Springboard CDFI and the Nationwide Mortgage Collaborative (NMC) respectfully and submits the following brief comments and ideas for consideration when crafting HUD’s 2018-2022 Strategic Plan. These comments are not at all exhaustive, but rather represent the top strategies around housing counseling and homeownership that we have heard and discussed with our partners in the field – almost all of whom are HUD approved housing counseling organizations (others being CDFIs).

1) Streamline and increase the housing counseling funding model to include;
a. Learnings and modelling from the highly successful NFMC program, such as;
i. different funding levels for different levels of service,
ii. more clarity around outcomes & documentation for each level of service,
iii. and less administrative burden for the nonprofit providers in billing.
b. Increased funding within this program for continuing education and certification of counselors to include more emphasis on lending and preparedness for a mortgage.
c. Increased funding for awareness and marketing of HUD approved services and service providers, especially now that the certification is in place. This is a necessary step in accomplishing the second main point below, and another example from NFMC which had an AdCouncil campaign.

2) Make significant progress in increasing the amount of home buyers who attend HUD approved homebuyer education and pre-purchase counseling sessions BEFORE entering into or beginning a purchase transaction. Research with consumers (including that of Fannie Mae) shows that housing counseling and education yields a negative perception prior to attending, but that after receiving services, consumers were excited and appreciative of the excellent information & training they received. The sad part is that most of those services occur AFTER someone has entered a transaction as a requirement of the process, when it may be too late to apply that learning. We must make better efforts to get consumers into these services and classes prior to entering transactions, and in doing so will further increase the efficacy of housing counseling overall. We applaud FannieMae in their creation of a Loan Level Price Adjustment that is intended to help fund housing counseling, and the fact that their registration form requires that the housing counseling services occurred prior to the mortgage application to encourage this sequencing for the benefit of the consumer – a workflow that we support and facilitate as the NMC with our partner agencies.
We at NMC/Springboard CDFI are working to lift up, enhance, and increase the effectiveness of this field, as we provide access to capital and scaled solutions to increase sustainable homeownership for underserved communities & people. We highly value HUD approved housing counseling organizations and experience the difference they make every day.
HUD has an opportunity with this strategic plan to streamline, clarify, and increase efficacy among its programs, while reducing regulatory burden along the way. We will always be a willing partner in our shared mission work, and in accomplishing the above improvements to the field of service.

Sincerely,
Gabe del Rio
President
gabe.delrio@springboard.org
Springboard CDFI / Nationwide Mortgage Collaborative
4351 Latham Street, Suite 100
Riverside, CA 92501
www.mortgagecollaborative.org

The National NeighborWorks® Association respectfully submits the following brief comments to be taken into consideration when developing and/or implementing the Department of Housing and Urban Development’s 2018-2022 Strategic Plan. These comments are not all inclusive of our ideas of having a comprehensive, effective Strategic Plan, but are the ones that we have been able to compile in the time afforded.

As the Department continues to improve on internal resource allocation, such as office space, office supplies, field office utilization, our comments are more focused on the Office of Housing Counseling and the delivery of those services. Though we believe that efficiency and cost-effective measures do at times have their return on implementation, it is important that the Department not cut into areas that would negatively effect program delivery, funding processing and evaluation. Therefore, our strategic planning comments are as follows:

Increasing Marketing and Outreach Efforts: The programs and services that are funded by HUD are invaluable to those that access them. Increasing the throughput of residents across the country to HUD funded and approved housing counseling agencies would increase the impact of funding and the financial resiliency of the population. Having the residents of the nation be able to have the credibility of the Department of Housing and Urban Development engaged in an awareness campaign would have incredible returns.

We also recommend that the increased levels of outreach include encouraging the use of housing counseling in the FHA arena; in highlighting access to pre-purchase, financial capabilities and other aspects financial education pre-loan originating, in addressing delinquent loans and in servicing reverse mortgages. All this would be especially useful in the area of FHA.

Affordable mutli-family housing is of utmost importance in a time when housing insecurity is at an all-time high. It is important that the strategic plan also include a re-commitment to increase significantly the availability of quality, affordable multi-family options to our residents.

Finally, it is equally important that the comments above be accessible to our residents in the rural communities. Including an awareness and plan of addressing the needs of the rural community in the strategic plan will increase the effectiveness and accessibility for our rural residents.

Thank you for the opportunity to provide these comments. National NeighborWorks® Association believes that the programs and services that the Department of Housing and Urban Development supports through technical and financial support are the foundation for success of homeowners and renters across the United States of America.

Lou Tisler, Executive Director
National NeighborWorks® Association
202.223.2526
LTisler@nnwa.us
1819 L Street NW, Suite 400
Washington, DC 20036
www.nnwa.us