SAHF Submits Letter to FHFA DTS Listening Session on Affordable Housing Preservation
August 09, 2022
The Stewards of Affordable Housing for the Future provides comments on the Federal Housing Finance Agency's (FHFA) 2022-2024 Duty to Serve (DTS) Listening Session on Affordable Housing Preservation, hosted on July 11, 2022.
In this letter, SAHF highlights the challenges to nonprofit's ROFR as one of the significant threats to the Housing Credit program, long-term affordability and mission-driven nonprofits seeking the wellbeing of residents. Our observations both in SAHF’s member portfolios and the broader industry reveal that these challenges most often arise from limited partners who were not the original tax credit investor, but rather purchased the interest during the initial fifteen-year compliance period.
SAHF details the broad impacts of these challenges. To address the potential harm these disputes can bring, SAHF provides recommendations including adopting stronger language indicating that reserves remain with the property, including in cases of a ROFR.