Family Stability and Opportunity Vouchers Act of 2019

Oppose the proposed changes to the disparate impact standard as interpreted by the U.S. Department of Housing and Urban Development (HUD). HUDs existing disparate impact rule is a necessary tool to challenge the structural inequalities that persist in housing and lending today. It has been an effective mechanism for uncovering forms of discrimination which are covert or unintentional and must be preserved to maintain access to credit and homeownership for all communities. Support HR 4783, to require the Director of the Federal Housing Finance Agency to require each Enterprise to include a preferred language question on the form known as the Uniform Residential Loan Application Support the following principles be included in any GSE reform: Establish capital levels consistent with what the GSEs are charging the market currently, consistent with statute and the unique risk characteristics of the GSEs. Maintain lines of business that enable the cross-subsidization of lending within all markets and communities, benefiting all borrowers. Retain FHFAs role as a strong independent regulator, with full oversight and approval of operations, capital requirements, fees, charges, and prudential standards. Ensure full and equal access for all lenders, regardless of size, including a prohibition on volume discounts with respect to guarantee fees, buy up and buy down fees, cash pricing, loan level price adjustments, and risk-sharing pricing. Serve all markets, including underserved, rural, and urban areas, equally. Expand access to all creditworthy borrowers and affordable housing through pooling of risk, more level pricing, and equitable distribution of the cost of catastrophic capital to protect against another market failure like the Great Recession; strengthening and ensuring compliance with affordable housing goals; enforcement of duty to serve obligations; compliance with fair housing and lending laws; and full funding of the Housing Trust Fund and Capital Magnet Fund. We believe that chartering additional guarantors would be overly disruptive and would not foster competition in the secondary market, instead creating a race-to-the-bottom environment for loan purchases and a potential competitive advantage that comes from vertical integration. Continue the credit risk transfer program by the GSEs to reduce their overall risk consistent with an economic benefit, with prohibitions on market structures/actions that create an unlevel playing field for loan origination. Charge a fair ongoing fee for maintenance of the existing Treasury line of credit or any explicit federal guarantee. Continue moving forward with administrative recapitalization plans to permit the GSEs to exit conservatorship into a utility-type system, including regulation of pricing and rates of return, to provide investors a fair return and to further the GSEs public mission. While we believe critical GSE reforms have already been accomplished through HERA and FHFA administrative actions, any additional reforms should achieve and conform to the above principles. HMDA data should still be disaggregated by race, gender, income and census tract category Support S. 3083, legislation to create 500,000 new Family Stability and Opportunity Vouchers. These are vouchers specifically designed for low-income families with young children to end homelessness and expand their neighborhoods of opportunity Support providing greater clarity to lenders on how FHA will address potential loan defects Oppose HUD's proposed Disparate Impact rule, as the existing rule is crucial to the continued and strengthened access to fair credit and homeownership

Client expense: $72,500 · Firm income: Not reported

Government targets: AMTRAK - Natl Railroad Passenger Corporation, Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), U.S. Postal Service (USPS), White House Office

Disabled Access Credit Expansion Act (H.R. 4045 and S.2290); Fair Housing Act Implementation and enforcement; Family Stability and Opportunties Vouchers Act; (S.3083) Eviction Crisis Act (S.3030)

Client expense: $50,000 · Firm income: Not reported

Government targets: Bureau of Citizenship & Immigration Services (BCIS), Centers For Medicare and Medicaid Services (CMS), Education, Dept of, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), SENATE, Transportation, Dept of (DOT)

S. 1583 - Lead-Safe Housing for Kids Act of 2019 S. 3083 - Family Stability and Opportunity Vouchers Act of 2019 H.R. 3316 - Neighborhood Homes Investment Act H.R. 4008 - No Biometric Barriers to Housing Act of 2019

Client expense: $10,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE