2012-2014 Enterprise Housing Goals
|Federal Information & News Dispatch, Inc.|
CFR Part: "12 CFR Part 1282"
RIN Number: "RIN 2590-AA49"
Citation: "77 FR 34263"
DATES: Written comments must be received on or before
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FHFA invites comments on all aspects of the proposed rule, and will revise the language of the proposed rule as appropriate after taking all comments into consideration. Copies of all comments will be posted without change, including any personal information you provide, such as your name, address, and phone number, on the FHFA Internet Web site at http://www.fhfa.gov. In addition, copies of all comments received will be available for examination by the public on business days
A. Statutory and Regulatory Background
The Federal Housing Enterprises Financial Safety and Soundness Act of 1992 (Safety and Soundness Act), as amended by the Housing and Economic Recovery Act of 2008 (HERA), requires FHFA to establish annual housing goals for mortgages purchased by
FOOTNOTE 1 See 12 U.S.C. 4561 et seq. END FOOTNOTE
FOOTNOTE 2 See 75 FR 55892. END FOOTNOTE
The housing goals established by FHFA include four goals and one subgoal for single-family, owner-occupied housing and one goal and one subgoal for multifamily housing. The single-family housing goals target purchase money mortgages for low-income families, families that reside in low-income areas, and very low-income families, and refinancing mortgages for low-income families. /3/ The multifamily special affordable housing goal targets multifamily housing affordable to low-income families, and the multifamily special affordable housing subgoal targets multifamily housing affordable to very low-income families. /4/
FOOTNOTE 3 See 12 CFR 1282.12. END FOOTNOTE
FOOTNOTE 4 See 12 CFR 1282.13. END FOOTNOTE
Although the Enterprises' substantial market presence has been key to restoring market stability, neither company is capable of serving the mortgage market today without the ongoing financial support provided by the
While the Enterprises are in conservatorship, all Enterprise activities, including those in support of affordable housing, must be consistent with the requirements of conservatorship under the Safety and Soundness Act, as amended by HERA. If FHFA determines that the Enterprise housing goals cannot be achieved consistent with the goals and requirements of conservatorship or in light of market conditions, FHFA, as conservator for each Enterprise, may take additional action, including suspension of the Enterprise housing goals until they can be achieved and in a manner consistent with the conservatorships. In the meantime, FHFA is proposing to continue with the existing structure of the housing goals, including the market-based approach that was adopted for 2010 and 2011, with new benchmark levels in place through 2014.
C. Prospective and Market-Based Approach
The current housing goals regulation sets forth single-family housing goals for 2010-2011 that include: (1) An assessment of Enterprise performance, as compared to the actual share of the market that meets the criteria for each goal; and (2) a benchmark level to measure Enterprise performance. For the single-family housing goals, an Enterprise has met a goal if it achieves the benchmark level for that goal, even if the actual market size for the year is higher than the benchmark level. An Enterprise has failed to meet a goal if its annual performance falls below both the benchmark level and the actual share of the market that meets the criteria for a particular goal for that year. FHFA determined that this approach is appropriate in light of recent market turmoil, especially while the Enterprises are operating in conservatorship, and in light of the difficulty of making projections accurately even in more stable economic environments. For those reasons too, and because the correspondence between available market data and the Enterprises' actual goals-qualifying activity is not exact, FHFA reserves some flexibility in determining whether an Enterprise has substantially complied with one or more goals.
III. Summary of Proposed Rule
The proposed rule would establish new benchmarks for the single-family housing goals for 2012, 2013 and 2014. The proposed rule would also establish new levels for the multifamily housing goals for those years. FHFA also seeks comments on whether the housing goals regulation should be amended to address the possibility that an Enterprise would receive credit under the housing goals for the purchase of a multifamily mortgage that was intended to facilitate the conversion of the property securing the mortgage from affordable rents to market rate rents.
IV. Single-Family Housing Goals
A. Analysis of Factors for Single-Family Housing Goals
Section 1332(e)(2) of the Safety and Soundness Act, as amended by HERA, requires FHFA to consider the following seven factors in setting the single-family housing goals:
(1) National housing needs;
(2) Economic, housing, and demographic conditions, including expected market developments;
(3) The performance and effort of the Enterprises toward achieving the housing goals under this section in previous years;
(4) The ability of the Enterprise to lead the industry in making mortgage credit available;
(5) Such other reliable mortgage data as may be available;
(6) The size of the purchase money conventional mortgage market, or refinance conventional mortgage market, as applicable, serving each of the types of families described, relative to the size of the overall purchase money mortgage market or the overall refinance mortgage market, respectively; and
(7) The need to maintain the sound financial condition of the Enterprises. /5/
FOOTNOTE 5 12 U.S.C. 4562(e)(2). END FOOTNOTE
FHFA's consideration of the size of the market for each housing goal includes consideration of the percentage of goals-qualifying mortgages under each housing goal, as calculated based on Home Mortgage Disclosure Act (HMDA) data for the three most recent years for which data is available. /6/
FOOTNOTE 6 See 12 U.S.C. 4562(e)(2)(A). END FOOTNOTE
FHFA's analysis of each statutory factor is set forth below.
1. National Housing Needs
The recent single-family housing market has been characterized by falling homeownership rates, high vacancy rates, weak sales, lower home prices, high foreclosure rates, and stricter underwriting. These trends are likely to continue in the near term. In many instances, they have had differing impacts for homeowners and home seekers of different ethnicities. Despite demand spurred by the "First Time" and "Move Up Home Buyer" tax credits in 2009 and 2010, the seasonally adjusted overall U.S. homeownership rate declined to 65.5 percent in the first quarter of 2012, after peaking at 69.1 percent in 2004. The homeownership rate for non-Hispanic whites declined from a peak of 76 percent in 2004 to 73.5 percent in the first quarter of 2012. For black households, the decline was more pronounced, going from a peak of 49.1 percent in 2004 to 43.1 percent in the first quarter of 2012. The homeownership rate for Hispanic households also had a noticeable decline, going from a peak of 49.7 percent in 2006 and 2007 to 46.3 percent in the first quarter of 2012. /7/
The homeowner vacancy rate--the proportion of housing inventory for homeowners that is vacant and for sale--dropped slightly to 2.2 percent in the first quarter of 2012, from a record high of 2.9 percent in 2008. But the vacancy rate may not fully capture the inventory of distressed and at-risk homes that have not yet completed the foreclosure process, but will add to the housing supply. /8/ By one estimate, nearly 900,000 excess vacant homes are either for sale, for rent, or being held off the market. /9/
FOOTNOTE 8 See generally,
FOOTNOTE 9 See Mark Zandi, Moody's Analytics, "To Shore Up the Recovery,
First-time homebuyers have experienced lower-priced housing. According to the 2011
For 2011, NAR reported that existing home sales were up by 1.7 percent from 2010. New home sales for 2011, as reported by the
HMDA data for 2010, the most recent year for which such data are available, indicated that in comparison with 2009, applications for conventional home purchase loans from black borrowers fell by 31 percent, and for Hispanic borrowers by 34 percent. Applications from white borrowers fell by 23 percent.
Denial rates for black and Hispanic applicants, however, decreased from 2008 to 2010. For black applicants, the denial rate dropped from 36.1 percent in 2008 to 32.3 percent in 2009 and to 30.9 percent in 2010, while the denial rate for Hispanics dropped from 31.1 percent in 2008 to 25.6 percent in 2009 and to 22.9 percent in 2010. /12/
FOOTNOTE 12 See Board of Governors of the Federal Reserve, "The 2009 HMDA Data: The Mortgage Market in a Time of Low Interest Rates and Economic Distress," Federal Reserve Bulletin, available at http://www.federalreserve.gov/pubs/bulletin/2010/pdf/2009_HMDA_final.pdf and "The Mortgage Market in 2010: Highlights from the Data Reported under the Home Mortgage Disclosure Act," available at http://www.federalreserve.gov/pubs/bulletin/2011/pdf/2010_HMDA_final.pdf. END FOOTNOTE
Low housing prices hurt existing homeowners as the number of foreclosures and underwater mortgages--where a homeowner owes more than the value of the home--remained at elevated levels. Although the number of homes with foreclosure filings fell 34 percent relative to 2010, 1.9 million homes were foreclosed on in 2011. /13/ Foreclosure figures likely would have been higher in 2011 had it not been for processing slowdowns as a result of concerns about foreclosure practices and documentation. Some housing analysts project higher foreclosure rates in 2012, with a downward trend beginning in 2013. As of the fourth quarter of 2011, the share of underwater mortgages was at a near-record high of 22.8 percent, and roughly 5.0 percent of mortgaged homes had less than 5 percent equity. /14/ The concentration of underwater borrowers is even higher for non-Enterprise loans. In a
FOOTNOTE 13 See "2011 Year-End Foreclosure Report: Foreclosures on the Retreat (
FOOTNOTE 14 See CoreLogic "Q42011 Negative Equity Report," available at: http://www.corelogic.com/about-us/researchtrends/asset_upload_file780_1.pdf. END FOOTNOTE
FOOTNOTE 15 See http://www.fhfa.gov/webfiles/23056/PrincipalForgivenessltr12312.pdf. END FOOTNOTE
According to the
FOOTNOTE 16 See http://www.mbaa.org/ResearchandForecasts/ForecastsandCommentary. END FOOTNOTE
One result of the mortgage crisis is that the mortgage market now has stricter and less flexible lending standards. According to the
FHFA has considered the above data in assessing national housing needs as required by the Safety and Soundness Act. FHFA has concluded that it is not necessary to adjust the benchmark levels based specifically on this factor.
2. Economic, Housing and Demographic Conditions
The current turmoil in the housing and mortgage markets affects the ability of the Enterprises to meet the housing goals. The market conditions include: (1) Tightened credit underwriting practices; (2) the financial condition of private mortgage insurance (MI) companies; (3) the increased role of FHA in the marketplace; (4) high unemployment; (5) the state of the refinance market; and (6) shifting demographic conditions. These developments have contributed to a decrease in the overall share of single-family loans likely to qualify for Enterprise housing goals credit.
Tightened credit underwriting practices. Continuing rigorous credit underwriting standards in the mortgage market have resulted in fewer goal-qualifying loans and a lower percentage of goal-qualifying loans in the market. Underwriting standards in the mortgage market generally, and at
FOOTNOTE 18 See generally
Financial condition of private MI companies. Substantial ratings downgrades for MI companies followed the recent financial crisis. Most MI companies continue to face difficulties in returning to profitability. One consequence of these difficulties is more stringent MI underwriting standards, which result in fewer goal-qualifying loans and a lower percentage of goal-qualifying loans in the overall market. These standards include restrictions on borrowers having multiple risk factors such as a high loan-to-value (LTV) ratio, a lower credit score, and limited documentation. These developments limit the ability of mortgage insurers to write new business and may reduce the overall mortgage lending volume, particularly for higher-LTV mortgages, which are more likely to count for purposes of the housing goals. Post-conservatorship loan-level pricing adjustments by the Enterprises may also have a similar impact.
Increased role of FHA in the marketplace. The composition of the affordable conventional mortgage market is also influenced by FHA's market share. FHA loans generally are pooled into mortgage-backed securities (MBS) guaranteed by the
High unemployment. In addition to being an indicator of the health of the economy in general, labor market conditions affect the housing market more directly because buying a house is considered a large investment and a long-term commitment that requires stable employment. Nonfarm payroll employment increased by 115,000 in
FOOTNOTE 21 See NeighborWorks, "National Foreclosure Mitigation Counseling Program--Congressional Update--Activity Through
State of the refinance market. The size of the refinance mortgage market has an impact on the share of affordable refinance mortgages. Historically, refinance mortgage volume increases when the refinancing of mortgages is motivated by low interest rates, i.e., "rate and term refinances," and this increased volume is dominated by higher-income borrowers. As a result, in periods of low interest rates, the share of lower-income borrowers will decrease. Likewise, refinancings that occurred when interest rates were high tended to have a higher proportion of lower-income homeowners who were consolidating their debts or who were drawing equity out of their homes for other uses. While there are fewer mortgage refinancings for both lower-income and higher-income borrowers during high interest rate periods, the decrease is larger for higher-income borrowers.
While mortgage interest rates are expected to rise later in 2012 to 2014, there is reason to expect that the refinance patterns observed in the past may not occur. In the current economic environment, lower-income homeowners tend to have less equity--or negative equity--in their homes because the prices of lower-valued homes have fallen more than the prices of higher-valued homes. /22/ At the same time, lenders have tightened underwriting requirements, requiring higher down payments and higher credit scores. As a result, fewer lower-income homeowners may be able to refinance in 2012 and 2013. In addition, programs established in the wake of the financial crisis have affected refinancings. The Home Affordable Refinance Program (HARP), which became effective in
FOOTNOTE 22 See
Shifting demographic conditions. In establishing the 2012-2014 housing goals, FHFA analyzed demographic characteristics and trends for their possible effect on housing demand. In the long term, housing demand is likely to increase as a result of population growth, immigration, and formation of new households by the generation born between 1981 and 2000. /23/ However, the impact of long-term demographic conditions on short-term goals performance would be minimal.
FOOTNOTE 23 See generally
Homeownership rates for owner-occupied units vary depending on demographic characteristics of households such as income, age, race, and type of household, as well as on the location and type of home. Generally, families are more likely than individuals to be homeowners, and homeowners generally tend to have higher incomes than renters.
The financial crisis has had broad effects across demographic categories. Homeownership rates peaked in the first quarter of 2005 for families with incomes greater than or equal to the median family income and families with incomes below the median family income, and then started falling. /24/ More specifically, the homeownership rate for families with incomes above the area median family income dropped from 84.5 percent in the first quarter of 2005 to 80.3 percent in the first quarter of 2012. The homeownership rate for families with incomes below the area median family income dropped from 53 percent to 50.4 percent over the corresponding period.
As discussed previously, the financial crisis took a significant toll on minority homeownership, with their homeownership rates trending sharply downwards. Recent times have also seen depressed immigration rates and headship rates among young as well as middle-aged households. /25/ Moody's Analytics has observed that with many young people living with their parents for longer periods, there is pent-up new household formation that should occur in the next year or two. /26/ Meanwhile, aging baby boomers have been projected to increase the number of households over the age of 65 by 35 percent from 2010 to 2020. /27/
FOOTNOTE 25 See
FOOTNOTE 26 See Mark Zandi, Moody's Analytics, "To Shore Up the Recovery,
FOOTNOTE 27 See
FHFA has considered the above data in assessing economic, housing and demographic conditions as required by the Safety and Soundness Act. FHFA has concluded that it is not necessary to adjust the benchmark levels based specifically on this factor.
3. The Performance and Effort of the Enterprises Toward Achieving the Housing Goals in Previous Years
Section 1332(a) of the Safety and Soundness Act, as amended by section 1128(b) of HERA, requires FHFA to establish three single-family owner-occupied home purchase mortgage goals for the Enterprises: A goal for low-income families; a goal for families that reside in low-income areas; and a goal for very low-income families. Section 1332(a) also requires FHFA to establish a goal for single-family refinancing mortgages for low-income families. The following section discusses performance on these single-family goals in 2010 and, to provide perspective, reviews what performance would have been on these four single-family goals had they been in effect from 2006 through 2009.
The figures shown in Tables 1-4 for 2010 are official performance results as determined by FHFA, based on loan-level information submitted by the Enterprises. The housing goals in the Safety and Soundness Act, as amended, apply to the Enterprises' acquisitions of "conventional, conforming, single-family, purchase money mortgages financing owner-occupied housing" for the targeted groups. The figures exclude units financed by Enterprise purchases of private label securities (PLS), since such units were not counted toward the goals in 2010.
Low-Income Families Housing Goal. The low-income families home purchase goal applies to mortgages made to "low-income families," defined as families with incomes no greater than 80 percent of area median income (AMI). /28/ As indicated in Table 1,
FOOTNOTE 28 See 12 U.S.C. 4502(14). END FOOTNOTE
Very Low-Income Families Housing Goal. The very low-income families home purchase goal applies to mortgages made to "very low-income families," defined as families with incomes no greater than 50 percent of AMI. In essence, this operates as a subgoal of the low-income families housing goal, which applies to families with incomes no greater than 80 percent of AMI.
As indicated in Table 2,
Table 1--GSE Past Performance on the Low-Income Home Purchase Goal, 2006-10 [Goal benchmark for 2010 was 27 percent] Enterprise Year Type of home Fannie Mae Freddie Mac Market share purchase (HP) (HMDA) mortgages 2010 Low-Income HP 120,430 82,443 Mortgages Total HP 479,200 307,555 Mortgages Low-Inc. % of 25.1% 26.8% 27.2% HP Mortgages 2009 Low-Income HP 148,423 105,719 Mortgages Total HP 582,673 415,897 Mortgages Low-Inc. % of 25.5% 25.4% 29.6% HP Mortgages 2008 Low-Income HP 226,290 158,896 Mortgages Total HP 977,852 655,156 Mortgages Low-Inc. % of 23.1% 24.3% 25.5% HP Mortgages 2007 Low-Income HP 383,129 284,434 Mortgages Total HP 1,471,242 1,008,064 Mortgages Low-Inc. % of 26.0% 24.6% 26.1% HP Mortgages 2006 Low-Income HP 359,609 197,900 Mortgages Total HP 1,295,956 895,049 Mortgages Low-Inc. % of 27.7% 22.1% 24.2% HP Mortgages Source: Official performance as determined by FHFA for 2010; performance if the goal had been in effect, as calculated by FHFA, for 2006-09. "Low-income" refers to borrowers with incomes no greater than 80 percent of Area Median Income (AMI). Notes:
Freddie Mac'sofficial performance for 2010 was initally reported as 27.8 percent, but it has since been revised as shown above. To determine whether an Enterprise's performance exceeded or fell short of the goal, FHFA compares official performance figures with the benchmark level and the low-income share of conventional conforming home purchase mortgages originated in 2010, based on FHFA analysis of data submitted by primary mortgage market lenders to the Federal Financial Institutions Examination Council(FFIEC) in accordance with the Home Mortgage Disclosure Act (HMDA). The low-income shares of the primary market are shown in the last column in the table.
Table 2--GSE Past Performance on the Very Low-Income Home Purchase Goal, 2006-10 [Goal benchmark for 2010 was 8 percent] Enterprise Year Type of home Fannie Mae Freddie Mac Market share purchase (HP) (HMDA) mortgages 2010 Low-Income HP 34,673 24,276 Mortgages Total HP 479,200 307,555 Mortgages Low-Inc. % of 7.2% 7.9% 8.1% HP Mortgages 2009 Low-Income HP 42,571 29,870 Mortgages Total HP 582,673 415,897 Mortgages Low-Inc. % of 7.3% 7.2% 8.8% HP Mortgages 2008 Low-Income HP 54,263 40,009 Mortgages Total HP 977,852 655,156 Mortgages Low-Inc. % of 5.5% 6.1% 6.5% HP Mortgages 2007 Low-Income HP 93,543 60,549 Mortgages Total HP 1,471,242 1,008,064 Mortgages Low-Inc. % of 6.4% 6.0% 6.2% HP Mortgages 2006 Low-Income HP 100,148 47,008 Mortgages Total HP 1,295,986 895,049 Mortgages Low-Inc. % of 7.7% 5.3% 5.9% HP Mortgages Source: Official performance as determined by FHFA for 2010; performance if the goal had been in effect, as calculated by FHFA, for 2006-09. "Very Low-income" refers to borrowers with incomes no greater than 50 percent of Area Median Income (AMI). Notes:
Freddie Mac'sofficial performance for 2010 was initally reported as 8.4 percent, but it has since been revised as shown above. To determine whether an Enterprise's performance exceeded or fell short of the goal, FHFA compares official performance figures with the benchmark level and the very low-income share of conventional conforming home purchase mortgages originated in 2010, based on FHFA analysis of data submitted by primary mortgage market lenders to the Federal Financial Institutions Examination Council(FFIEC) in accordance with the Home Mortgage Disclosure Act (HMDA). The very low-income shares of the primary market are shown in the last column in the table.
Low-Income Areas Goal and Subgoal. Three categories of mortgages qualify for the low-income areas housing goal:
(1) Home purchase mortgages for families in low-income census tracts, defined as tracts with median family income no greater than 80 percent of AMI;
(2) Home purchase mortgages for families with incomes no greater than 100 percent of AMI who reside in minority census tracts, defined as tracts with minority population of at least 30 percent and a median family income less than 100 percent of AMI; and
(3) Home purchase mortgages for families with incomes no greater than 100 percent of AMI who reside in Federally-declared disaster areas (regardless of the minority share of the population in the tract or the ratio of tract median family income to AMI).
FHFA established an overall goal for this category of home purchase mortgages of 24 percent for 2010-2011. As indicated in Table 3,
The 2010-2011 final rule also established a subgoal for the low-income and high-minority census tracts components of the goal. For 2010 and 2011, FHFA set the benchmark level for this subgoal at 13 percent. /29/ As indicated in Table 3,
FOOTNOTE 29 Affordability levels in low-income and high-minority areas, but not for disaster areas, can be adequately modeled using econometric time series forecast models. END FOOTNOTE
Refinancing Housing Goal. The refinancing housing goal is targeted to low-income families, i.e., families with incomes no greater than 80 percent of AMI, and applies to mortgages that are given to pay off or prepay an existing loan secured by the same property. Thus, the goal does not apply to home equity or home purchase loans.
Table 3--GSE Past Performance on the Low-Income Areas Home Purchase Goal and Subgoal, 2008-10 [Goal benchmark for 2010 was 24 percent; subgoal benchmark was 13 percent] Year Type of home purchase (HP) Enterprise Market share mortgages (HDMA) Fannie Mae Freddie Mac 2010 Low-Income Tract HP 44,467 24,037 Mortgages High-Minority Tract HP 14,814 8,052 Mortgages Subgoal Qualifying 59,281 32,089 Mortgages Total HP Mortgages 479,201 307,555 Subgoal Qualifying % of 12.4% 10.4% 12.1% Mortgages Disaster Area HP Mortgages 55,972 38,898 Goal-Qualifying Mortgages 115,253 70,876 Goal Qualifying % of 24.1% 23.0% 24.0% Mortgages 2009 Low-Income Tract HP 59,150 37,138 Mortgages High-Minority Tract HP 18,349 11,259 Mortgages Subgoal Qualifying 77,499 48,397 Mortgages Total HP Mortgages 582,673 415,897 Subgoal Qualifying % of 13.3% 11.6% 13.2% Mortgages Disaster Area HP Mortgages 79,255 55,565 Goal-Qualifying Mortgages 156,754 103,962 Goal Qualifying % of 26.9% 25.0% 28.1% Mortgages 2008 Low-Income Tract HP 118,875 80,288 Mortgages High-Minority Tract HP 29,245 19,160 Mortgages Subgoal Qualifying 148,120 99,448 Mortgages Total HP Mortgages 977,852 655,156 Subgoal Qualifying % of 15.1% 15.2% 14.3% Mortgages Disaster Area HP Mortgages 100,822 67,776 Goal-Qualifying Mortgages 248,942 167,224 Goal Qualifying % of 25.5% 25.5% 25.5% Mortgages Source: Official performance as determined by FHFA for 2010; performance if the goal had been in effect, as calculated by FHFA, for 2008-2009. See definition of "Low-income Area" in text. Notes:
Freddie Mac'sofficial performance for 2010 was initially reported as 10.8 percent on the subgoal and as 23.8 percent on the goal. Its official performance has since been revised as shown above. To determine whether an Enterprise's performance exceeded or fell short of the 2010 goal and subgoal, FHFA compares official performance figures with the benchmark levels and the corresponding shares of conventional conforming home purchase mortgages originated in 2010, based on FHFA analysis of data submitted by primary mortgage market lenders to the Federal Financial Institutions Examination Council(FFIEC) in accordance with the Home Mortgage Disclosure Act (HMDA). The subgoal and goal-qualifying shares of the primary market are shown in the last column of the table.
Qualifying permanent modifications of loans for low-income families under the Administration's Home Affordable Modification Program (HAMP) are counted toward the refinancing housing goal. The impact of such modifications on goal performance is shown in Table 4.
Table 4 shows the Enterprises' performance on this goal for 2010, as well as what performance would have been if the goal had been in effect for the preceding four years. Performance shown for all years excludes units financed by Enterprise purchases of PLS, because such units were not counted toward the goals in 2010.
As indicated in Table 4,
4. The Ability of the Enterprises To Lead the Industry in Making Mortgage Credit Available
Leading the industry in making mortgage credit available includes making mortgage credit available to primary market borrowers at differing income levels with varying credit profiles living in various markets. Leadership also relates to the Enterprises' loss mitigation efforts, implementation of loan modification and refinance programs and support for state and local housing finance agencies. The Enterprises, along with FHA and VA, now lead the market in making mortgage credit available. In 2011, the Enterprises remained the largest issuers of MBS, guaranteeing 72 percent of single-family MBS. This situation is widely viewed as undesirable for the long term. The Enterprises' losses have depleted their capital and resulted in their being sustained only by infusions of capital from the U.S. Treasury under the Senior Preferred Stock Purchase Agreements. FHFA as conservator exercises a statutory mandate to conserve and preserve the Enterprises' assets, and to place the Enterprises in a sound and stable condition. Consistent with those responsibilities, FHFA has announced a number of steps to reduce the role of the Enterprises in the mortgage market. FHFA has taken into account all of the foregoing considerations in assessing the Enterprises' ability to lead the industry.
Table 4--GSE Past Performance on the Low-Income Refinance Goal, 2006-10 [Goal benchmark for 2010 was 21 percent] Enterprise Year Type of Fannie Mae Freddie Mac Market share refinance (HMDA) mortgages 2010 Low-Income 373,105 286,741 Refinance Mortgages Total 1,934,270 1,378,578 Refinance Mortgages Low-Inc. % of 19.3% 20.8% 20.2% Refinance Mortgages Low-Income 44,343 25,244 Refinance Loan Modifications Total 63,428 37,411 Refinance Loan Modifications Low-Income % 69.9% 67.5% NA of Refinance Loan Modifications Low-Income 417,448 311,985 Refinance Total Refinance 1,997,698 1,415,989 Total Low-Inc. % of 20.9% 22.0% 20.2% Refinance Total 2009 Low-Income 479,631 326,912 Refinance Mortgages Total 2,415,169 1,708,676 Refinance Mortgages Low-Inc. % of 19.9% 19.1% 20.9% Refinance Mortgages Low-Income 114,390 63,708 Refinance Loan Modifications Total 168,437 94,062 Refinance Loan Modifications Low-Inc. % of 67.9% 67.7% NA Refinance Loan Modifications Low-Income 594,021 390,620 Refinance Total Refinance 2,583,606 1,802,738 Total Low-Inc. % of 23.0% 21.7% NA Refinance Total 2008 Low-Income 335,864 215,016 Refinance Mortgages Total 1,455,287 927,816 Refinance Mortgages Low-Inc. % of 23.1% 23.2% 23.4% Refinance Mortgages 2007 Low-Income 351,739 252,889 Refinance Mortgages Total 1,421,342 1,005,519 Refinance Mortgages Low-Inc. % of 24.7% 25.2% 24.3% Refinance Mortgages 2006 Low-Income 301,995 217,882 Refinance Mortgages Total 1,133,684 838,104 Refinance Mortgages Low-Inc. % of 26.6% 26.0% 24.8% Refinance Mortgages Source: Official performance as determined by FHFA for 2010; performance if the goal had been in effect, as calculated by FHFA, for 2006-09. "Low-income" refers to borrowers with incomes no greater than 80 percent of Area Median Income (AMI). Notes: To determine whether an Enterprise's performance exceeded or fell short of the 2010 goal, FHFA compares official performance figures with the benchmark level and the low-income share of conventional conforming refinance mortgages originated in 2010, based on FHFA analysis of data submitted by primary mortgage market lenders to the
Federal Financial Institutions Examination Council(FFIEC) in accordance with the Home Mortgage Disclosure Act (HMDA). The low-income shares of refinances in the primary market are shown in the last column in the table. There is no market data on loan modifications.
FHFA has considered the above data in assessing the ability of the Enterprises to lead the industry in making mortgage credit available as required by the Safety and Soundness Act. FHFA has concluded that it is not necessary to adjust the benchmark levels based specifically on this factor.
5. Other Reliable Mortgage Data
HMDA data reported by loan originators is the primary source of reliable mortgage data for establishing the single-family housing goals. In setting the housing goal benchmark levels, FHFA evaluates the Enterprises' performance with respect to leading or lagging the housing market under specific goals and compares HMDA data with mortgage purchase data provided by the Enterprises.
FHFA also uses other reliable data sources including:
In the development of economic forecasts, FHFA uses data and information from
6. Market Size
Expectations for the 2012 and 2013 single-family mortgage market are for zero or slow growth. Quantifiable factors influencing FHFA's outlook for the mortgage market include general growth in the economy, employment, inflation, and the interest rate environment. Industry observers expect subprime mortgage market activity to remain minimal through 2013. The FHA-insured mortgage market share is expected by industry observers to continue to be a major factor in the affordability levels in the conventional market as FHA loans will continue to be an attractive option for low-income homebuyers. /30/ The effects of unemployment, FHA market share, and refinancing have been discussed previously (see Section 2). The effects of interest rates, house prices, the overall housing market, manufactured housing, and the market outlook are discussed below.
FOOTNOTE 30 FHFA monitors the economic, housing and mortgage market forecasts of 12 industry and government entities. These entities are referred to as "industry observers." For more information, and specifically which economic indicators each entity forecasts, see "Market Estimation Model for the 2012-2014 Enterprise Single-Family Housing Goals"ublished at FHFA's Web site, www.fhfa.gov. END FOOTNOTE
Market Outlook. Industry observers' economic and mortgage market forecasts are presented in Tables 5 and 6. On average, industry forecasters project the economy to continue to grow in 2012 and 2013, with real Gross Domestic Product (GDP) growing at rates of 2.3 and 2.7 percent, respectively. These industry observers also expect the unemployment rate to remain below 9.0 percent in 2012, and falling to 7.8 percent in the fourth quarter of 2013.
BILLING CODE 8070-01-P
See Illustration in Original Document.
See Illustration in Original Document.
BILLING CODE 8070-01-C
Interest Rates. Affordability in the mortgage market relies in part on the interest rate environment. Mortgage interest rates are impacted by many factors. Interest rates on longer term financial instruments such as mortgages typically follow the fluctuations of the 10-Year Treasury Note yield, with approximately an 180 basis point spread reflecting the differences in liquidity and credit risk. With uncertainty in the financial markets of the
FOOTNOTE 31 Federal Open Market Committee,
House Prices. Trends in house prices influence the housing and mortgage markets. In periods of house price appreciation, home sales and mortgage originations increase as the expected return on investment rises. In periods of price depreciation or price uncertainty, home sales and mortgage originations decrease as risk-averse homebuyers are reluctant to enter the market. House prices generally fell during 2009 through 2011, and are expected to fall slightly in 2012 before rebounding in 2013. Industry forecasts show a decrease in the S&P/Case Shiller Home Price Index of -0.5 percent in 2012 and an increase of 0.8 percent in 2013 (see Table 6).
Housing Market. An active housing market is generally good for the affordable home market. When there are more homes for sale, potential home buyers have more options, prices tend to be more competitive and the search costs to find affordable housing decrease. Historical volumes for sales of both new and existing houses are shown in Table 6, along with forecasts for 2012-2013. Total home sales reached a 10-year annual low in 2010 at 4.5 million units. Home sales increased slightly in 2011 to 4.6 million units and industry observers expect that home sales will increase to 4.9 million units in 2012 and to 5.1 million units in 2013--well below 2004-2006 levels.
During 2009 and early 2010, special homebuyers tax credits were available for first-time and repeat homebuyers. Mortgages to first-time homebuyers tend to be more likely to qualify for housing goals than those for repeat homebuyers, who tend to be older and have higher incomes. Many first-time homebuyers whose mortgages might otherwise have been available to receive goal-qualifying loans for home purchases in 2012-2014, instead bought their homes in 2009 or 2010 to take advantage of the first-time homebuyers tax credit.
Manufactured Housing Loans. Between 2008 and 2010, 58 percent of manufactured housing loans were higher priced, according to HMDA data. Because chattel-financed loans do not count towards achievement of the housing goals, it was necessary to adjust the HMDA figures with respect to market estimates to account for this part of the manufactured housing market. Accordingly, FHFA down-weighted the average 2008 to 2010 manufactured housing contribution to the goals market estimates by 80 percent for the home purchase mortgage goals and 50 percent for the refinance mortgage goal. This resulted in the market estimate for the low-income home purchase housing goal being reduced by 1.4 percent, the very low-income home purchase housing goal by 0.5 percent, the low-income areas home purchase housing goal by 0.6 percent, and the low-income borrower refinance housing goal by 0.2 percent. The projected market estimates in Table 5 reflect these adjustments.
Housing Goal Outlook. FHFA's estimates of the market performance for the two single-family owner-occupied home purchase housing goals and one subgoal, and the refinancing mortgage housing goal, are provided in Table 5. For 2012 and 2013, FHFA estimates that the low-income borrower shares of the home purchase mortgage market will be 22.4 percent and 19.6 percent, respectively. FHFA estimates that the very low-income borrower share of the home purchase mortgage market will be 7.5 percent for 2012 and 7.3 percent for 2013. FHFA estimates that the share of goal-qualifying mortgages in low-income areas in the home purchase mortgage market, excluding designated disaster areas, will be 11.9 percent in 2012 and 11.8 percent in 2013.
The refinance share of the market, as measured by the MBA, averaged 68 percent in 2011. With interest rates projected to rise during 2012-2013, industry observers expect the refinance share of total originations to decrease. Generally speaking, decreasing refinance share leads to a higher percentage of refinance originations made up of lower-income borrowers. Accordingly, with a projected refinance share of 62 percent in 2012 and 48 percent in 2013 (down from 68 percent in 2011), FHFA's market model estimates that 21.2 percent of refinance mortgages will be made to low-income borrowers in 2012 and 24.1 percent in 2013. These estimates are reflective of historical lending patterns and trends. However, as evidenced by the Federal Reserve Bank of
FOOTNOTE 32 Federal Reserve Bank of
To arrive at the market estimates, FHFA used an econometric state space methodology to extend the trends of the market performance for each goal, based on a monthly time series database provided by the
FHFA used all relevant information when determining the benchmark levels for the 2012 and 2013 housing goals. While the tightening of underwriting standards is not included in the market estimates calculation, it was considered in the determination of the benchmark levels. FHFA attempts to use the most current data possible when estimating market size, including information from FHFA's MIRS and combined
FOOTNOTE 33 See http://www.fhfa.gov/Default.aspx?Page=72. END FOOTNOTE
7. Need To Maintain the Sound Financial Condition of the Enterprises
The financial performance of both Enterprises is dominated by credit-related expenses and losses stemming principally from purchases and guarantees of mortgages originated in 2006 and 2007 and from purchases of PLS. As discussed above, FHFA's duties as conservator require the conservation and preservation of the Enterprises' assets. While reliance on the Treasury's backing will continue until legislation produces a final resolution to the Enterprises' future, FHFA is monitoring the activities of the Enterprises to: (a) Limit their risk exposure by avoiding new lines of business; (b) ensure profitability in the new book of business without deterring market participation or hindering market recovery; and (c) minimize losses on the mortgages already on their books. Given the importance of the Enterprises to the housing market, any goal-setting must be closely linked to putting the Enterprises in sound and solvent condition.
B. Single-Family Housing Goal Benchmark Levels
Based on the factors described above, proposed
Housing goal for low-income families. The proposed benchmark level of the annual goal for each Enterprise's purchases of purchase money mortgages on owner-occupied single-family housing for low-income families is 20 percent of the total number of such mortgages purchased by that Enterprise.
Housing goal for very low-income families. The proposed benchmark level of the annual goal for each Enterprise's purchases of purchase money mortgages on owner-occupied single-family housing for very low-income families is 7 percent of the total number of such mortgages purchased by that Enterprise.
Housing goal and subgoal for families in low-income areas. The benchmark level of the annual goal for each Enterprise's purchases of purchase money mortgages on owner-occupied single-family housing for families in low-income areas is set annually by notice from FHFA. The benchmark level is based on the benchmark level for the low-income areas subgoal, plus an adjustment factor that reflects the incremental percentage share that mortgages for low- and moderate-income families in designated disaster areas had in the most recent year for which data is available. The proposed benchmark level of the annual subgoal for each Enterprise's purchases of purchase money mortgages on owner-occupied single-family housing for families in low-income census tracts and for low- and moderate-income families in minority census tracts is 11 percent of the total number of such mortgages purchased by that Enterprise.
Housing goal for refinancing mortgages. As discussed in the Economic, Housing and Demographic Conditions Section, the historic secular patterns in the refinance market show that when interest rates increase, more higher income homeowners drop out of the refinance market relative to lower income homeowners. This is attributed to the differing motivations for refinancing between the groups, where lower income borrowers are more likely to be seeking a cash-out refinance, which is less dependent on interest rates, than a rate-and-term refinance. The market model, which is based on historical patterns in the refinance market, projects that the low-income borrower share of the refinance market will increase from 21 percent in 2012 to 24 percent in 2013 (see Table 5). FHFA is taking into consideration the current economic environment, including the tightening of underwriting standards and the decrease in equity in the housing stock, in the setting of the refinance goal benchmark. Therefore, the proposed benchmark level of the annual goal for each Enterprise's purchases of refinancing mortgages on owner-occupied single-family housing for low-income families is 21 percent of the total number of such mortgages purchased by that Enterprise, the low end of the projected range.
V. Multifamily Housing Goals
A. Analysis of Factors for Multifamily Housing Goals
Section 1333(a)(4) of the Safety and Soundness Act, as amended by HERA, requires FHFA to consider the following six factors in setting multifamily special affordable housing goals:
(1) National multifamily mortgage credit needs and the ability of the Enterprise to provide additional liquidity and stability for the multifamily mortgage market;
(2) The performance and effort of the Enterprise in making mortgage credit available for multifamily housing in previous years;
(3) The size of the multifamily mortgage market for housing affordable to low-income and very low-income families, including the size of the multifamily markets for housing of a smaller or limited size;
(4) The ability of the Enterprise to lead the market in making multifamily mortgage credit available, especially for multifamily housing affordable to low-income and very low-income families;
(5) The availability of public subsidies; and
(6) The need to maintain the sound financial condition of the Enterprise.
FHFA's analysis of each of the six factors is set forth below.
1. National Multifamily Mortgage Credit Needs
In 2011, traditional participants in multifamily mortgage financing continued to increase their presence. Life insurance companies, and to a limited extent, commercial mortgage-backed securities (CMBS) issuers, increased their lending volumes in 2011 compared to 2010. Nevertheless, the Enterprises remain by far the largest sources of multifamily capital, comprising over 60 percent of originations in dollar terms. /34/
FOOTNOTE 34 "GSEs Capture More Than 60 Percent of Market in 2011", Multifamily Executive,
The difficulties encountered by CMBS issuers in 2011 will likely continue into 2012 as rating agencies remain hesitant to grade commercial mortgages bundled into CMBS. FHFA expects that in 2012 the Enterprises will have a lower market share than what they had in 2011, a little less than 60 percent in terms of dollars. /35/ As investors become more confident in the stability of the multifamily mortgage market, the CMBS market should slowly make a return, and the Enterprises' market share should decline over the 2012-2014 period, although the overall multifamily mortgage market should slowly grow as the economy recovers. In arriving at this conclusion, FHFA considered, among other factors, vacancy rates, origination rates, and property prices.
FOOTNOTE 35 "GSEs Capture More Than 60 Percent of Market in 2011", Multifamily Executive,
Vacancy Rates and Origination Rates. Falling vacancy rates are usually associated with increased rents and investor interest in multifamily properties. According to the
FOOTNOTE 36 "Axiometrics' Research Indicates Strongest Monthly Sequential Rent and Occupancy Growth in Last 4 Years",
Property Prices. As of the end of
2. The Performance and Effort of the Enterprises in Making Mortgage Credit Available for
Multifamily Low-Income Housing Goal. The multifamily low-income housing goal includes units affordable to low-income families (those with incomes no greater than 80 percent of AMI). Both Enterprises played major roles in funding multifamily units for low-income families between 2006 and 2009, as shown in Table 7.
In the final rule establishing the housing goals for 2010-2011, FHFA set the minimum goal for
See Illustration in Original Document.
Multifamily Very Low-Income Subgoal. The multifamily very low-income housing subgoal includes units affordable to very low-income families (those with incomes no greater than 50 percent of AMI). Enterprise financing of rental units for very low-income families over the 2006-2010 period is reported in Table 8. On average, from 2006 to 2009,
See Illustration in Original Document.
Financing of Low-Income Units in
FOOTNOTE 38 12 U.S.C. 4563(a)(3). END FOOTNOTE
Small multifamily housing plays an important role as a source of affordable rental housing. According to the 2007
See Illustration in Original Document.
Both Enterprises have decreased the volume of their purchases of small multifamily mortgages in the past few years due to a lack of CMBS issuances available for sale and a decline in the overall volume of small multifamily loans available for purchase.
3. Multifamily Mortgage Market Size
With demand for multifamily housing increasing, the multifamily mortgage market should continue to grow. The number of multifamily units completed in 2011 was 130,000, according to the
FOOTNOTE 39 "New Privately-Owned Housing Units Completed",
As in prior years, multifamily housing goals are set separately for each Enterprise, and are measured in units rather than dollar volume. Several factors support continuing to establish different goal levels for each Enterprise. First, loan maturities will be increasing for both
4. Ability of the Enterprise To Lead the Market in Making Multifamily Mortgage Credit Available
The multifamily housing market began to improve in many geographic areas in 2011 (e.g., decreasing vacancy rates, increasing rents and rising property values). As discussed above, FHFA expects this improvement to continue through 2014.
By 2011, however, the Enterprises' multifamily mortgage market share declined to a little over 60 percent as traditional competitors such as life insurance companies, conduits and banks re-entered multifamily lending. The decline in Enterprise multifamily mortgage market share should continue through 2012-2014 as these traditional competitors increase their presence in the multifamily mortgage market.
5. Availability of Public Subsidies
Public subsidies for multifamily housing have been affected by the mortgage credit crisis. The value of low-income housing tax credits (LIHTCs), an important source of equity for new low-income housing, fell in 2009 but has recovered to a point where the LIHTC market is substantially healthier. Total equity raised through LIHTCs is forecasted to average
FOOTNOTE 40 "2012 Q & A on the Housing Credit Program",
FOOTNOTE 41 LIHTC Market Gets its Mojo Back", Tax Credit Advisor, housingonline.com,
6. Need To Maintain the Sound Financial Condition of the Enterprises
The financial condition of both Enterprises is discussed in more detail above. FHFA has considered the multifamily housing goals in light of the importance of the Enterprises to the housing market and in light of FHFA's duties as conservator to conserve and preserve the assets of the Enterprises. The proposed multifamily housing goal levels for 2012-2014 are aligned with safe and sound practices and market reality.
B. Multifamily Housing Goal Levels
The proposed rule would set different multifamily goals for each of the Enterprises, as was done in previous years. Reflecting a more robust multifamily market in the years 2012 through 2014, as well as an anticipated decline in market share of the Enterprises, the proposed rule would establish the multifamily special affordable housing goals and subgoals as follows:
Multifamily Low-Income Housing Goals. The proposed annual goal for
Multifamily Very Low-Income Housing Subgoals. The proposed annual subgoal for
The proposed low-income goal and very low-income subgoal for the 2012-2014 period reflect the unusually high volume and market share the Enterprises experienced in 2011. FHFA believes this level of market share will gradually decrease in 2012 and beyond. In 2011, multifamily units financed by
VI. Special Counting Requirements
A. Multifamily Subordinate Liens
Section 1282.16(b)(10) of the current housing goals regulation excludes both single-family and multifamily subordinate lien mortgages from counting towards the housing goals, although it does not prohibit the purchase of Charter-compliant subordinate lien mortgages. The Supplementary Information to the 2010-2011 housing goals final rule indicated that FHFA might solicit further public comment on whether multifamily subordinate lien mortgages should be counted for purposes of the housing goals. /42/ However, FHFA has determined that it will not solicit such comments at this time. The current housing goals regulation that excludes both single-family and multifamily subordinate lien mortgages from counting towards the housing goals will remain in effect during the period covered by this proposed rule.
FOOTNOTE 42 See 75 FR 55892, 55924 (
Multifamily subordinate liens are only available to borrowers who have an existing first lien mortgage from the Enterprises, therefore the property securing the first lien mortgage will have already been counted for housing goals purposes. Subordinate liens are available either to supplement the purchase proceeds in connection with the sale of an Enterprise funded property and assumption of the existing first lien mortgage by a buyer, or as an equity take out by an existing borrower who will either retain the proceeds or use them to fund property improvements. Equity take outs used for property improvements and upgrades may have the effect of repositioning a formerly affordable property so it can charge higher rents and be removed from the affordable stock. Because the purpose of the multifamily housing goals is to gauge the Enterprises' efforts to support the affordable housing needs of renters, FHFA has decided not to propose changes to the current housing goals regulation regarding counting of subordinate lien mortgages towards housing goals.
B. Multifamily Property Conversion
Section 1282.15(d) currently requires the Enterprises to use tenant income to determine the affordability of rental units where such information is available, and to use rent where income information is not available. Some commenters on the proposed 2010-2011 housing goals rule raised concerns that using current rental information could lead to counting a multifamily mortgage as "affordable" in cases where the property is expected to convert from affordable rents to market rate rents. FHFA indicated in the Supplementary Information to that rule that it expected to address this issue in a subsequent rulemaking. /43/
FOOTNOTE 43 See 75 FR 55926. END FOOTNOTE
For a variety of reasons, mortgages that result in the conversion of multifamily properties from affordable rents to market rate rents are not likely to receive housing goals credit. The Enterprise underwriting standards for multifamily properties use actual rents, as provided on the property rent roll at the time of underwriting, rather than post-conversion projected rents. This limits the likelihood that an Enterprise will purchase a multifamily mortgage where the financing depends on increases in the current rents. The Enterprises may still purchase such loans indirectly through purchases of CMBS. For example, in one well-publicized case in
FOOTNOTE 44 It is also worth noting that subsequent litigation resulted in restrictions on the owners' ability to convert to market rents. END FOOTNOTE
Because it is unlikely that an Enterprise would receive housing goals credit for a mortgage that finances the conversion of a multifamily property from affordable rents to market rate rents, FHFA is not proposing any change to the rules for determining affordability for multifamily mortgages. However, in view of public and congressional concerns in this area, FHFA requests comment on whether the housing goals regulation should be amended to address the possibility that a multifamily mortgage financing the conversion of a property from affordable rents to market rate rents could be treated as affordable under the Enterprise housing goals. In particular, FHFA requests comment on whether
VII. Paperwork Reduction Act
The proposed rule does not contain any information collection requirement that requires the approval of the
VIII. Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C.
The General Counsel of FHFA certifies that the proposed rule, if adopted as a final rule, is not likely to have a significant economic impact on a substantial number of small entities because the regulation is applicable only to the Enterprises, which are not small entities for purposes of the Regulatory Flexibility Act.
List of Subjects in 12 CFR Part 1282
Mortgages, Reporting and recordkeeping requirements.
Authority and Issuance
For the reasons stated in the Supplementary Information, under the authority of 12 U.S.C. 4511, 4513, and 4526, FHFA proposes to amend part 1282 of title 12 of the Code of Federal Regulations as follows:
PART 1282--ENTERPRISE HOUSING GOALS AND MISSION
1. The authority citation for part 1282 is amended to read as follows:
Authority: 12 U.S.C. 4501, 4502, 4511, 4513, 4526, 4561-4566.
* * * * *
(c) * * *
(2) The benchmark level, which for 2012, 2013 and 2014 shall be 20 percent of the total number of purchase money mortgages purchased by that Enterprise in each year that finance owner-occupied single-family properties.
(d) * * *
(2) The benchmark level, which for 2012, 2013 and 2014 shall be 7 percent of the total number of purchase money mortgages purchased by that Enterprise in each year that finance owner-occupied single-family properties.
* * * * *
(f) * * *
(2) The benchmark level, which for 2012, 2013 and 2014 shall be 11 percent of the total number of purchase money mortgages purchased by that Enterprise in each year that finance owner-occupied single-family properties.
(g) * * *
(2) The benchmark level, which for 2012, 2013 and 2014 shall be 21 percent of the total number of refinancing mortgages purchased by that Enterprise in each year that finance owner-occupied single-family properties.
* * * * *
(b) Multifamily low-income housing goal. --(1) For the year 2012, the goal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to low-income families shall be, for
(2) For the year 2013, the goal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to low-income families shall be, for
(3) For the year 2014, the goal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to low-income families shall be, for
(c) Multifamily very low-income housing subgoal. --(1) For the year 2012, the subgoal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to very low-income families shall be, for
(2) For the year 2013, the subgoal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to very low-income families shall be, for
(3) For the year 2014, the subgoal for each Enterprise's purchases of mortgages on multifamily residential housing affordable to very low-income families shall be, for
[FR Doc. 2012-14105 Filed 6-8-12;
BILLING CODE 8070-01-P
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