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: 

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)


NCST Rulemaking Comments:

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 (12/2/2020)

Notice of HUD Proposed Rulemaking Regarding FHA Single Family Loan Sale Program: NCST Comment (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)