.


PRT fully supports the FHFA oversight of the regulated entities, as this will create formal standards, definitions, reporting guidelines, and protocols for non-compliance that are necessary to ensure rural America receives equitable access to homeownership and investment in their communities. PRT Partners, who serve not only as CDFIs in these communities but as a multitude of community resources, are positioned to share expert insights into what their communities, states, and region need to consider in the design of the oversight standards to ensure all rural, native, and persistently poor communities are not further marginalized by program design and implementation.

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