NCST is pleased to share publications, comment letters, and letters in which one of our team members served as an author or as a signee. This is another way we serve as a voice for vacant properties and the mission-focused developers working to return these properties to productive use.
NCST Policy Letters:
Comment Letter: Comment to the Federal Housing Administration on CWCOT First Look (ML 2022-08) (6/3/22)
Joint Statement: Advocates Applaud FHFA Move to Require Mortgage Lenders to Obtain Applicants’ Language Preference (5/3/22)
Joint Letter: Feedback to the Federal Housing Administration on Mortgage Letter 2022-06 (4/25/22)
Joint Letter: Letter to FHFA Encouraging Leadership on Language Access (1/12/22)
Comment Letter: Comment to the Consumer Financial Protection Bureau on Section 1071 Small Business Lending Data Collection (1/6/22)
Joint Comment: Comment to FHFA on the Proposed Rule to Amend the Enterprise Regulatory Capital Framework – Prescribed Leverage Buffer Amount and Credit Risk Transfer (11/26)
Joint Comment: Comment to the Federal Housing Finance Agency on 2022-2024 Enterprise Housing Goals Advance Notice of Proposed Rulemaking (10/25)
Comment Letter: Comment to the Federal Housing Finance Agency on the Enterprise Equitable Housing Finance Plans Request for Input (10/25)
Joint Letter: The Underserved Mortgage Markets Coalition Appeal for Meaningful GSE Duty-to Serve Plans (10/21)
Joint Letter: Cross-Industry Sign on Letter Infrastructure (8/25)
NCST Comment Letter to Federal Housing Finance Agency: Request for Input on Fannie Mae and Freddie Mac Proposed 2022-2024 Duty to Serve Plans (7/16) Statement before FHFA Duty to Serve Listening Session (7/13)
Joint Letter: Office of Management and Budget RFI on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government (7/6)
NCST Statement: FHFA Listening Session on Closing the Gap to Sustainable Homeownership (6/29)
Statement for the Record: House Financial Service Committee Hearing on “Justice for All: Achieving Racial Equity through Fair Access to Housing and Financial Services” (3/17)
Joint Letter: Support for Legislation on Data Acquisition and Language Access in Mortgage Servicing (3/9)
NCST Comment Letter to Federal Housing Finance Agency: Request for Information on Appraisal-Related Policies, Practices, and Processes (2/26/2021)
NCST Comment Letter to Federal Reserve: Advanced Notice of Proposed Rulemaking on the Community Reinvestment Act (2/6/2021)
Joint Release: Advocates Applaud Senate Bill Fund to Help Millions of Families Keep Their Homes; Urge Inclusion in COVID Stimulus Bill (2/5/2021)
Joint Letter: Letter to President-Elect Biden on Foreclosure Prevention in the Stimulus (1/17/2021)
Joint Letter: Comment to the Veterans Administration on Partial Claim Proposal (1/8/2021)
Joint Letter: Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework (8/31)
Joint Letter: Letter to the Consumer Financial Protection Bureau Re: Language Access Roundtable Discussion (8/24)
Joint Letter: FHA & FHFA Forbearance Letter (6/24)
NCST Letter to the Federal Reserve: Expanding the Federal Reserve Main Street Lending Program to Nonprofits (6/22)
Joint Letter: Emergency Rental Assistance and Rental Market Stabilization Act (5/6)
Joint Request: Single Consumer-facing Portal on COVID Housing Relief (5/4)
Joint Letter: Housing Industry Coalition Letter in Support of Rental Assistance (5/4)
Joint Letter: Letter to Housing Regulators on Tenant Protections in CARES Act (5/1)
Joint Letter: Renewed Call for Credit and Debt Protections in COVID-19 Relief (5/1)
Joint Letter: Civil Rights, Consumer, Housing, and Real Estate Groups Urge U.S Treasury and Federal Regulators to Help Mortgage Servicers Maintain Liquidity (4/17)
Joint Letter: HUD Must Do Much More to Protect Older Reverse Mortgage Borrowers in the Coronavirus Epidemic (3/24/20)
NCST Letter to the OCC, FDIC, and Federal Reserve on “Joint Statement on CRA Consideration for Activities in Response to COVID-19” CRA Activities and Need to Halt Rulemaking (3/23/20)
Joint Letter: 63 Organizations Call for Credit and Debt Protections to Address Financial Distress from COVID-19 (3/23/20)
Joint Letter to Regulatory Agencies Requesting Extension of Public Comment Periods (3/20/20)
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NCST Rulemaking Comments:
Comment to the OCC, FDIC, and Federal Reserve on the 2022 Community Reinvestment Act Notice of Proposed Rulemaking: NCST and Homeownership Alliance Comment (8/5/2022)
Comment to the Federal Housing Finance Agency on 2022-2024 Enterprise Housing Goals Advance Notice of Proposed Rulemaking: Joint Comment Letter with Center for Responsible Lending and Americans for Financial Reform Education Fund (10/25/2021)
Enterprise Equitable Housing Finance Plans Request for Input: NCST Comment (10/24/2021)
Consumer Financial Protection Bureau RFI: Protections for Borrowers Affected by the COVID-19 Emergency Under RESPA: Joint Comment Letter with the Center for Responsible Lending (5/10/2021)
Consumer Financial Protection Bureau Request for Information: Equal Credit Opportunity Act and Regulation B: Joint Comment Letter with Americans for Financial Reform (12/1/2020)
Testimony before the Federal Housing Finance Agency By Kristin Siglin on Duty to Serve: NCST Comment (10/21/20)
Qualified Mortgage Definition under the Truth-in-Lending Act (Regulation Z): General QM Loan Definition: NCST Comment (9/8/2020)
RE: Seasoned QM Loan Definition: NCST Comment (9/3/2020)
RE: FHFA’s Enterprise Regulatory Capital Framework NPRM: NCST Comment (8/10/2020)
NCST opposes the proposed changes to the Community Reinvestment Act (CRA) regulations published in the January 9, 2020, Federal Register: NCST Comment (4/8/2020)
RE: Affirmatively Furthering Fair Housing Proposed Rule, Docket No. FR-6123-P-02: NCST Comment (3/12/2020)
Proposed Claims Without Conveyance of Title Program Enhancements Posted on Drafting
Table for Public Feedback: NCST Comment (3/6/2020)
Notice of White House Council on Eliminating Regulatory Barriers to Affordable Housing; Request for Information: NCST Comment (1/31/2020)
Testimony before the Federal Housing Finance Agency By Kristin Siglin on Duty to Serve: NCST Comment (12/2/2019)
Notice of HUD Proposed Rulemaking Regarding FHA Single Family Loan Sale Program: NCST Comment; NCST Blog Post (7/15/2019)
Proposed IRS Regulation on Qualified Opportunity Funds: NCST Comment (7/1/2019)
Review of HUD Housing Policy in Opportunity Zones: NCST Comment (6/17/2019)
Coalition Comment on Opportunity Zone Data: NCST Comment (5/31/2019)
Fannie Mae Duty to Serve Plan Modification RFI: NCST Comment (11/2/2018)
FHFA Strategic Plan 2018-2020: NCST Comment (10/27/2017)
FHFA Affordable Housing Goals 2018-2020: Coalition comment letter
Sign on organizations: Prosperity Now (formerly CFED) and National Consumer Law Center (9/5/2017)
HUD Regulatory Reform: NCST Comment (7/31/2017)
FHFA Duty to Serve – GSE Proposed Underserved Markets Plans: NCST Comment
Sign on organization: Center for Community Progress (7/10/2017)
FHFA Duty to Serve Rule: Coalition Comment
Sign on organizations: Prosperity Now (formerly CFED), Center for Community Progress, and Housing Partnership Network (3/17/2016)