Newsletter: December 2021

With the recent passage of the bipartisan infrastructure bill, Congress has moved onto the Build Back Better Act, which includes approximately $170 billion in funding for housing initiatives. On December 1, a bill was introduced in the House to make permanent and expand eligibility for the federal tax deduction of mortgage insurance (MI) premiums. USMI recently submitted two comment letters to the Federal Housing Finance Agency (FHFA) on its proposed “Amendments to the Enterprise Regulatory Capital Framework Rule,” and its “Enterprise Equitable Housing Finance Plans.” Finally, USMI published a new blog examining the costs that are often additional and unanticipated by prospective homeowners. We delve into these developments and more below.

Build Back Better Act. The House passed the $1.75 trillion Build Back Better (BBB) Act on November 19, sending the social spending bill to the Senate. The legislation allocates about $170 billion to provisions for affordable housing. According to the Biden administration, this would be the largest investment in affordable housing in history and it will mean the construction or preservation of more than 1 million affordable homes. BBB, in its current form, would provide funding for numerous homeownership initiatives, including: $10 billion for first-generation first-time homebuyer down payment assistance (DPA) based on House Financial Services Committee Chairwoman Maxine Waters’ (D-CA) “Downpayment Toward Equity Act”; $10 billion for the U.S. Department of Housing and Urban Development’s (HUD) HOME Investment Partnerships Program to fund building, buying, and/or rehabilitating affordable housing for rent or homeownership; $5 billion for wealth-building loans (20-year subsidized mortgages) for first-generation first-time homebuyers based on Sen. Mark Warner’s (D-VA) “Low-Income First-Time Homebuyers Act” (LIFT Act); $1.75 billion for a new “Unlocking Possibilities” zoning and land use reform program; $800 million for fair housing activities; and $100 million for a pilot program at HUD to expand small-dollar mortgage options for homebuyers purchasing homes at $100,000 or less.

The Middle Class Mortgage Insurance Premium Act of 2021. On December 1, Reps. Ron Kind (D-WI) and Vern Buchanan (R-FL) introduced legislation that would make permanent and expand eligibility for the deduction of MI premiums from federal income taxes. USMI released a statement writing that the legislation “is smart public policy that benefits potentially millions of existing homeowners…Since 2007, the ability to deduct the cost of MI premiums has helped to put extra dollars back into the hands of millions of families each year and we strongly support legislation to make the tax deduction permanent.” MI deductibility has enjoyed broad bipartisan support, dating back to when the bill was originally introduced in 2005, and continues to have broad housing industry support, including from the Mortgage Bankers Association, National Association of Home Builders, National Association of REALTORS®, and National Housing Conference. National Mortgage News, DS News, Financial Regulation News and published articles on the proposed legislation that quote the bill’s sponsors and USMI.

USMI Submits Comment Letter for FHFA’s Proposed Amendments to the Enterprise Regulatory Capital Framework. On November 23, USMI submitted a comment letter on FHFA’s Notice of Proposed Rulemaking (NPR) on “Amendments to the Enterprise Regulatory Capital Framework (ERCF) Rule – Prescribed Leverage Buffer Amount and Credit Risk Transfer.” In its letter, USMI recommends that FHFA adjust the credit risk transfer (CRT) minimum risk weight floor to lower than 5 percent, consider alternative methods to determine the Prescribed Leverage Buffer Amount (PLBA), reduce the single-family risk weight floor to 10 percent or less, and make changes to the Countercyclical Adjustment. These recommendations are outlined further in USMI’s executive summary to the comment letter.

Most comments to the NPR support the proposed changes by FHFA to CRT and the PLBA. On the PLBA, many respondents note that the proposed changes would make the framework more risk-based and prevent the PLBA from being the typical binding requirement. On the proposed changes to reduce the minimum risk weight floor for CRT from 10 to 5 percent, most commenters generally supported the reduction and some suggested it be reduced or refined further. Most commenters also supported the removal of the overall effectiveness adjustment for CRT. In addition, many responses – including from insurance agency Guy Carpenter, Freddie Mac, and the Housing Policy Council – support reducing the single-family risk weight floor below the current 20 percent in the final rule. Further, several other organizations – including Urban Institute, Center for Responsible Lending, National Community Stabilization Trust, National Housing Conference, Consumer Federation of America, Leadership Conference and the National Association of REALTORS® – express concerns with the current Countercyclical Adjustment and recommend FHFA revisit this element within the final rule to ensure it will not have unintended consequences.

In a press release, USM President Lindsey Johnson is quoted saying, “We appreciate the work FHFA has undertaken to date to provide for minimum capital requirements for the Enterprises, including the December 2020 final rule to establish a post-conservatorship capital framework. While a robust framework is necessary to ensure the stability of the housing finance system, overly stringent requirements or ones that inaccurately reflect the risks of the assets held by the Enterprises can be disruptive. It is critical FHFA creates a capital framework that strikes an appropriate balance between maintaining borrowers’ access to affordable mortgage credit and ensuring the Enterprises and taxpayers are protected from risk.”

USMI Submits Comment Letter on FHFA’s Enterprise Equitable Housing Request for Input (RFI). On October 25, USMI submitted a comment letter to FHFA’s RFI on “Enterprise Equitable Housing Finance Plans” (the Plans), which articulates a framework by which the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, will be required to prepare and implement three-year plans to advance equity in housing finance. USMI writes in its letter that it “commends the FHFA for soliciting feedback on the Plans to identify the barriers to sustainable housing opportunities, set goals to address those barriers, and implement policies to address them. The private MI industry welcomes the opportunity to work with FHFA, the GSEs, and other housing finance stakeholders to support the Biden Administration’s goal of a comprehensive approach to advancing equity for all.” In its comment letter, USMI specifically recommends that FHFA review and reform loan-level price adjustments (LLPAs); review and revise the ERCF; modify the Preferred Stock Purchase Agreements (PSPAs); finalize the new products and activities rule; and provide greater data and transparency to address longstanding inequities in the housing finance system.

New Blog: Hidden Costs Harmful to Homeownership. In USMI’s latest blog on its 2021 National Homeownership Market Survey, we examined the way hidden or unanticipated costs impact homeownership. Home prices are increasing at historic levels and consumers expect both home prices and mortgage interest rates to increase over the next year. Sixty percent of respondents to the survey believe minorities face added homebuying costs because they tend to have lower credit and higher debt according to the survey. The survey also found that 60 percent of respondents believe reducing costs for low down payment homebuyers is the most important item for the homebuying process and 37 percent support cutting hidden costs on mortgages.

What We’re Reading. On December 2, Fannie Mae released a report titled, “Barriers to Entry: Closing Costs for First-Time and Low-Income Homebuyers,” which analyzed the costs associated with closing a mortgage loan and presented potential solutions to reduce certain closing costs for specific borrowers, where these additional costs may act as a barrier to homeownership. Based on a sample of 1.1 million conventional purchase mortgages acquired in 2020, Fannie Mae found that “median closing costs as a percent of home purchase price were 13 percent higher for low-income first-time homebuyers than for all homebuyers, and 19 percent higher than for non-low-income repeat homebuyers.”

Nominations We’re Watching. Julia Gordon, the nominee to lead the Federal Housing Administration, is still waiting on a full Senate vote. Meanwhile, the Senate Committee on Banking, Housing, and Urban Affairs on December 2 favorably reported via voice vote the nomination of Alanna McCargo to serve as the president of Ginnie Mae.

ICYMI: USMI Member Spotlight – Essent. In case you missed it, Essent Chairman and CEO Mark Casale was featured on our member spotlight. Casale shared his thoughts on Essent’s views on the housing market as we come out of the COVID-19 pandemic, the continued evolution of the private MI industry and the role of innovation, and how this evolution will better serve borrowers and the housing finance system. Read the full Q&A here.

Newsletter: October 2021

Autumn has arrived and Congress is in high gear as House and Senate Democrats work to advance their bipartisan infrastructure bill, despite being at odds over the size and scope of the budget reconciliation package. In addition, on Congress’ near-term to-do list is addressing the nation’s debt ceiling. The Administration’s housing access and affordability efforts have also gathered steam, most notably with the White House, Federal Housing Finance Agency (FHFA), and U.S. Department of Housing and Urban Development (HUD) making several announcements related to housing supply and fair lending last month, including a Memorandum of Understanding (MOU) announced on fair lending enforcement between FHFA and HUD.

September also marked the start of Hispanic Heritage Month, which runs through October 15. This month provides an opportunity to recognize the significant contributions and influence of Hispanic Americans to the history, culture, and achievements of the United States. In honor of Hispanic Heritage Month, USMI dove deeper into today’s Hispanic homeownership market and how it will shift in the future. We further detail these and more developments below.

Hispanic Homeownership: How the Hispanic Population Growth Helps Drive the Homeownership Market
Hispanic Heritage Month Industry Leader Q&A: Marisa Calderon
Developments at FHFA
White House Plan to Address Housing Supply Agenda
Budget Reconciliation Package Makes Progress
Nominations and Confirmations
What We’re Watching: Housing Finance Strategies and National Housing Conference Panels
What We’re Reading: MBA Path to Diversity Scholarship Q&A

Hispanic Homeownership: How the Hispanic Population Growth Helps Drive the Homeownership Market. On September 15, the first day of Hispanic Heritage Month, USMI published a blog post on Hispanic homeownership, the impact this demographic is having in today’s market, and the various challenges this population faces in attaining the American Dream of owning a home. Over the last few years, the Hispanic population has been a key component in the growth of the homeownership market in the U.S., and it is projected to be the demographic group leading this segment of the industry for the next several decades. We also referenced data from our 2021 National Homeownership Market Survey, which provides greater insights into perceptions and challenges pertaining to the housing market and homebuying process. This blog post was also posted in Spanish, and was featured in National Mortgage Professional and Insurance News Net.

Hispanic Heritage Month Industry Leader Q&A: Marisa Calderon. In honor of Hispanic Heritage Month, USMI reached out to Hispanic leaders in the mortgage industry to discuss their work and perspectives on the goal of increasing Hispanic homeownership in America. Marisa Calderon, Executive Director of National Community Reinvestment Coalition’s (NCRC) Community Development Fund and a housing and financial services industry veteran, recently shared with USMI her thoughts on these issues and others, relating to the mortgage finance sector in 2021 and beyond. Read the full Q&A here.

Developments at FHFA. Under Acting Director Sandra Thompson, FHFA has announced a number of changes and proposals designed to increase access and affordability for borrowers. 

  • On August 11, FHFA announced that Fannie Mae will consider 12 months of positive rental payment history in its risk assessment processes for loans that would otherwise be ineligible for acquisition due to thin or nonexistent borrower credit history. Speaking about the announcement, Acting Director Sandra Thompson said, “[w]ith this update, Fannie Mae is taking another step toward understanding how rental payments can more broadly be included in a credit assessment, providing an additional opportunity for renters to achieve the dream of sustainable homeownership.”
  • On September 7, FHFA announced that the government sponsored enterprises (GSES or Enterprises), Fannie Mae and Freddie Mac, will be required to submit Equitable Housing Finance Plans to the Agency by the end of 2021. The plans will aim to identify and address barriers to sustainable housing opportunities, including the GSEs’ goals and action plans to advance equity in housing finance for the next three years. FHFA released a Request for Input (RFI) on the Enterprises Equitable Housing Finance Plans that is due on October 25. FHFA also held a listening session on September 28 soliciting additional input from stakeholders. Speakers detailed several recommendations for FHFA to enhance the plans, as well as other actions FHFA and the GSEs might take to combat the racial homeownership gap and possible fair lending violations, including focuses on targeted down payment assistance, reviewing and reassessing loan level pricing adjustments (LLPAs), and additional changes to the GSEs’ final capital rule than those that were proposed by FHFA in September 2021 among others.
  • On September 14, the FHFA and the U.S. Department of the Treasury suspended certain provisions added to the Preferred Stock Purchase Agreements (PSPAs) with Fannie Mae and Freddie Mac on January 14, 2021. In the announcement about the suspended provisions, Acting Director Sandra Thompson said, “this suspension will provide FHFA time to review the extent to which these requirements are redundant or inconsistent with existing FHFA standards, policies, and directives that mandate sustainable lending standards.”
  • Lastly, on September 15, FHFA announced that it is seeking comment on a Notice of Proposed Rulemaking (NPRM) that would amend the Enterprise Regulatory Capital Framework (ERCF) for Fannie Mae and Freddie Mac. The proposed amendments would “refine the prescribed leverage buffer amount (PLBA) and the capital treatment of credit risk transfers (CRT) to better reflect the risks inherent in the Enterprises’ business models and to encourage the distribution of credit risk from the Enterprises to private investors.”

On August 31, 2020, USMI submitted a comment letter on FHFA’s Proposed Rule on ERCF emphasizing the importance of constructing a balanced, transparent, and analytically justified post-conservatorship capital framework for the GSEs.

White House Plan to Address Housing Supply. On September 1, the White House announced a plan to increase affordable housing supply as part of President Biden’s “Build Back Better” agenda. While Congress works on the budget reconciliation and bipartisan infrastructure bills, the White House’s plan includes provisions such as relaunching the Federal Financing Bank and HUD risk sharing program, increasing Fannie Mae and Freddie Mac’s low-income housing tax credit investment cap, and making funding available for affordable housing production under the Capital Magnet Fund.

Budget Reconciliation Package Makes Progress. A $3.5 trillion reconciliation bill passed the House Budget Committee on September 25. The House Financial Services Committee (HFSC) held a markup in mid-September for its portion of the Build Back Better Act. The bill, passed by a vote of 30-24 on September 14, would provide for $322 billion in funding for new and existing federal housing programs, including: $90 billion for new rental assistance; $80 billion to address public housing capital backlog; $80 billion in housing supply investments; and $10 billion in first-time, first-generation homebuyer down payment assistance (DPA).

Nominations and Confirmations. On September 13, the White House announced that President Joe Biden intends to nominate Alanna McCargo for President of the Government National Mortgage Association (Ginnie Mae) at HUD and she is scheduled to testify before the Senate Committee on Banking, Housing, and Urban Affairs on October 7. USMI welcomed the decision and cited McCargo’s extensive experience in mortgage policy.

On September 21, the Senate voted 49-48 to discharge from the Senate Committee on Banking, Housing, and Urban Affairs the nomination of Rohit Chopra to head the Consumer Financial Protection Bureau (CFPB), and voted 50-48 to confirm him as CFPB Director on September 30. Lastly, the Committee also announced it would hold a hearing on October 5 to vote on several nominees, including Julia Gordon to serve as Federal Housing Administration (FHA) Commissioner.

What We’re Watching: Housing Finance Strategies and National Housing Conference Panels. On September 20, USMI President Lindsey Johnson joined a Housing Finance Strategies panel with several other housing industry leaders to discuss the Biden Administration’s changing regulatory environment, the transition to digital mortgages, and the remote workforce in the housing industry. The program is available here.

On September 30, Johnson joined a National Housing Conference (NHC) panel for a conversation on Fannie Mae and Freddie Mac’s role in affordable homeownership, housing reforms, and closing the racial homeownership gap. Johnson specifically shared the results from USMI’s 2021 National Homeownership Market Survey, which was released earlier this year. Watch the panel here.

What We’re Reading: MBA Path to Diversity Scholarship Q&A. USMI is proud to partner with the Mortgage Bankers Association (MBA) in support of their Path to Diversity Scholarship program, which has a strong record of increasing diverse representation in the housing finance industry. USMI President Lindsey Johnson spoke with MBA NewsLink for a Q&A session about the scholarship and its impact. Read more here.

Newsletter: July 2021

As the August recess approaches, there have been several notable developments in the housing finance industry. Policymakers and industry leaders continue to focus on top priorities including new homeowner protections, the bipartisan infrastructure deal, housing affordability and supply, and down payment assistance (DPA), among others. Further, during the past month, U.S. Mortgage Insurers (USMI) released its latest Member Spotlight highlighting a Q&A with Enact’s President and CEO, Rohit Gupta; a statement congratulating Julia Gordon on her nomination to serve as Federal Housing Administration (FHA) Commissioner; and published two blog posts noting and discussing the top findings from USMI’s 2021 National Homeownership Market Survey. Below are some of the key developments USMI has been following over the last month.

Bipartisan Infrastructure Deal. On July 28, the $1.2 trillion infrastructure deal cleared a major procedural vote in the Senate. The 67-32 vote passed with support from all 50 Democrats and 17 Republicans. This vote allows the Senate to start the debate and amendment process to resolve outstanding issues. Draft legislative text of the bill circulated on Thursday; however, the bill’s authors noted today that the text has not yet been finalized. According to the draft text, the bill would provide about $550 billion in new federal money for roads, bridges, and other physical infrastructure programs. While agreement on final text and clearing final votes in the House and Senate remain, if passed, the bill would mean the largest infusion of federal money into public works in more than a decade.

USMI’s 2021 National Homeownership Market Survey. Following the June release of USMI’s 2021 National Homeownership Market Survey, fielded by ClearPath Strategies to 1,000 adults in the U.S., USMI published two blog posts titled, “National Homeownership Market Survey: Key Takeaways,” and “Top Homebuying Challenges: Affordability and Supply.” In these posts, USMI highlights that more than 7 in 10 respondents view owning a home as important for stability and financial security. In addition, nearly 7 in 10 respondents ranked the lack of affordable housing as the number one housing challenge, while nearly 6 in 10 stated that low housing supply is another top issue, all of which become more acute among minority and lower income homebuyers. The latest blog notes that just this week, “the Federal Housing Finance Agency (FHFA) released its Home Price Index and reported that home prices were up 1.7 percent in May, and up an astonishing 18 percent year over year. This significant home price appreciation is largely driven by the lack of housing supply in today’s market and is impacting borrowers’ access to homeownership across the country.” 

USMI Member Spotlight: Enact CEO Rohit Gupta Talks About First-Time Homebuyers. Earlier this month, USMI talked with Rohit Gupta, President and CEO of Enact, formerly Genworth Mortgage Insurance (MI), about the company’s new brand as well as how it is better positioned to serve low down payment borrowers and the first-time homebuyer market. Gupta said that private MI “is imperative in order for borrowers with low down payments to have access to home mortgage financing options,” and noted that Enact’s First-Time Homebuyer Market Report shows how the housing finance system continues to perform well with the private MI industry ensuring access to credit for first-time homebuyers.

USMI Joins Coalition Letter to Bipartisan Senate Infrastructure Group on Usage of G-Fees. Last week,USMI joined a coalition of housing finance organizations, including Mortgage Bankers Association (MBA), National Association of REALTORS®, and National Housing Conference, in sending a letter to the bipartisan Senate group negotiating infrastructure legislation. In this letter, the coalition requested that lawmakers refrain from utilizing guarantee fees (g-fees) charged by the government sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, as a source of funding offsets. G-fees are charged by the GSEs and intended to cover the credit risk and other costs that the GSEs incur when they acquire single-family loans from lenders, and the consumer ultimately pays for these fees in their mortgage costs. It is important that future homeowners not be saddled with additional cost burdens, especially those from spending that is not housing-related. As representatives of institutions that span the entire housing finance ecosystem, the coalition reaffirmed the belief that g-fees should only be used as originally intended: “a critical risk management tool to protect against potential mortgage credit losses and to support the GSEs’ charter duties.

USMI Statement on Julia Gordon’s Nomination as FHA Commissioner. On June 28, USMI released a statement on President Biden’s nomination of Julia Gordon to serve as FHA Commissioner. Gordon has broad experience in the housing finance system, specializing in supporting affordable homeownership and promoting consumer protection policies for underserved markets. USMI President Lindsey Johnson said, “[w]e look forward to working closely with Gordon in seeking to promote a complementary, collaborative, and consistent housing finance system that enables sustainable homeownership for American families while also protecting taxpayers.”

Biden Administration Announces New Homeowner Protections. Last week, the Biden Administration unveiled additional actions to prevent foreclosures, offering loan modifications and payment reductions for homeowners with government-backed mortgages to help them stay in their homes, as the federal ban on foreclosures is set to end on July 31. The Biden Administration said about 1.8 million Americans remain in forbearance today, more than a year after emergency safeguards were put in place due to the COVID-19 crisis. The new loan modification programs for mortgages backed by the FHA, Department of Agriculture (USDA), and Department of Veterans Affairs will “aim to provide homeowners with a roughly 25 percent reduction in borrowers’ monthly principal and interest (P&I) payments to ensure they can afford to remain in their homes and build equity long-term.”

Additionally, on Thursday, the White House called on Congress to extend the eviction moratorium and announced that President Biden has “asked the U.S. Departments of Housing and Urban Development, Agriculture, and Veterans Affairs to extend their respective eviction moratoria through the end of September, which will provide continued protection for households living in federally-insured, single-family properties.” Today, FHA announced an extension of its single family eviction moratorium through September 30, and FHFA announced that it will be extending its COVID-19 real estate owned (REO) Eviction Moratorium through September 30, 2021. The REO eviction moratorium applies to properties that have been acquired by an Enterprise through foreclosure or deed-in-lieu of foreclosure transactions. The current moratorium was set to expire on July 31, 2021.

Lastly, late Thursday evening, U.S. House Financial Services Committee (HFSC) Chairwoman Maxine Waters (D-CA) and 100 Democratic cosponsors introduced H.R. 4791, the “Protecting Renters from Evictions Act of 2021,” which would extend the moratorium on residential evictions through December 31, 2021.

FHFA Dropping Fee Introduced During COVID-19. On July 16, the FHFA announced that the GSEs will eliminate the Adverse Market Refinance Fee for loan deliveries effective August 1, 2021. At the direction of FHFA, the GSEs implemented a 50-basis point refinance fee for mortgages at or above $125,000 to cover potential losses due to the COVID-19 pandemic. The fee took effect December 1, 2020 and, according to the MBA, added approximately $1,400 to the cost of refinancing most mortgages. “The COVID-19 pandemic financially exacerbated America’s affordable housing crisis,” said FHFA Acting Director Sandra L. Thompson, adding, “[e]liminating the Adverse Market Refinance Fee will help families take advantage of the low-rate environment to save more money.”

House Financial Services Committee Holds Hearing with HUD Secretary Marcia Fudge. On July 20, the HSFC held a hearing titled, “Building Back A Better, More Equitable Housing Infrastructure for America: Oversight of the Department of Housing and Urban Development,” (HUD) in which Secretary Marcia Fudge participated as a witness. During the hearing, legislators demonstrated bipartisan agreement on housing affordability becoming a growing challenge. Secretary Fudge indicated in her opening remarks that housing affordability “keeps families awake at night,” and said that housing is “the number one crisis in this country today.” Committee members discussed several facets of the issue and a variety of approaches to address it, particularly in support of first-time homebuyers finding themselves priced out of a competitive market. Representatives Blaine Luetkemeyer (R-MO) and Ted Budd (R-NC) inquired about HUD’s potential tools to combat the impacts of regulations on housing costs. Secretary Fudge conveyed that HUD is exploring tools at the federal level to incentivize localities to update their zoning policies and remove other statutory barriers to affordable housing. Representative Ted Budd (R-NC) asked Secretary Fudge about how the $213 billion in funding proposed in President Biden’s infrastructure plan for new and rehabilitation of existing affordable housing would be divided. Fudge noted that dollar amounts had not been decided but the administration is targeting the development of 2 million new units and rehabilitation of 500,000 existing units. Other topics discussed included accessibility and affordability of FHA credit, GSE lending to minority borrowers, HUD appraisal task force, climate risks, and Property Assessed Clean Energy (PACE) loans.

What We’re Reading: Congressional Proposals to Increase Homeownership. On July 19, USMI published a blog post titled, “Washington Focuses on Infrastructure and Equity with an Eye Toward Homeownership.” The blog notes that as policymakers shift their focus from the COVID-19 pandemic to negotiating and drafting legislative text for President Biden’s infrastructure proposals, Congressional Democrats are championing housing policies intended to promote equitable communities and give traditionally underserved Americans a stake in those communities. In this sense, the piece outlines and details the various legislative proposals put forth by Democratic legislators to help these underserved communities. Many of these proposals seek to address issues such as the critical housing supply shortage, first-time/first-generation DPA proposals, tax incentives to support homeownership, and home equity building opportunities.

USMI released principles for Access and Affordability in January, in which it suggests that “existing DPA programs— and any expansions – should balance responsible underwriting that promotes sustainable homeownership and access to affordable low down payment mortgages. DPA programs should be targeted to serve the creditworthy borrowers who are unable to attain even a 3 [percent] or 3.5 [percent] down payment. It is important that DPA programs are structured and operated in a sustainable manner so as to not create excessive leverage and risk within the mortgage finance system, or pose undue risk to taxpayers and the economy, which will ultimately hurt vulnerable homeowners most.” Further, USMI encouraged policymakers, including HUD Secretary Marcia Fudge, to pursue policies that promote affordable and sustainable access to mortgage finance credit, but that do not add fuel to the fire in terms of artificially lowering what is already relatively affordable mortgage finance credit as such actions would inject more “demand” into the market without addressing the “supply” side—which will only drive-up home prices further, hurting affordability at the lower end of the market most.