Equitable Housing Finance Plan

FREDDIE MAC

Our Commitment to Making Home Possible Equitably

June 2022
Introduction�����������������������������������������������������������������������������������������������������������������������������������������1

SECTION 2: Barriers to Equitable Housing �������������������������������������������������������������������������������������������� 2

2.1: The Foundation of Inequity in Housing ���������������������������������������������������������������������������������������������������������� 

2.2: The Persistence of Inequity��������������������������������������������������������������������������������������������������������������������������� 

2.3: Systemic Barriers ���������������������������������������������������������������������������������������������������������������������������������������� 

SECTION 3: Plan Overview �����������������������������������������������������������������������������������������������������������������15

SECTION 4: Special Purpose Credit Programs��������������������������������������������������������������������������������������17

4.1: Pricing: Single-Family Loan-Level Price Adjustments  ��������������������������������������������������������������������������������������2

4.2: Mortgage Insurance Cost Reduction ����������������������������������������������������������������������������������������������������������� 2

4.3: Single-Family Title Insurance Cost Reduction  ����������������������������������������������������������������������������������������������� 2

4.4: Automated Collateral Evaluation Expansion ������������������������������������������������������������������������������������������������� 2

4.5: Reserve Funds������������������������������������������������������������������������������������������������������������������������������������������ 2

4.6: Servicing for Sustainability (Single-Family) ��������������������������������������������������������������������������������������������������� 2

4.7: Increase Diverse Multifamily Borrowers’ Access to Capital ����������������������������������������������������������������������������� 2

SECTION 5: Targeted Outreach and Interventions ������������������������������������������������������������������������������32

5.1: Promote Down Payment Assistance Tools with Industry Partners Serving Black and Latino Communities  �������������� 3

5.2: Finance Housing for Persons with Intellectual and/or Developmental Disabilities  ��������������������������������������������� 3

5.3: Finance Permanent Supportive Housing for Persons Who Formerly Experienced Homelessness�������������������������� 3

5.4: Provide Technical Assistance on Renovation Financing for Single-Family Homes in Traditionally

Underserved Black and Latino Communities   ����������������������������������������������������������������������������������������������� 39

5.5: Expand Develop the Developer Program to Include Small Multifamily Properties �����������������������������������������������4

5.6: Social Bond Issuance (Single-Family)  ���������������������������������������������������������������������������������������������������������� 4

Table of Contents

Implementation of the activities and 

objectives in Freddie Mac’s Equitable 

Housing Finance Plan may be subject 

to change based on factors including 

FHFA review for compliance with Freddie 

Mac’s statutory charter, specific FHFA 

approval requirements and safety and 

soundness standards, FHFA guidance 

and directives, regulatory requirements, 

Senior Preferred Stock Purchase 

Agreement obligations, and adverse 

market or economic conditions, as 

applicable.

EQUITABLE HOUSING FINANCE PLAN
5.7: Affirmative Marketing Plan  ������������������������������������������������������������������������������������������������������������������������ 4

5.8: Equity Research Agenda  ��������������������������������������������������������������������������������������������������������������������������� 4

SECTION 6: Broad Interventions to Address Systemic Barriers to Equitable Housing������������������������������51

6.1: Improve Fairness in Credit Scoring ������������������������������������������������������������������������������������������������������������� 5

6.2: Improve Fairness in Underwriting   �������������������������������������������������������������������������������������������������������������� 5

6.3: Solutions to Address Appraisal Bias������������������������������������������������������������������������������������������������������������� 5

6.4: Provide Capital for Very Small Multifamily Properties by Expanding “Linked Loan” Parameters  ��������������������������� 5

6.5: Support Renter and Multifamily Borrower Resource Organizations  ����������������������������������������������������������������� 6

6.6: Develop Multifamily Correspondent Lender Program for Community Development Financial Institutions,

Minority Depository Institutions and Small Lenders���������������������������������������������������������������������������������������� 62

6.7: Facilitate Ground-Up Construction and Adaptive Reuse of Affordable and Middle-Income Rental Housing

for Individuals and Families  ����������������������������������������������������������������������������������������������������������������������� 64

6.8: Rehabilitate Affordable Rental Housing ������������������������������������������������������������������������������������������������������� 6

6.9: Explore and Implement Methods to Preserve At-Risk Affordable Housing through Freddie Mac

Affordability Restrictions  ����������������������������������������������������������������������������������������������������������������������������71

6.10: Analyze Low-Income Housing Tax Credit Properties at Risk of Lost Affordability ������������������������������������������������ 7

6.11: Analyze and Identify Affordable Rental Housing Needs ��������������������������������������������������������������������������������� 7

6.12: Financial Empowerment for Renters: Credit Building Through On-time Rent Reporting, CreditSmart

and Equity Building for Renters  ������������������������������������������������������������������������������������������������������������������ 77

6.13: Identify and Implement Enhanced Baseline Tenant Protections ����������������������������������������������������������������������� 8

6.14: Analyze Housing Choice Voucher Availability, Efficacy and Acceptance for Renters and Homeowners ����������������� 8

6.15: Reform the Single-Family Rental Market with a Focus on Equity, Affordability and Sustainability��������������������������� 8

SECTION 7: Conclusion ���������������������������������������������������������������������������������������������������������������������86

SECTION 8: Appendix �����������������������������������������������������������������������������������������������������������������������88

8.1: Consumer Research Interview & Surveys������������������������������������������������������������������������������������������������������ 8

8.2: Industry Research Interviews ���������������������������������������������������������������������������������������������������������������������� 9

EQUITABLE HOUSING FINANCE PLAN
Introduction

Too often, many communities of color, specifically Black and Latino communities, face 

difficulty accessing a quality, affordable place to call home that enables intergenerational 

wealth and mobility. Decades of discriminatory housing policies and practices directed at

Black and Latino families effectively isolated and prevented them from renting or owning 

an affordable home in the neighborhood of their choice or accumulating wealth through 

homeownership. The cumulative effect of these historical practices has impacted equity

in housing, creating gaps in homeownership, wealth and opportunity that persist today

Freddie Mac was chartered by Congress in 1970 to provide liquidity, stability and 

affordability to all corners of the U.S. housing market. For more than 50 years, we ha

been working continuously to fulfill our mission of making home possible for millions of 

renters and homeowners across the nation. However, there is more work to be don

Today, we extend our commitment of serving homebuyers and renters across all markets 

and dimensions, including, but not limited to, race, ethnicity, sexual orientation and 

accessibility, to focus specifically on furthering equity in housing

We recognize this is a challenge too big to be addressed lightly. We must act both

directly to address unique challenges and broadly to remediate systemic issues in 

the housing market. We are focused on improving access to credit, housing choice,

economic mobility, financial empowerment and assistance from trusted housing 

professionals. We will undertake actions that tackle the housing supply challenge,

expand credit responsibly and promote sustainable housing opportunities in a safe and 

sound manner

This Equitable Housing Finance Plan underscores Freddie Mac’s commitment to work 

across the industry and with FHFA to create opportunities for all families to access quality 

and affordable housing and to set new standards that bring more individuals closer to 

their American Dream

“Freddie Mac’s Equitable Housing Finance Plan 

looks closely at current housing environment and 

puts forth meaningful and challenging solutions 

that advance equitable and sustainable ownership 

and rental opportunities for all. It is part of Freddie 

Mac’s effort to serve our mission expansively by 

increasing access, expanding credit responsibly and 

bringing greater access to the American Dream.” 

 – Michael J. DeVito, CEO

EQUITABLE HOUSING FINANCE PLAN 1
SECTION 2

Barriers to 

Equitable Housing

Freddie Mac studied the long history of racial housing discrimination and 

examined its effects that persist today. We scrutinized internal research,

industry feedback and deep external ethnographic analysis to understand the 

unique experiences of Black and Latino communities as they relate to housing

Additionally, we reviewed comments submitted in response to FHFA’s 

Equitable Housing Finance Plan Request for Information (RFI) regarding the 

state of equitable housing in the market, and we incorporated this input into 

our approach and the specific activities included in the plan

The following sections detail the foundation and persistence of housing inequity 

and the five most common systemic barriers present in today’s market
2.1: The Foundation of Inequity in Housin

The history of housing in the United States is one of wealth and opportunity — and 

inequity and exclusion. From the start of the modern American housing market in the

early 20th century, homeownership and wealth-building were granted overwhelmingly 

and intentionally to white households. The adoption of discriminatory practices was

apparent in the public domain (i.e., federal/local laws and practices) and in the privat

sector, including the mortgage industry

Five high-profile examples demonstrate the scope 

and impact still felt today:

Redlining

Deed Restrictions and Restrictive Covenants

Discrimination in Access to Housing Subsidies

Exclusionary Zoning

Urban Renewal

EQUITABLE HOUSING FINANCE PLAN 3
Redlining – Redlining as a matter of federal policy (as opposed to solely a pernicious 

practice) started and was codified in the Federal Housing Administration lending policies 

and the Homeowner’s Loan Corporation (HOLC) residential security maps, which 

prevented the provision of government-backed financing in many neighborhoods with 

minority residents

1

 Generations of minority households could not purchase homes or 

move to emerging suburban neighborhoods. Public-sponsored practices at all levels

(federal, state and local) and private market discriminatory practices in mortgage lending 

reinforced and continued to exacerbate the disparities and cut off access to wealth 

building, economic mobility and social mobility for future generations

Deed Restrictions and Restrictive Covenants – Redlining practices and housing 

segregation were often cemented through deed restrictions and restrictive covenants 

on properties themselves

2 This practice prevented the sale of homes to minority buyers

Homeowners’ associations and other local groups enforced these restrictions and the 

status quo of segregated neighborhoods

3

Discrimination in Access to Housing Subsidies – A long history of discrimination 

in access to housing subsidies exists in the United States, beginning in redlined 

neighborhoods and extending into the Servicemen’s Readjustment Act of 1944 (G.I. Bil

The Veterans Administration, established under the G.I. Bill, adopted the Federal Housin

Administration’s (FHA’s) racial exclusion programs when insuring mortgages for returning 

veterans

4 For example, large developments in prominent areas such as Levittown, NY 

and San Francisco, CA were financed by the Veterans Administration and upheld the 

same racial restrictions. While the G.I. Bill itself did not include exclusionary languag

the underwriting manual of the FHA included language stating that “incompatible racial 

groups should not be permitted to live in the same communities” and prevented loans to 

Black veterans from being insured

5

1 https://www.nber.org/papers/w292

2 “Racially restrictive covenants were meant to keep [non-white] individuals out of neighbourhoods by blocking them from 

purchasing or occupying a home.

 Gaucher, Hayley. “Book Note: Saving the Neighborhood: Racially Restrictive Covenants, Law, And Social Norms, by

Richard RW Brooks and Carol M Rose.”

Osgoode Hall Law Journal 51.2 (2014): 717-71

3 Id

4 https://www.history.com/news/gi-bill-black-wwii-veterans-benefi

5 https://www.npr.org/transcripts/5266558

EQUITABLE HOUSING FINANCE PLAN 4
Zoning – Zoning ordinances were used to prevent racial and ethnic minorities from 

moving into certain neighborhoods, whether through minimum lot size and square 

footage requirements or limits on building heights

6 Housing segregation was extended 

to property types. Multifamily rental properties and manufactured housing were often

prohibited in predominantly white communities. Apartments were described as “a

parasite” that would lead to the ultimate destruction of neighborhoods by the landmark 

1926 Supreme Court case Village of Euclid v. Ambler Realty7 which enabled the locality 

to establish and enforce zoning ordinances. While much has changed since 1926, the

persistent use of zoning to maintain development patterns often results in perpetuation 

of existing economic and de facto racial segregation

Urban Renewal – Urban renewal and highway development increased segregation

As public works projects were developed, it was common practice to displace minority 

residents, build through minority communities and disconnect communities from social 

and economic opportunities. Often, displacement was coupled with the construction

of high-density “towers in the park” public housing that further disconnected minority 

residents. Underfunding of urban renewal programs over time led to a deterioration of

the properties and the living experience

Laws, policies and practices such as these created nearly insurmountable hurdles to an 

equitable housing market. Although many of the last century’s discriminatory practices

and standards have been formally repealed or declared illegal or unconstitutional, they 

persist in new and subtle ways

6 https://pubs.aeaweb.org/doi/pdfplus/10.1257/app.2014

7 Village of Euclid, Ohio v. Ambler Realty Co., 272 U.S. 365 (1

EQUITABLE HOUSING FINANCE PLAN 5
2.2: The Persistence of Inequit

The persistent effects of inequitable housing policies and practices can be seen 

throughout the housing experience — from homeownership rates and credit gaps to 

geographic underinvestment and exposure to climate risk

Homeownership Gap – As of the first quarter of 2022, the Black homeownership rate 

(44.7 percent) and Latino rate (49.1 percent) were below the non-Latino white rat

(74 percent)

8 These homeownership gaps are significant and underscore the need 

for us all to do better

Segregation – The level of residential segregation has not changed materially over the 

last hundred years. Additionally, exclusionary zoning disproportionately and negatively

impacts communities of color

9

8 https://www.census.gov/housing/hvs/files/currenthvspress.

9 https://tcf.org/content/facts/understanding-exclusionary-zoning-impact-concentratedpoverty/?agreed=1&session=

Wealth & Income Inequality – Generations of segregation and disparities in economic 

and social mobility resulted in deep wealth gaps, impeding equitable access to sustainable 

housing. The average white family has accumulated seven times the wealth of the average

Black family and five times that of the average Latino family

10 As a result, Black and Latino 

borrowers are less likely to receive assistance or inheritance from their family for home 

purchase down payments

11 This wealth gap is tied to the homeownership gap, as renters 

generally have less net worth than homeowners. In 2019, homeowners had 40 times the

net worth of renters

12 Income inequality persists as well. The 2019 Black median household

income was $43,862 and the Latino median income was $55,658, as compared to white 

median income of $71,644

13 Further, more than half of Black and Latino renters were costburdened just prior to the COVID-19 pandemic and are now at increased risk of missing 

rental payments and/or facing eviction

14

Credit Building Inequity – Disparities in credit scores and the ability to obtain credit 

negatively influence housing access. High credit scores positively affect borrowing

power and the cost of financing, yet Black and Latino residents are more likely to be 

unbanked,15 have lower average credit scores and face barriers to credit building

10 https://apps.urban.org/features/wealth-inequality-chart

11 https://www.urban.org/sites/default/files/publication/104134/an-essential-role-for-down-payment-assistance-inclosing-americas-racial-homeownership-and-wealth-gaps_0.

12 https://www.federalreserve.gov/publications/files/scf20.

13 https://www.urban.org/research/publication/closing-gaps-building-black-wealth-through-homeownership/vie

full_report

Source: Urban Institute calculations from the 1962 Survey of Financial Characteristics of Consumers (December 31), the 

1963 Survey of Changes in Family F

inances and the 1983–2019 Surveys of Consumer Finances

14 https://www.jchs.harvard.edu/blog/black-and-Latino-renters-face-greatest-threat-eviction-pande

15 https://www.fdic.gov/analysis/household-survey/2019report.

EQUITABLE HOUSING FINANCE PLAN 6
Discrimination – Black and Latino Americans are more likely to report experiencing 

discrimination when renting or buying a home. Per a Freddie Mac survey completed

in 2020, 42 percent of Black Americans and 29 percent of Latino Americans have felt 

discriminated against when renting or buying a home, compared to 11 percent of white 

Americans. When looking to the future, 44 percent of Black renters and 39 percent of

Latino renters expect to feel discriminated against the next time they rent, compared 

to 16 percent of white renters. Black and Latino homebuyers are more likely to feel

discriminated against when buying a home: 51 percent of Black homebuyers and 

42 percent of Latino homebuyers versus 18 percent of white homebuyers

Undervaluation & Underinvestment – Redlining and segregated housing coincided 

with undervaluation and underinvestment in Black and Latino communities — affecting 

both residents and properties. Access to credit is often tied to geography, and

predominantly Black and Latino communities often find themselves in credit deserts, 

making them less likely to benefit from credit-building opportunities

16 Today, we 

continue to see the effects of redlining and systemic underinvestment in historically 

redlined communities. Freddie Mac research finds that communities of color are more

likely to receive home appraisal values below contract price

17 18

Climate Risk Inequity – Black and Latino households are disproportionately subject 

to climate and environmental risks and hazards. When analyzing flood risk in 38 major

metropolitan areas, 8.4 percent of homes in formerly redlined areas face high flood risk

compared to 6.9 percent of homes that were deemed desirable in historical redlining

maps

19 The net effect of this was apparent after Hurricane Katrina

. Four of the seven zip

codes that faced the costliest flood damage from Hurricane Katrina were at least 

75 percent Black

20

16 https://www.consumerfinanc.gov/about-us/blog/new-research-report-geography-credit-invisibility

17 https://wwwfreddiemac.com/research/insight/20210920_home_appraisal.page

18 https://www.redfi.com/news/redlining-flood-risk

19 https://wwwfreddiemac.com/research/insight/20220510-racial-ethnic-valuation-gaps-home-purchase-appraisalsmodeling-approac

20 https://www

.scientificamerica.com/article/flooding-disproportionately-harms-black-neighborhoods

EQUITABLE HOUSING FINANCE PLAN

7
Black 

Homeownership 

Gap

Wealth 

Building 

Capacity

Appraisal

Bias

Racial 

Bias

Societal & 

Political Will 

to Change 

the System

Strength of the 

Perception that the 

System is Optimal

Level of 

Socio-economic 

Policy Intervention

Income Access to 

Employment

Equity in 

Job Market

Equity in 

Education

Access to 

Education

Access to 

Transportation

Private 

Transportation 

Ownership

Access to 

Public 

Transportation Inheritance/Generational 

Wealth

Access to Credit

Lender Incentive

Realtor Incentive

Gentrification

Home

Ownership

Housing

Prices

Housing

Demand

Mortgages

Approved Sale of Houses

NIMBYism

Urban Planning 

& Zoning 

Regulations

Climate 

Change

Housing Supply

Density

New Housing

Developer Incentive

Existing Housing 

Placed on the Market

Housing

Desirability

Interest

Rate

Positive Relationship

Negative Relationship

Fluid Relationship

2.3: Systemic Barrier

Considerable historical data is available on the topic of housing inequity among renters 

and homebuyers in Black and Latino communities. As shown in the image below, this

is a complex ecosystem. To fully understand its depth and to develop a robust plan

to improve equitable housing, Freddie Mac believed the subject warranted listening 

personally to first-hand accounts — the contemporary voices behind the data. Contributors to the

Black Homeownership Gap

This graphic represents the intricate relationship 

between official public policies, industry practices 

and individual attitudes that have contributed 

over time to the Black homeownership gap.

EQUITABLE HOUSING FINANCE PLAN 8
1 Individual Bias and Discrimination

Examples: Appraisal Bias | Tenant Screening Discrimination | Discriminatory Evictions | 

NIMBYism | Realtor Steering

2 Institutional/Policy Bias and Discrimination

Examples: Credit Assessment Methods | Land Use and Exclusionary Zoning | 

Equality-focused Policy | Profit-maximizing Incentive Structures

3 Economic Disadvantage 

Examples: Generational Wealth Gap | Asymmetric Resilience | 

Access to Education and Employment

4 Limited Supply and Quality of Housing

Examples of Supply Gaps: Size of Affordable Housing Gap | Decline in Construction of 

Affordable Units | Median House Price Growth (vs. Income) | Vulnerable Group

Examples of Root Causes and Friction Points: Impacting Housing Supply and Quality | Cost of Land | 

Zoning & Permitting | Cost of Construction Materials | Labor Shortage | Economics of Affordable 

Housing Project | Pockets of Financial Illiquidity | Quality and Lack of Services

5 Negative Buyer/Renter Sentiment

Examples: Lack of Trust in Financial Institutions | Homebuyer Confidence | Pervasive Fear

Five Barriers to Equitable Housing

From August 2021 through October 2021, Freddie Mac led an extensive research project 

combining human-centered ethnography with quantitative surveys at scale, as well as subjectmatter-expert interviews to build a deeper understanding of the equitable housing challenge

The results of this project revealed that racial disparities in the housing market are driven by 

five barriers to equitable housing.

Members of Black and 

Latino communities 

have disproportionately 

experienced one or more of 

the following five barriers:

Click on each header to go to 

that section.

EQUITABLE HOUSING FINANCE PLAN 9
Barrier 1 – Individual Bias and Discrimination

Key Insights

• Freddie Mac ethnographic research finds that Black and Latino communities 

report experiencing microaggressions that erode trust across the homeownership 

and rental journey. These issues are not only systemic, but also personal. The

affect the emotional readiness and willingness to continue (or even initiate) the 

homebuying process

• Black and Latino buyers report navigating a general feeling of knowing where they are 

welcome and where they are not. For some it’s a non-issue, but for many it is a factor

that further limits desirable inventory

Research Findings

Freddie Mac is focused and very intentional in its approach to eliminate disparities in 

homeownership. We conducted two studies to determine whether minorities are more

likely to receive an appraisal value that is lower than the contract price during purchase 

transactions (referenced as “Appraisal Gap”)

21 22 Our studies found:

• Appraisers’ opinions of home value are more likely to fall below the contract price in 

Black and Latino census tracts, and the extent of the gap increases as the percentage 

of Black or Latino people in the tract increases

• Black and Latino applicants receive lower appraisal values than the contract price 

more often than white applicants

• Properties in Black and Latino tracts receive appraisal values lower than the contract 

price more often than those in white tracts. As the concentration of Black or Latino

individuals in a census tract increases, the appraisal gap increases

• Our modeling results show that after controlling for a list of appropriate factors:

o Properties in Black and Latino tracts receive appraisal values lower than the 

contract price more often than those in white tracts.

o The likelihood for properties in Black tracts and Latino tracts to receive “appraisal 

value lower than contract price” increases as the Black or Latino concentration 

increases in the tracts

o When “appraisal value lower than contract price” takes place, houses in Black tracts 

are appraised slightly lower relative to comparable homes in White tracts in terms 

of the percent difference between the appraisal value and the contract price

Freddie Mac continues to be a proactive industry player in seeking to analyze and 

better understand factors contributing to the results found in these appraisal reports

We remain fully committed to testing and learning with the goal of achieving more 

consistent valuation outcomes across all communities, including reliance on automated 

valuation-based solutions

21 http://www.freddiemac.com/research/insight/20210920_home_appraisals.pa

22 https://www.freddiemac.com/research/insight/20220510-racial-ethnic-valuation-gaps-home-purchase-appraisalsmodeling-approa

EQUITABLE HOUSING FINANCE PLAN 10
Barrier 2 – Institutional / Policy Bias and Discrimination

Key Insights

• Continued reliance on FICO® scores across industries disfavors Black and Latino 

households whose credit scores are often lower. This is due in part to their largest

continual payment — rent — not being reported to credit bureaus

• Land use and exclusionary zoning raise the cost of land and limit accessibility of 

higher-opportunity neighborhoods for lower-income families

• State and local jurisdictions too often establish a low standard for tenant rights or 

allow landlords to deny tenants’ applications based on their source of income

• Ecosystem actors are hesitant to build and launch equity-driven programs that 

provide affirmative support to minorities due to a lack of clear guidance regarding 

how those activities would be interpreted considering anti-discrimination aspects of 

The Fair Housing Act and Equal Credit Opportunity Act (ECOA)

23

• Lenders and real estate agents have the greatest impact on homebuyers’ experience, 

and ideally would have commensurate incentive to deliver equitable service

For example, to expedite the home selection process, agents may steer minority 

homebuyers, thereby reducing their housing choice and their trust in the process

23 https://www.federalreserve.gov/econres/notes/feds-notes/disparities-in-wealth-by-race-and-ethnicity-in-the-201

survey-of-consumer-finances-20200928.ht

EQUITABLE HOUSING FINANCE PLAN 11
Barrier 3 – Economic Disadvantage

Key Insights

• The gap in generational wealth between minorities and non-minorities is a key 

economic disadvantage that perpetuates the homeownership gap. Programs

that focus solely on equal opportunity are unlikely to succeed in closing racial 

homeownership gaps

• Black and Latino families on average have less in emergency savings and are less likely 

to have a friend or family member who can offer financial help

24

• Asymmetric resilience — when system shocks, like natural disasters, public health 

emergencies and economic downturns occur, marginalized communities are prone 

to experiencing compounded negative impacts as it relates to financial health and 

secure housing and may face a limited range of quality home buying options or 

challenges in retaining homeownership

• Minority homebuyers often lack the same level of access to information and/or social 

networks about navigating the homebuying journey as most white homebuyers and 

may make detrimental buying and/or financing decisions as a result

24 https://www.federalreserve.gov/econres/notes/feds-notes/disparities-in-wealth-by-race-and-ethnicity-in-the-201

survey-of-consumer-finances-20200928.ht

EQUITABLE HOUSING FINANCE PLAN 12
• As a result, 1 in every 3 U.S. households continues to be cost burdened with limite

disposable income to spend on other basic needs. The housing affordability crisis

is a nationwide phenomenon, not just a coastal problem, as home prices continue 

appreciating and affordable rentals decrease across most states

28

• Three groups have been disproportionally affected by the affordability crisis: Black/

Latino households, families with children and people with disabilities

o Black and Latino renters remain ~10 percent more cost-burdened than white renters 

and Black/Latino households are ~25-30 percent less likely than white households 

to own their home. The gap impacts the ability of Black and Latino households to

create generational wealth. Black households have 3 times less median household

wealth than white households

29

o Among homeowners, households with children are ~2.4 times more likely to

defer mortgage payment and among renters, households with children are 

~2 times more likely to defer rent payment

30

o Likewise, people with disabilities are disproportionally affected, earning 

40 percent lower median income with insufficient accessibility to housing

Two percent of total housing inventory is accessible for people with mobility 

disabilities, while 14 percent of Americans have mobility disabilities

31

28 U.S. Census Bureau; Joint Center for Housing Studies of Harvard University, National Low Income Housing Coaliti

29 U.S. Census Bureau; Joint Center for Housing Studies of Harvard Universi

30 U.S. Census Bure

31 U.S. Census Bureau, National Center on Birth Defects and Developmental Disabilities, Center for Disease Control an

Prevention

Barrier 4 – Limited Supply and Quality of Housing

Key Insights

• Housing supply remains a core economic barrier. The overall supply and demand

gap for housing units in the U.S. has been growing at a rate of ~600,000 units pe

year (or ~7 Million total) and ~325,000 units per year for affordable housing units 

(~3.5 Million) since 201

25

• Construction of affordable housing units has declined — construction of entry level 

homes declined by 5 percent and of rental affordable homes by 7 percent since 

2010. At the same time, the number of low- to-moderate income (LMI) households

increased, especially non-white households increased by 112 percent

26

• Existing stock has become out of reach for LMI households as housing costs 

significantly outgrew incomes. Median house prices have grown 4 times faster than

median household incomes since 1970 and median monthly rents have grown 

2 times faster than the incomes of the lowest quintiles during the same period

27

25 U.S. Census Bureau; Joint Center for Housing Studies of Harvard University, National Association of Realtors, Pe

Research Center, Yardi Matrix

26 U.S. Census Bureau; Joint Center for Housing Studies of Harvard University, Metropolitan Policy Program at Brookings

National Association of Realtors, Pew Research Center, 

Yardi Matrix, BCG analysis

27 U.S. Census Bure

25 U.S. Census Bureau; Joint Center for Housing Studies of Harvard University, National Association of Realtors, Pe

Research Center, Yardi Matrix

26 U.S. Census Bureau; Joint Center for Housing Studies of Harvard University, Metropolitan Policy Program at Brookings

National Association of Realtors, Pew Research Center, 

Yardi Matrix, BCG analysispoverty/?agreed=1&session=1

27 U.S. Census Bure

EQUITABLE HOUSING FINANCE PLAN 13
Barrier 5 – Negative Buyer and Renter Sentiment

Key Insights

• Surveys and ethnographic research indicate significant consumer distrust in the 

U.S. Banking System and mortgage lending companies on behalf of minorities, whic

is likely to be a barrier to distributing programs through those channels. Non-Black,

non-community banks’ share of lending to Black consumers dropped by nearly half 

from 80 percent to 42 percent between 2007–2018

32

• A lack of confidence about the homebuying process inhibits minorities from taking 

the first steps towards homeownership. Even though about half of low- to moderateincome homeowners and renters are aware of financial assistance programs,

14 percent of homeowners and 27 percent of renters apply, as most do not believe 

they qualify

• Whether it is fear from a previous experience, fear of the responsibility of maintaining 

a home, fear of not having family or a partner to fall back on during hard times, it can 

take longer for some to feel comfortable with venturing into homeownership

32 FDIC data and Urban Institute Calculations, “Share of mortgage origination to the Black Community 2007-2018”

“I have two checking [accounts] – one I spend from, and 

one I put money in for bills, and one savings account, 

no credit cards...I can’t get a loan, I’m invisible.” 

– Prospective homebuyer, Freddie Mac ethnographic research

“I’ve been through a lot even outside of this. As much 

as I’ve been through with this process, yeah I’m angry 

and it left me jaded, but I’ve been through worse.” 

– Prospective homebuyer, Freddie Mac ethnographic research

EQUITABLE HOUSING FINANCE PLAN 14
SECTION 3

Plan Overview Many barriers to equity affect individuals and communities in unique ways 

and must be addressed directly. Others are systemic and must be addressed

broadly through efforts that can reform fundamental aspects of housing

In our Equitable Housing Finance Plan, we take both a direct 

approach—through Special Purpose Credit Programs and other 

means—and a systemic approach—through broader efforts such as helping 

to address the affordable housing supply shortage or establishing new 

standards in opportunities for renters. We must pursue both approaches to

effectively address housing cost burden and limitations in housing choice 

and opportunity disproportionately experienced by Black and Latino renters 

and homeowners. Through combined efforts, we can reduce the impact

of individual and institutional discriminatory policies and practices and bring 

real change to the housing market
Plan Overview

Address the Homeownership Gap

Freddie Mac will address the homeownership 

gap for Black and Latino borrowers through 

responsible and impactful initiatives that expand 

access to credit, implemented primarily through 

Special Purpose Credit Programs

1 Address Systemic Underinvestment 

within Formerly Redlined Areas

The vestiges of legalized redlining remain, 

evidenced by underinvestment and undervaluation 

within many Black and Latino communities 

nationwide. We will strengthen support for

underserved renters and multifamily borrowers, 

expanding financing for affordable housing 

developers and helping Community Development 

Financial Institutions funds (CDFI), minority 

depository institutions (MDI) and smaller banks 

with improved access to capital

2 Finance the Creation and 

Preservation of Affordable Housing

The profound shortage of affordable housing in 

the U.S. disproportionately affects Black and Latin

households. As a result, high rents and high home

prices depress the ability to access opportunities for 

social and economic mobility. Freddie Mac plans to

leverage private, global investments to create and 

preserve vital, affordable housing. These efforts

will consider the need to preserve — and not 

displace — the communities intended to benefit 

from new investments

3

Increase Opportunities for Renters

Too often renters have fewer opportunities than 

homeowners for social and economic mobility

This gap disproportionately affects Black and 

Latino households. Freddie Mac will increase

opportunities for renters at multifamily properties 

and from within renters’ communities. Efforts will

focus on mainstreaming financial empowerment, 

wealth building opportunities, tenant protections 

and resident services for renters within Freddie 

Mac financed rental communities and ultimately the 

multifamily industry at large

4 Eliminate Disparities Among Members 

of Black and Latino Communities 

Freddie Mac’s ethnographic research surfaced 

the wide array of disparities reported by Black and 

Latino communities. We commit to (re)building trust

in the housing ecosystem, as demonstrated by 

our actions and by inviting the experiences of Black 

and Latino communities into our approach

For example, we will create opportunities and 

access to capital for emerging diverse multifamily 

developers, in order to increase wealth-building 

opportunities and enhance the ability for people 

to invest in and grow their communities. We will

continue to set standards in both renter support 

and renter protections

5

EQUITABLE HOUSING FINANCE PLAN 16
SECTION 4

Special Purpose 

Credit Programs This section of our Equitable Housing Plan demonstrates our targeted 

approach through Special Purpose Credit Programs (SPCPs) that are 

necessary to address mortgage lending barriers and eliminate disparities 

facing Black and Latino homebuyers and renters
Market Challenges and Barriers

As a result of residential segregation and lack of access to credit, it is increasingly difficult 

for historically underserved communities to build wealth through homeownership. The

gaps between white and Black homeownership rates today are the largest since 1890, 

at a 30+ percentage point difference. According to the Home Mortgage Disclosure Act

(HMDA) data, conventional loan denial rates in 2020 were 25 percent for Black applicants, 

19 percent for Latino applicants and 12 percent for non-Latino white applicants

33

The ECOA allows for-profit and not-for-profit organizations to develop SPCPs to 

expand access to credit to a class of persons who, under the organization’s traditional 

standards of creditworthiness, would not be able to obtain credit or would receive 

it on less favorable terms than are customary. Under an SPCP, characteristics that are

otherwise prohibited in considering the extension of credit, such as race and ethnicity, 

can be considered, provided the organization has conducted an assessment and found 

evidence of a special social need for this class of persons, and provided that the need 

is tied to the organization’s customary credit standards. An SPCP may include benefits,

such as down payment assistance, reduced pricing, or expanded credit eligibility. As the

U.S. Department of Housing and Urban Development (HUD) recently clarifie

SPCPs offered by non-profit organizations to serve economically disadvantaged 

classes and those offered by for-profit organizations to meet special social 

needs that are carefully tailored and targeted to meet ECOA and Regulation B’s 

specifications will generally not “discriminate” within the meaning of the [Fair 

Housing] Act, just as they do not constitute discrimination under ECOA

34

A well-designed SPCP offers the opportunity to address special social needs, such as 

the homeownership gap for minority borrowers, and to provide liquidity to historically 

redlined areas that remain underserved

33 2020 Home Mortgage Disclosure Act (HMDA) data

34 HUD, Office of General Counsel Guidance on the Fair Housing Act’s Treatment of Certain Special Purpose Credit 

Programs That Are Designed and Implemented in Compliance with the Equal Credit Opportunity Act and Regulation B, 

December 6, 2021 Available at https://www.hud.gov/sites/dfiles/GC/documents/Special_Purpose_Credit_Progra

OGC_guidance_12-6-2021.pd

According to the Home Mortgage Disclosure Act 

(HMDA) data, conventional loan denial rates in 2020 

were 25 percent for Black applicants, 19 percent for 

Latino applicants and 12 percent for non-Latino white 

applicants.33

EQUITABLE HOUSING FINANCE PLAN 18
Our Actions

Freddie Mac plans to purchase loans originated through SPCPs. Our initial research

supports identifying a special social need for the following borrower communities: (a) 

Black or African American, (b) Latino and non-white Latino, (c) American Indian or Native 

American and (d) borrowers in census tracts with a non-white population greater than 50 

percent

35 Our purchase of SPCP loans, and our own SPCP development, make SPCPs 

a key strategic tool to expand homeownership for these underserved communities. In

addition to a commitment to purchase SPCP loans and design our own SPCP program, 

we commit to partnering with lenders and community organizations through targeted 

marketing and outreach to ensure the success of SPCPs to increase homeownership for 

Black and Latino families

Action 1: Purchase SPCP Loans

There is a growing interest among lenders in originating loans under an SPCP and selling 

the loans to Freddie Mac. We plan to purchase loans originated through lenders’ SPCP

If necessary, we will review lender SPCPs and establish terms of business (TOBs) that 

will permit lenders to sell us loans originated under their SPCPs. We also may update

the Freddie Mac Single-Family Seller/Servicer Guide (Guide) to include requirements for 

selling loans originated under a lender SPCP

Action 2: Offer Freddie Mac SPCP

Freddie Mac has prepared a model SPCP written plan for any SPCP we may design and 

will begin implementation planning in 2022. We will develop and implement an SPCP

program that offers some or all the following benefits: (a) down payment assistance, 

(b) improved pricing/reduced fees, (c) expanded underwriting, (d) reserve funds for 

borrower hardship and (e) expanded loan servicing to an identified class of borrowers 

35 Lenders may identify other special social needs with supporting evidence that warrants the formation of a well-designed 

SPCP

with special social needs. Some specific SPCP features we have identified as initial

priorities are detailed below in Sections 4.1 through 4

We are also continuing to research how best to structure and implement an SPCP 

program for optimal impact, including:

• Refining geo-targeting strategy – Freddie Mac is exploring SPCP geo-targeting 

strategies, such as targeting Majority Minority Census Tracts (MMCTs)

o Targeting geographies based on home loan origination activity – for example, 

independent mortgage banks and credit unions have doubled their share of all 

purchase loans to Black borrowers over the past decade

36 We need to better 

understand how to leverage and scale these successes

o Targeting geographies that have above-average concentration of mortgage-ready 

Black and Latino renters

o Targeting geographies based on key economic indices – multiple existing 

economic indices categorize census blocks based on key special needs. For

example, the Area Deprivation Index (ADI) allows for rankings of neighborhoods 

by socioeconomic disadvantage in a region of interest (e.g., at the state o

national level)

37 It includes factors for the theoretical domains of income, 

education, employment, and housing quality. The ADI is one of many indices that

Freddie Mac may utilize as a geographic targeting tool to reach Black and Latino 

populations more efficiently than by using MMCTs

• Targeting individuals instead of geographies – Freddie Mac may make its SPCP 

program accessible to anyone who self-identifies as Black, Latino or American Indian/

Native American. Another demographic to explore is the first-generation homebuye

Freddie Mac continues to evaluate potential special social needs, as well as the risks 

and operational challenges posed by this type of targeting

• Leveraging trustworthy channels – Freddie Mac’s ethnographic research 

underlined the importance of borrower trust in delivering successful SPCP programs

We will explore opportunities to market Freddie Mac SPCPs through new channels 

that more effectively reach Black and Latino communities

36 https://www.urban.org/sites/default/files/publication/101849/the20potential20and20limits20of20blackowned20banks_0.

37 https://www.neighborhoodatlas.medicine.wisc.

Our initial research supports identifying a special 

social need for the following borrower communities: 

(a) Black or African American, (b) Latino and non-white 

Latino, (c) American Indian or Native American and 

(d) borrowers in census tracts with a non-white 

population greater than 50 percent. 

35 Lenders may identify other special social needs with supporting evidence that warrants the formation of a well-designed 

SPCP

EQUITABLE HOUSING FINANCE PLAN 19
Goals

Period Key Action Items Goals 

Year 1 – 2022 Purchase loans originated under lender SPCPs: 

• Identify and address operational components of purchasing a SPCP loan

• Purchase SPCP loans from lenders

Offer Freddie Mac SPCP to Lenders: Develop Freddie SPCP written plan

• Refine targeting/geo-targeting affirmative strategy

• Develop plans for scalability by promoting lender participation in 

Freddie Mac’s SPCP

• Develop plans to promote adoption of Freddie Mac’s model SPCP to enable 

small lenders to participate

• Monitor and analyze available data to find ways to improve the program

• Stand up a framework for SPCPs that will include policy development, analytics, 

market outreach, internal and external governance and publication of Guide 

updates, if necessary

• Develop (and launch) robust marketing plan to support any Guide updates for 

the SPCP in 2022

• Develop robust training resources for Sellers to support Guide updates for the 

SPCP in 2022

• Develop baseline projection of SPCP purchase volume for 2023

Year 2 – 2023 • Monitor and analyze available data to find ways to improve the program

• Securitize SPCP loans into social bonds

• Provide liquidity for SPCP loans

• Promote adoption of SPCP among lenders

• Promote SPCP options through channels trusted by Black/Latino communities

Year 3 – 2024 • Monitor and analyze available data to find ways to improve the program. • Provide liquidity for SPCP loan

• Promote adoption of SPCP among lenders

• Promote SPCP options through channels trusted by Black/Latino communities

EQUITABLE HOUSING FINANCE PLAN 20
4.1: Pricing: Single-Family Loan-Level Price Adjustments

Market Challenges and Barriers

Freddie Mac and Fannie Mae (the GSEs) use loan-level price adjustments (LLPAs) to 

determine the fees they charge a lender for a loan they purchase. LLPAs consider several

credit characteristics, including a borrower’s credit score and loan-to-value (LTV) ratio. As

Black and Latino borrowers on average have lower credit scores and lower levels of cash 

for down payments, their corresponding LLPAs may be higher

Freddie Mac Home Possible®, our flagship affordable loan offering, caps LLPAs to reduce 

fees for low-income borrowers. Borrowers with LTVs greater than 80 percent and FICO

Scores38 greater than 680 need no LLPAs — the majority of Home Possible borrowers pay 

$0 in LLPAs. In addition, LLPAs for borrowers with FICO Scores below 680 are capped at a

level also well below what they would be under the broad LLPA fee levels in the Guide. The

Black and Latino share of Home Possible borrowers is disproportionately higher than the 

Black and Latino share for non-Home Possible offerings

LLPAs are critical drivers of Freddie Mac’s ability to (a) provide liquidity to mortgage 

markets in a safe and secure manner and (b) promote lending to low- and moderateincome borrowers. LLPAs allow us to establish pricing that covers the risk of our loan

purchases while cross-subsidizing that risk to help fulfill our Charter responsibilities and 

equity commitments

We also plan to explore pricing incentives to support origination to low-balance, 

first-time and/or non-traditional borrower financial situations. Regulations prohibit

compensation based on loan products or features and cap fees, which can offset 

origination costs. Fees and compensation are usually a fixed percentage of the

loan amount and are only realized if the loan closes. As a result, originators may be

disincentivized to take on smaller loans, inexperienced borrowers, alternative sources of 

credit and income and/or down payment assistance programs, complexities making a 

loan more costly to manufacture and with a higher rate of fall-out

38 https://www.fico.com/en/products/fico-sco

Our Actions

Freddie Mac plans to evaluate changes to our LLPA structure, including minimizing LLPAs 

for SPCP loans, to help us achieve our equity objectives, while ensuring we operate in 

a safe and sound manner. We are also exploring pricing changes to incentivize more

lending at low loan balances. We will further engage with lenders and conduct deeper

analysis to understand how our pricing construct can be better optimized to support 

more lending to first-time homeowners

Goals

Period  Key Action Items  Goals  

Year 1 – 2022  • Evaluate changes to our LLPAs 

to support Equity goals

• Evaluate pricing changes to 

incentivize lenders to originate 

low-balance loans

• Propose LLPA changes 

for SPCP by year end

Year 2 – 2023  • Analyze data and continue 

to refine LLPAs as needed

• Quarterly monitoring 

and reporting

Year 3 – 2024  • Analyze data and continue 

to refine LLPAs as needed

• Quarterly monitoring 

and reporting

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 21
4.2: Mortgage Insurance Cost Reduction

Market Challenges and Barriers

The ongoing cost of mortgage insurance (MI) adds to the cost of homeownership for 

borrowers with loans with LTV ratios greater than 80 percent. This particularly impacts

lower-income borrowers, who are disproportionately Black and Latino. For example,

Black homeowners on average pay $550 more per year on mortgage insurance 

premiums, compared to white homeowners, resulting in a potential reduction in 

retirement savings of over $23,000

39

Our Actions

Freddie Mac plans to work with mortgage insurers and industry partners to build a new 

program to reduce MI costs for high-LTV borrowers in historically underserved segments 

of the markets, through an SPCP

Goals

Period Key Action Items Goals 

Year 1 – 2022 • Explore development of a program 

to reduce the cost of MI and the 

borrower’s overall closing costs

• Complete analysis of 

opportunities to reduce 

MI costs

39 The Unequal Cost of Black Homeownership: https://gcfp.mit.edu/wp-content/uploads/2020/10/Mortgage-Cost-forBlack-Homeowners-10.1

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 22
4.3: Single-Family Title Insurance Cost Reduction

Market Challenges and Barriers

Freddie Mac requires clean title for all mortgages, which lenders almost always satisfy 

with a title insurance policy. Title insurance is a significant part of the borrower’s cashto-close. The policy premium is usually the largest closing cost, and these costs ar

disproportionately felt by Black and Latino borrowers

Title insurance policies, attorney opinions of title and certificates of title (collectively 

“policies”) insure that title to real property is held by the person(s) identified in the 

deed, with a lien by the lender shown on the mortgage. Policies are underwritten by

conducting title examinations prior to closing the mortgage loan. We require policies to

be delivered with every mortgage

Policies are expensive, averaging over one percent of the loan amount, and most 

consumers do not shop for lower rates, even when they are available. Furthermore,

smaller-balance loans pay relatively higher rates

Complete failure of title is extremely rare and usually leads to Seller/Servicer remedy

Refinances, in particular, present less risk, as major title problems should have been 

cured at purchase and the incremental risk of title defects arising between purchase and 

refinance is small

Our Actions

We are working with the industry to determine how we might lower the cost of title 

insurance, especially for low-balance loans

Goals

Period Key Action Items Goals

Year 1 – 2022 • Explore lower cost title solutions with the industry • Develop lower cost title solutions by year-end 2022

Year 2 – 2023 • Initial roll-out of lower cost title solutions. • Support origination of 5,000 loans with lower cost title solution

Year 3 – 2024 • Evaluate expanding and tie in to SPCP. • Expand progra

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 23
4.4: Automated Collateral Evaluation Expansion

Market Challenges and Barriers

As discussed in Section 2.3, Freddie Mac’s research concluded that appraisal gaps,

which negatively impact Black and Latino borrowers and homeowners, exist on purchase 

appraisals

40 Further, our analysis shows that leveraging Home Value Explorer® (HVE) 

and Automated Collateral Evaluation (ACE) leads to relatively lower gaps. ACE offers a

prudent automated collateral valuation alternative to appraisals. Freddie Mac currently

permits ACE for certain purchase transactions with LTV ratios up to 80 percent, however, 

most Black and Latino borrowers have LTVs greater than 80 percent

Our Actions

Using automated tools to establish home values helps remove human bias, although 

it limits the collection and evaluation of a property’s current condition. Freddie Mac is

exploring expanding its policy to allow ACE for purchase transactions with higher LTV ratios 

with risk mitigants such as an onsite property data report or home inspection for SPCPeligible borrowers, which should mitigate appraisal gaps for Black and Latino borrowers

ACE leverages HVE combined with a property condition model and other algorithms 

for consistent and effective results. ACE relies on statistically based, empirically derived

confidence scores. Similar confidence scores are not available in appraisals. Expande

use of ACE offers an opportunity to mitigate human bias in traditional appraisals

Leveraging ACE,

• Provides sustainable access to credit

• Reduces borrower closing costs (ACE saved consumers $293M over a six-month 

period). Appraisal fees can range between $600 and $2,000

• Mitigates impacts associated with appraisal gaps. HVE values lead to lower

value gaps

• Reduces time to originate a loan (translates to potential reductions to borrower’s 

interest rate/points)

40 http://www.freddiemac.com/research/insight/20210920_home_appraisals.pa

Goals

Period Key Action Items Goals

Year 1 – 2022 • To begin in Year 2 – 2023

Year 2 – 2023 • Evaluate expanding ACE 

availability on purchase 

transactions with > 80% LTV

• Evaluate SPCP viability to reduce 

appraisal costs for historically 

underserved borrowers

Year 3 – 2024 • Monitor performance. • Ensure key metrics are within

expectations and rationalize further 

scale. Adjust accordingl

• Reduce appraisal costs for 

historically underserved borrowers 

pending policy deployment

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 24
4.5: Reserve Fund

Market Problems and Barriers 

Freddie Mac’s commitment to sustainable homeownership includes plans to implement 

one or more reserve funds to improve mortgage default performance for Black and Latino 

homeowners. Borrowers without several months’ worth of personal cash reserves, as

is often the case for first-time homebuyers who’ve depleted their savings to acquire 

their home, are not well positioned to weather unexpected income or expense shocks

When such financial shocks are temporary, the availability of access to a reserve fund 

could significantly improve a borrower’s ability to retain homeownership. Freddie Mac is

committed not only to getting more minority borrowers into homes, but keeping them in 

those homes, growing wealth for their families

Reserve funds may reduce credit impacts and defaults during temporary hardship and 

enable servicer intervention before missed payments. Freddie Mac is analyzing reserve

fund options that include permitting withdrawals for a missed or partial mortgage payment, 

to fund a home repair, or for a medical emergency that caused a temporary hardship

If such reserve funds reduce defaults as intended, we will assess whether reserves 

could be used as an underwriting risk offset, to expand access to credit and/or reduce 

acceptance-rate disparities

“If I ran into trouble? Cry. I would just have to figure 

it out. I definitely cannot handle more expense.” 

– Homeowner, Freddie Mac ethnographic research

Our Actions

Freddie Mac is evaluating different reserve fund structures and funding alternatives

Goals

 Period Key Action Items Goals

Year 1 – 2022 • Continue analyzing reserve 

fund implementation 

options, challenges and 

timeline

• Implementation planning 

for SPCP component with 

reserve fund feature

• Continue analysis of lendercreated products with 

reserve funds

• In concert with development 

of sustainable bond 

framework, continue analysis 

of investor/donor appetite 

for UMBS-linked reserve 

funds

• Establish a viable framework for a 

reserve fund(s)

Year 2 – 2023 • Continue performance 

analysis

• Implement an SPCP component 

permitting use of reserve fund 

withdrawals

• Link a reserve fund to Sustainable 

Bond Program, if Year 1 analysis 

supports doing so

• Performance reporting on loans 

supported by reserve funds

Year 3 – 2024 • Continue performance 

analysis

• Performance reporting on loans 

supported by reserve funds

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 25
4.6: Servicing for Sustainability (Single-Family)

Market Challenges and Barriers

When a borrower faces financial hardship — absent early intervention — they may 

become delinquent. Borrowers could benefit from specific training, counseling and tools

that may not currently be available to them, or that they may be unaware of

Financial hardships more deeply impact Black and Latino families because, on average, 

white families have eight times the wealth of Black families and five times the wealth 

accumulation of Latino families. Additionally, the average white family is more likely to

report having friends or family who could give them $3,000 compared to Black and 

Latino families

41

Some borrowers are not aware of loss mitigation programs that exist to help them to 

overcome delinquency problems. Sustainable homeownership is also built upon trust

between the homeowner and the Servicer/financial institutions — and these relationships 

can be challenging at times. Borrowers who may not fully trust their Servicer are less likely

to proactively engage with them to request assistance in the event of a financial hardship

A missing payment causes a delinquency that is reported both to Freddie Mac and to the 

credit repositories

41 https://www.federalreserve.gov/econres/notes/feds-notes/disparities-in-wealth-by-race-and-ethnicity-in-the-201

survey-of-consumer-finances-20200928.ht

“When I had my first home, I was so excited... 

[my mortgage] was cheaper than my rent... then had 

repairs after a hurricane, then had to dig up the ground 

to fix plumbing. I didn’t have an emergency fund so 

had to work overtime to get stuff fixed.”

– Former homeowner, Freddie Mac ethnographic research

Our Actions

Freddie Mac is reevaluating its servicing policies to better improve borrower outcomes, 

particularly for Black and Latino homeowners, with a goal of implementing improvements 

through an SPCP

Action 1: Special Servicing Framework

Freddie Mac is evaluating a servicing strategy that would maximize effectiveness of 

servicing by providing tailored outcomes to reduce expected default rates for certain 

targeted loan populations. This strategy may include special servicing to offer servicing

and loss mitigation support for borrowers in this program and may include loss mitigation 

decisioning based on the individual circumstances of each mortgage and borrower, as 

opposed to more general and globally applied servicing provisions

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 26
Action 3: Loss Mitigation, Borrower Outreach, Education and Counseling

Freddie Mac is considering a wide range of options in the servicing space to improve 

home retention outcomes for Black and Latino families, while balancing Freddie Mac’s 

safety and soundness

Freddie Mac currently offers both borrower- and servicer-facing educational resources

For example, Freddie Mac Home Possible® Mortgages are eligible for certain advantages, 

including a welcome letter, early delinquency counseling and, in certain rural areas, 

NextJob counseling services. Servicers are subject to detailed outreach requirements and

must share information about loss mitigation options to delinquent borrowers

Freddie Mac plans to analyze its servicing policies to ensure that loans originated under 

its SPCP have successful outcomes, through potential policy changes including, but not 

limited to, the following:

• Expanded Home Possible outreach and counseling opportunities

• Enhanced educational materials

• Adjustments to charge-off policies

• Eliminated/reduced 3rd party valuations in loss mitigation and servicing

• Updates to Mortgage Insurance cancellation requirements

• Updates to borrower-facing documents (e.g., solicitation letter

Freddie Mac also plans to leverage/expand existing policies and outreach tools 

that have proven valuable, such as:

• Add loss mitigation disclosure/flyer to origination package and monthly statements

• Create voluntary annual “homeownership training” classes

• Enhance borrower education during months when borrower is more likely to skip a 

payment

• Host borrower education sessions in places in the community where a borrower feels 

comfortable/maximize trust

• Share borrower education resources with Employee Assistance Programs within 

organizations to enable them to support delinquent borrowers

Action 2: Automatic Payment Deferral

Freddie Mac recognizes that borrowers impacted by a temporary financial hardship 

may need access to payment deferral options, so we are exploring permitting certain 

borrowers to be eligible for automatic deferrals of monthly mortgage payments 

that would otherwise cause the borrower to become delinquent. Freddie Mac has

introduced payment deferral options in the past for borrowers impacted by natural 

disasters and COVID-19. Freddie Mac plans to leverage the lessons learned from those

programs, including working with Servicers to find new ways to avoid some of the 

problems associated with temporary delinquencies. For example, offering temporary

principal and interest deferral to a borrower prior to the borrower becoming 30 days 

delinquent permits the borrower to remain current on the loan. The primary difference

with this proposed payment deferral option is that it would be executed automatically 

before the mortgage ever becomes a full month delinquent

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 27
Goals

Period Key Action Items Goals

Year 1 – 2022 • Develop draft program parameters and evaluate potential effectiveness to 

determine whether to pursue a Special Servicing Framework

• Refine Automatic Payment Deferral offering and determine (a) offering 

eligibility and (b) securitization impacts

• Identify tangible servicing improvements for potential implementation

• Complete analysis to understand automatic payment deferral benefits for defined eligible 

population

• Finalize decision on viability for Special Servicing Framework and Automatic Payment 

Deferral approach

Year 2 – 2023 • Develop Special Servicing Framework

• Establish success measures for enhanced policies and evaluate effectiveness

• If analysis shows viability, launch Special Servicing Framework and Automatic Payment 

Deferral

Year 3 – 2024 • Continue to evaluate outcomes. • Successful rollout of servicing improvements, contributing to improved servicing outcomes

for Black and Latino borrowers

  

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 28
4.7: Increase Diverse Multifamily Borrowers’

Access to Capital

Market Challenges and Barriers

For borrowers in the multifamily housing industry, access to capital is one of the most 

important ingredients for success. However, borrowers that are controlled by or owned

by a certain percentage of minorities, women, persons with disabilities, veterans and 

those who identify as LGBTQ (collectively known in this context as diverse borrowers) are 

believed to have less access to capital and are underrepresented in the multifamily industry

This apparent unequal access to capital has continued to perpetuate the wealth gap, as well 

as a lack of diversity of borrowers in the multifamily housing industry

To increase access to capital for diverse borrowers in the multifamily housing industry, 

we need to understand what access to capital diverse borrowers currently have. With this

information, we will be better able to determine how to support them, including ways 

to directly target and develop diverse borrowers that are emerging in the industry. The

ability to execute on both targeted loan transactions and securitizations would increase 

access to capital for diverse borrowers and enable Freddie Mac to channel impactmotivated bond investors with specific investment criteria to direct their capital towards 

diverse borrowers and their communities

“Impractical liquidity and net worth requirements... 

exclude highly qualified prospective borrowers of color.”

– Respondent from Freddie Mac survey of Diverse Multifamily Borrowers

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 29
Action 2: Diverse Borrower Specialized Offerings or Programs

We will explore the need for and viability of SPCPs or other products designed to meet 

the needs of emerging diverse borrowers to grow and scale their businesses

As we gain a better understanding of the needs and opportunities for emerging diverse 

borrowers, we will be better able to develop specific offerings or programs to increase 

access to capital

Action 3: Create Path for Diverse Borrower Specialized Offerings or Programs to 

Back Social Bonds or Other Alternative Execution Vehicles

We will expand disclosures in a standardized, anonymized format. These disclosures will

enable social impact motivated investors to meet their investment criteria

Our Actions

To increase access to capital for diverse borrowers through Freddie Mac, we intend to 

take the following three key actions:

Action 1: Diverse Borrower Marketing and Outreach

Under our outreach strategy, we will network and provide relationship management, 

support and resources to help diverse borrowers scale business operations. We will lead

round tables and other ongoing, continuous outreach efforts to quantify feedback. Our

outreach to CDFIs, MDIs and SFIs mentioned throughout our Equitable Housing Finance 

Plan will augment this outreach, as these institutions often serve a high concentration of 

diverse borrowers. Our goal is to build new relationships and shed light on the need for

SPCPs or other products to meet emerging diverse borrowers’ needs to more easily get 

deals done with Freddie Mac Multifamily

“Starting a business from scratch is tough. 

Especially tough when trying to meet loan [financial] 

requirements as a first-generation business owner.”

– Respondent from Freddie Mac survey of Diverse Multifamily Borrowers

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 30
Goals

Period Key Action Items Goals

Year 1 – 2022 Marketing and Outreach:

• Continue outreach efforts through individualized calls and touchpoints

• Establish relationship management resources at Freddie Mac for diverse and emerging diverse 

borrowers

• Track success through volume captured from this cohort and opportunities to scale this effort

Specialized Offerings or Programs: 

• Leverage ongoing surveys, outreach and self-testing efforts to determine effectiveness of a 

specialized offering

• Determine what is scalable and propose a program or loan product

Social Bonds or Alternative Execution Vehicles: 

• Explore modifying pooling practices for loans made to diverse borrowers to enable us to eventually 

develop Capital Markets executions and improve the liquidity needed for us to better serve these 

specialized programs targeting diverse borrowers

 Marketing & Outreach: 

• Host at least two networking events to promote partnership and 

connections

Specialized Offerings or Programs:

• Develop framework for first specialized transaction by year-end 2022

Year 2 – 2023 Marketing and Outreach:

• Continue ongoing relationship management resources for diverse and emerging diverse borrowers

• Track success through volume captured from this cohort and opportunities to scale this effort

Specialized Offerings or Programs:

• Execute proposed program(s) or loan offering(s)

• Explore additional programs

Social Bonds or Alternative Execution Vehicles:

• Start developing a path and appropriate Capital Markets execution for newly created diverse 

borrower programs to be included in social bonds to improve liquidity for these program(s)

Marketing & Outreach: 

• Host at least two networking events to promote partnership and 

connections

Specialized Offerings or Programs: 

• Launch diverse borrower program or loan offering and complete 

transactions

Year 3 – 2024 Marketing and Outreach:

• Continue ongoing relationship management resources for diverse and emerging diverse borrowers

• Track success through volume captured from this cohort and opportunities to scale this effort

Specialized Offerings or Programs:

• Execute proposed program(s) or loan(s)

• Explore additional programs

Social Bonds or Alternative Execution Vehicles:

• Launch an appropriate Capital Markets execution path for diverse borrower programs either 

through social bonds or other appropriate vehicles

 Marketing & Outreach:

• Host at least two networking events to promote partnership and 

connections

Specialized Offerings or Programs:

• Increase transactions within specialized offerings or programs

Social Bonds or Alternative Execution Vehicles:

• Launch Capital Markets execution for diverse borrower programs.

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 31
SECTION 5

Targeted 

Outreach and 

Interventions 

This section of our Equitable Housing Finance Plan demonstrates our 

targeted outreach and intervention solutions that address the 

homeownership gap, increase and improve the quality of affordable 

housing supply for Black and Latino homeowners and renters and 

address systemic underinvestment within formerly redlined areas
5.1: Promote Down Payment Assistance Tools with

Industry Partners Serving Black and Latino Communities 

Market Challenges and Barriers

Saving for a down payment remains a significant barrier for Black and Latino borrowers

White families are more likely to report the ability to obtain $3,000 from a family or friend 

(71.9 percent) compared to Black (40.9 percent) and Latino (57.8 percent) famil

42 

Our Actions

Freddie Mac plans to address the need for down payment assistance for Black and Latino 

borrowers by developing a digital platform, “DPA Tool” to maximize down payment 

assistance program utilization nationwide and to increase incremental originations by 

seamlessly connecting and matching down payment assistance programs, lenders, 

counselors and borrowers. Freddie Mac will continue its efforts to drive down payment

assistance utilization, standardization and funding. We plan to promote the DPA Tool

with industry partners serving Black and Latino communities to increase utilization of 

down payment programs — affinity trade associations, nonprofit housing organizations, 

housing counselors, housing advocates and consumer groups

42 https://www.federalreserve.gov/econres/notes/feds-notes/disparities-in-wealth-by-race-and-ethnicity-in-the-201

survey-of-consumer-finances-20200928.ht

“There are a lot of ways [white] people get help 

getting approved for mortgage that minority groups 

don’t have access to, like a friend or family member 

transferring money to your account.”

– Former Homeowner, Freddie Mac ethnographic research

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 33
Goals

Period Key Action Items Goals 

Year 1 – 2022 • Evolve the loan officer experience of the DPA tool through development efforts. • Incorporate 45 state Housing Finance Agencies’ down payment assistance programs into

the tool

• Incorporate 20 select high-volume local and municipal down payment assistance provider 

programs nationwide into the tool

• Launch loan officer and down payment assistance provider functionality in market by 

year-end 2022

• Raise awareness of the tool to 15 national organizations serving Black and Latino 

communities

Year 2 – 2023 • Engage with community partners to drive use of DPA Tool to benefit Black and 

Latino borrowers

• Explore opportunities to standardize down payment assistance requirement 

standards for the industry

• Expand down payment assistance provider and loan officer participation

• Establish DPA Tool utilization baseline metrics within targeted communities

• Research and develop a national common “DPA” offering supported by the DPA Tool, 

standardized subordinate lien documents and standardized data

Year 3 – 2024 • Continued engagement with community partners to drive use of DPA Tool

• Evaluate DPA Tool effectiveness in addressing needs of borrowers, community 

partners and lenders

• Further expand DPA Tool utilization with targeted communities

“In a lot of markets, the incremental savings from renting 

may never amount to the down payment needed to afford 

a home, so renting to owning is not a feasible path.” 

– Survey respondent, Freddie Mac ethnographic research

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 34
Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

5.2: Finance Housing for Persons with Intellectual

and/or Developmental Disabilities 

Market Challenges and Barriers

Intellectual and Developmental Disabilities (IDD) can span many types of disabilities but 

are most often associated with developmental disabilities, cognitive or mental health 

challenges, or traumatic brain injuries. Individuals with mobility related IDD face a large

deficit in suitable housing. While 14 percent of all Americans have mobility disabilities,

2 percent of total housing units are accessible to these individuals

43 Additionally, people 

with IDD are often among those with the lowest incomes and face significant housingrelated discrimination

44

Before the Housing for IDD (HIDD) group home model first emerged in the early 2000s, 

the only options for families of individuals with IDD were placing their loved ones in an 

institutional setting or caring for them at home with limited to no support. Affordable

housing subsidies have long waiting lists and institutional settings have been found 

to offer inadequate care and quality of life for individuals with IDD

45 Because many 

residents are very low-income, they derive their rent and care payments from social 

security, Medicaid and/or other government programs. Among family members and

caregivers, there were small scale, local efforts to start group living, though these efforts 

had limited access to capital and were not standardized

Freddie Mac’s acquisition of loans secured by HIDD properties has been limited for 

several reasons. The first is increasing home prices, which push HIDD sponsors to buy

existing care providers instead of increasing the footprint of available homes. Second,

states have various funding approaches to Medicaid, and some states may simply 

lack the resources to place individuals in HIDD. Third, the HIDD loan product is new

and complex — which currently limits the lenders in our network (Optigo®) who can 

participate — and requires additional credit performance evaluation due to the unique 

nature of this product. Fourth, HIDD loans present increased capital and hedging risk as

they are held for investment on Freddie Mac’s balance sheet. Lastly, most HIDD homes

are owned by smaller operators/care providers with limited ability to meet minimum 

borrower net worth and liquidity requirements

43 BCG Analysis, JCHS, Census Bureau

44 American Association on Intellectual and Developmental Disabilities

45 American Association on Intellectual and Developmental Disabilities

EQUITABLE HOUSING FINANCE PLAN 35
Our Actions

Freddie Mac intends to leverage and scale our program to support more households 

and further attract Environmental, Social and Corporate Governance (ESG)-minded 

investment capital. Our HIDD program supports community-based, small-group living

environments for IDD residents. Borrowers under Freddie Mac’s HIDD loan program have

historically been owners of substantial portfolios of single-family homes that are leased 

to care providers. HIDD homes are distinguishable from other single-family homes only

by internal modifications that enable resident accessibility, such as wheelchair ramps and 

bathroom modifications

To further expand supply and address market obstacles, Freddie Mac’s priority is to 

continue providing liquidity for loans benefiting our existing HIDD borrowers who have 

proven ability to operate HIDD real estate and provide proper oversight of care providers 

and meet financial obligations. Freddie Mac will also endeavor to work with our Optigo

lenders to build new HIDD borrower relationships, seek transactions with established, 

reputable care providers who also own real estate and explore opportunities to finance 

HIDD transactions in traditional apartment communities and other residential settings 

that offer greater resident independence

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period Key Action Items Goals

Year 1 – 2022 • Work with Optigo lenders to build relationships with existing HIDD 

sponsors and seek out emerging sponsor and care provider relationships

• Complete at least one transaction

Year 2 – 2023 • Aggregate sufficient HIDD collateral for a second social bond offering. • Complete at least two transaction

• Issue a second social bond offering for HIDD loans

Year 3 – 2024 • Assess market opportunity for financing HIDD and other transactions 

serving individuals with IDD within apartment settings

• Complete at least three transactions

In June 2021, Freddie Mac issued $230 million in social bonds in the form of a pool of 

multifamily participation certificates (Multifamily PCs®) backed by 1,267 rental homes 

across 39 states and Washington, DC, for individuals with IDD. The properties provided

4,462 resident beds, approximately 90 percent being affordable to people making 

50 percent area median income (AMI). The HIDD social bond issuance was wellreceived by the market and is an execution that Freddie Mac intends to scale to continue

providing liquidity to this sector of the rental housing market. These expansive efforts,

however, depend on the market’s awareness of our offering

Freddie Mac has broadened awareness of this critical housing need within the mortgage 

banking and investor communities through the HIDD social bond issuance. Investors

are increasingly seeking such opportunities to invest in. We intend to expand the HIDD

program to purchase, pool and securitize social bonds with HIDD loans in a measured 

and strategic manner of the three-year horizon

EQUITABLE HOUSING FINANCE PLAN 36
5.3: Finance Permanent Supportive Housing for

Persons Who Formerly Experienced Homelessness

Market Challenges and Barriers

The U.S Department of Housing and Urban Development (HUD) estimates that

approximately 580,000 people were experiencing homelessness in the U.S. as o

January 2020, which represents a nationwide increase for the fourth consecutive year

46

Black and Latino individuals and families represent 39.4 percent and 22.5 percent of th

population experiencing homelessness, respectively, despite accounting for 12 percent 

and 16 percent respectively of the total U.S. population. HUD found that nearly 

percent of persons experiencing homelessness were concentrated in 4 states: California 

(28%/161,548 people); New York (16%/91,271 people); Florida (5%/27,487 people); 

and Texas (5%/27,229)

Of the 580,000 persons experiencing homeless in the U.S., HUD estimates that 7

percent experience homelessness as individuals while the remaining 30 percent 

experience homelessness as part of a family with at least one adult and one child under 

the age of 18. Nine in ten persons experiencing homelessness as families were sheltered,

however 51 percent of individuals experiencing homelessness were unsheltered. Per

HUD, there are more than 50,000 additional people facing unsheltered homelessness 

in 2020 relative to 2015. In fact, there are five major cities where more than 80 percent

of the homeless population is unsheltered, the California cities of San Jose, Los Angeles, 

Fresno, Oakland and Long Beach

Furthermore, there are 37,252 veterans experiencing homelessness in the U.S. whic

represents 8 percent of all adults experiencing homelessness — 98 percent of whom 

experience homelessness as individuals. Of those individuals, 27 percent (9,794

veterans) had chronic patterns of homelessness, which HUD defines as individuals with 

a disability who have been continuously homeless for one year or more or who have 

experienced at least four episodes of homelessness in the last three years where the 

combined length of time homeless on those occasions is at least 12 months

46 https://www.huduser.gov/portal/sites/default/files/pdf/2020-AHAR-Part-1.

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 37
Freddie Mac is experienced in working with localities to provide financing for longterm housing with rental assistance and services supporting persons who formerly 

experienced homelessness (Permanent Supportive Housing) in markets across the 

country. We have seen a growing trend of more states and localities looking to scale

these efforts. Despite the challenges and complexity of this issue, there are considerable

resources being allocated toward proven methods of addressing homelessness. For

example, California has committed $4.8 billion over the next two years to alleviate

homelessness, including funding for Permanent Supportive Housing. This provides not

only housing but also services including health care, mental health counseling, substance 

abuse treatment, and employment training. Research has demonstrated that Permanent

Supportive Housing provides an 88 percent decrease in homelessness relative to 

other programs47 and a median economic benefit of $17,016 per year, representing a 

societal cost savings of $1.44 for every $1 investe

48 By working directly with states and 

localities, Freddie Mac can leverage its capital, resources, and expertise to help address 

this critical issue and support and scale programs that potentially could be replicated in 

markets across the country

Our Actions

Leveraging our experience, we intend to take a multi-stage approach identifying and 

working with more states and localities to address homelessness and scale strategies that 

are effective at achieving long-term sustainable results

We will first conduct research to identify the markets that have the greatest need relative 

to their existing resources and have innovative programs with potential for scalable 

and replicable impact. Freddie Mac will then build the framework for a successful

strategy and identify at least one municipality to establish a program. Based on work in

this municipality and our experience, we will seek to replicate and expand our impact 

on a national scale. While we have worked in markets across the country on various

transactions, we anticipate that this focused and deliberate approach will lead to a 

deeper and greater impact over time and will help to establish new industry standards

47 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8513

48 https://www.thecommunityguide.org/findings/health-equity-housing-first-progra

Freddie Mac’s program will explore a variety of actionable steps to help finance more 

permanent supportive housing. We will evaluate opportunities to provide financing directly

to developers or provide liquidity to financial institutions that are directly involved in 

providing debt capital for permanent housing solutions. Examples to be explored include:

Project RoomKey — repurposing under-utilized real estate, and 833 Bryant in San Francisco 

— funding the development of innovative lower cost modular construction. Through our

efforts, Freddie Mac can continue to strengthen public-private partnerships by helping 

to scale nonprofits such as Step Up or Jamboree Housing that are actively seeking to end 

homelessness through permanent housing solutions

Goals

Period Key Action Items Goals

Year 1 – 2022 • Research and identify the 

markets with the greatest 

need

• Establish parameters 

and select one or 

more municipalities for 

collaboration

• Municipality-identified

Year 2 – 2023 • Implement program with 

municipal partner(s)

• Program roll-out in one 

municipality

Year 3 – 2024 • Analyze results and refine 

program parameters

• Expand program on a 

national scale

• Program roll-out nationally

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 38
Our Actions

Freddie Mac will explore policy and infrastructure improvements to expand market 

utilization of its renovation products, while focusing on safety and soundness

Specifically, our equity focus is on leveraging Freddie Mac’s leadership position in the 

industry to provide technical assistance to nonprofits, lenders, real estate professionals 

and homebuyers to increase renovation financing in Black and Latino communities

• Expand renovation financing

o Engage with community organizations and their lending and real estate partners 

to understand and address challenges and barriers to utilizing existing renovation 

products

o Focus on improving housing stock in Majority Minority Census Tracts (MMCTs) and 

historically redlined communities that remain underserved

o Promote the enhancement of existing housing stock in areas such as resiliency, energy 

efficiency, accessibility, ADU carve-outs and other maintenance-related priorities

o Provide education and outreach to lenders and consumers

o Expand Freddie Mac’s partnership among nonprofits, lenders, real estate 

professionals and homebuyers to facilitate the acquisition and rehabilitation 

of city-owned properties in MMCTs and historically redlined communities that 

remain underserved

5.4: Provide Technical Assistance on Renovation

Financing for Single-Family Homes in Traditionally 

Underserved Black and Latino Communities  

Market Challenges and Barriers

• Need for Renovation Financing Options Disproportionately Exists for Black 

and Latino Families. Over 25 percent of affordable single-family homes nationwide 

require moderate or significant rehabilitation, and communities of color are more 

likely to live in neighborhoods that historically have suffered from undervaluation 

and underinvestment. Freddie Mac research confirms that homes in Black and Latino

communities also are more likely than majority white communities to be appraised 

at values below contract price.

A vast majority of renovations that require financing are financed using credit cards 

(22 percent), personal loans (39 percent) or home equity (22 percent), and these 

financing options are typically more expensive than GSE-program loans. Yet even

through the use of traditional refinance mortgages, Black homeowners on average 

face higher mortgage interest rates after refinancing than white homeowners, both 

at similar income levels and when Black homeowners have higher income levels

49 

Affordable financing options can support Black and Latino homeowners to renovate 

and remain in their homes, thus improving the quality of homes in neighborhoods 

that have historically suffered from undervaluation.

Further, Black and Latino neighborhoods often correlate with neighborhoods most 

susceptible to the negative impacts of climate change, creating a potentially greater 

need for climate-resilient rehabilitation strategies

50

• Not User-Friendly. Freddie Mac’s market research suggests that the current first lien 

renovation ecosystem is not user-centric due to complexity and the extensive nature 

of the application process for financing, thus discouraging homeowners

51

• Need Will Continue to Exist for Affordable Renovation Financing. This is fueled by 

aging housing stock, demand for energy improvements, climate risks, the need for 

resiliency retrofits, growing demand for Accessory Dwelling Units (ADUs), the need for 

restoration of vacant and abandoned properties and accessibility accommodations

49 https://www.jchs.harvard.edu/blog/high-income-black-homeowners-receive-higher-interest-rates-low-income-whitehomeown

50 U.S. Natural Hazards Index from National Center for Disaster Preparedness, U.S. Census Bureau, 2020 Cen

Redistricting Data (Public Law 94-171) Summary File

51 Market participant interviews

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

49 https://www.jchs.harvard.edu/blog/high-income-black-homeowners-receive-higher-interest-rates-low-income-whitehomeown

50 U.S. Natural Hazards Index from National Center for Disaster Preparedness, U.S. Census Bureau, 2020 Cen

Redistricting Data (Public Law 94-171) Summary File

51 Market participant interviews

EQUITABLE HOUSING FINANCE PLAN 39
• Targeted marketing and training on Freddie Mac renovation products

o Develop training to ensure local organizations and borrowers fully understand the 

benefits and use of our renovation product offerings

o Provide marketing support to community organizations for bringing awareness 

to families about accessing renovation financing and receiving support from 

community partners with expertise in renovations

• Expand first lien renovation offering

o Expand Guide requirements for ADUs

Goals

Period Key Action Items Goals

Year 1 – 2022 • Explore expanding current partnerships in historically underserved Black and 

Latino communities to provide technical assistance to borrowers purchasing 

properties that need renovation in target markets

• Conduct a qualitative assessment on renovation financing challenges

• Examine new ways to provide liquidity to landbanks to turn vacant properties 

into affordable housing units

• Complete a qualitative housing stock assessment and identify renovation needs and types 

of property improvements that can help improve the quality of housing in historically 

underserved Black and Latino communities

• Establish new partnership with 2 to 5 landbanks

• Develop product enhancement recommendations based on the qualitative housing stock 

assessment

Year 2 – 2023 • Design and implement sourcing strategies to support renovation of aged 

inventory focusing on improving quality of housing units in targeted markets

• Expand partnerships with municipalities or landbanks that own a large 

number of aged and distressed inventory to bring inventory back into market 

as affordable housing stock

• Provide technical assistance, including targeted outreach, information, and resources, to 

support the renovation of housing units in Black and Latino communities

• Provide renovation financing training to 100 loan officers serving Black and Latino 

communities

• Educate at least 200 consumers on the renovation financing process

Year 3 – 2024 • Continue sourcing strategies to support renovation of aged inventory 

focusing on improving quality of housing units

• Expand partnerships with municipalities or landbanks that own many aged 

and distressed inventory to bring inventory back into market as affordable 

housing stock

• Provide technical assistance to support the renovation of 300+ SF housing units in Black and 

Latino communities

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

“Just a house free of mold, you know. A quiet 

neighborhood, where I can take my daughter for a 

walk without worrying about stepping on a needle”

– Homeowner, Alabama, Freddie Mac ethnographic research

EQUITABLE HOUSING FINANCE PLAN 40
Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

5.5: Expand Develop the Developer Program

to Include Small Multifamily Properties 

Market Challenges and Barriers

Formerly redlined communities, many of which remain underserved, are in many cases 

still undervalued and subject to underinvestment, affecting both community members 

and properties. The effects of discriminatory housing policy are still felt among Black

and Latino renters today in these areas and elsewhere as many practices prevented 

generations of families from gaining equity in homeownership, causing racial disparities 

in wealth. Continued underinvestment — and difficulty accessing capital — enable

housing to deteriorate and exacerbate disparities in life outcomes. In other cases, some

of these communities have experienced — or are about to experience — gentrification, 

often without the input of those living in the communities today

There is a need to preserve the housing stock for renters living in historically disinvested 

communities who are at risk of being pushed out of their neighborhoods due to 

gentrification and rising rent and home prices. An important aspect of addressing

both challenges is increasing opportunities for members of the community to become 

developers in their own communities — building wealth while building communities

The goal of our program — Develop the Developer (DTD) — is to spur reinvestment from 

within these communities to deter gentrification, create opportunities for wealth creation 

and generate the next class of emerging borrowers

Our Actions

We plan to increase redevelopment activity by expanding education and financing 

opportunities for emerging minority and female developers whose focus is on 

developing and redeveloping their own communities. Our DTD program, launched in

2020 with a focus on single-family properties, has been successful at supporting minority 

and female developers already in the process of starting new residential development 

projects that will provide mixed income housing in occupied by communities of color

The program so far has focused on developers of one-to-four-unit properties in the 

single-family housing space. However, in many communities, small multifamily properties

are vital forms of rental housing, an important part of the community, and a key entry 

point into multifamily property ownership and investment

Under our plan, we will extend the current DTD curriculum to target 5+ unit buildings in 

underserved communities of color. With the curriculum spanning 1-4 and 5+ units, our

“linked loan” offering (described below in Section 6.4) will enable the Freddie Mac DTD

platform to fully support these emerging developers as they grow and scale

We will start the program in select markets and expand over time as we better 

understand the unique needs and challenges new developers face in acquiring and 

rehabilitating small multifamily properties. Our enhanced program will help deter

gentrification and create wealth building opportunities for developers working in 

minority communities that are historically underserved and underinvested

To execute the program, we will bring in seasoned multifamily partners to provide 

funding, industry knowledge and advice to emerging developers. Participants will pitch

project proposals at the end of the course, which may be live or simulated transactions

The goal is to execute as many live transactions as possible

Goals

Period Key Action Items Goals

Year 1 – 2022 • Expand the DTD curriculum 

to include 5+ unit 

properties

• Identify initial market to roll 

out expanded program

• Expand curriculum

• Select initial market

Year 2 – 2023 • Launch program in initial 

market

• Analyze the effectiveness 

and ease of the DTD program 

in 2023

• Determine how the DTD 

program can be more 

scalable and effective

• Graduate at least 10 multifamily 

developers from the initial market 

course

Year 3 – 2024 • Introduce the DTD program 

in at least one additional 

market

• Graduate at least 10 multifamily 

developers from the second 

market’s course

EQUITABLE HOUSING FINANCE PLAN 41
5.6: Social Bond Issuance (Single-Family) 

In October 2021, Freddie Mac issued its first single-family UMBS backed entirely by 

Home Possible loans. Through creation of this new specified bond category, enabled

by the Special Eligibility Program (SEP) disclosures the GSEs implemented in August 

2021, we have made a key step toward establishing a single-family social bond issuance 

program. These disclosures, reported at the loan and pool levels, cover Home Possible,

Freddie Mac Refi PossibleSM and HFA Advantage®. Each offering has embedded benefits

for borrowers’ social impact

Pooling Approach

Investors have indicated specified bonds collateralized by affordable loans will meet 

current investor social bond requirements for certain investors. However, the ESG

market is rapidly evolving as investors look to establish bond scoring systems and ways 

of measuring the impact of their investments. Investors are beginning to set aside funds

to specifically invest in more narrowly defined communities. They want to drive access

and equity in housing, in addition to earning an economic return and having a positive 

reputational impact. Some investors have asked about Freddie Mac’s ability to pool

loans based on property and borrower characteristics we don’t currently disclose. These

characteristics include AMI, majority/minority census tracts, race/ethnicity and gender

Investors seem to agree to the extent social bonds are formed on criteria we currently 

don’t/can’t disclose at the loan and/or pool levels, transparency around collateral 

eligibility and pooling rules is paramount and will suffice

Freddie Mac’s initial approach is simple — begin with issuance based on current 

affordable products that have embedded borrower benefits and for which securities 

disclosures are available. Our SEP disclosures will help investors quickly identify

potentially eligible social investments. As the single-family ESG mortgage market

continues to grow size and sophistication, we will want to pool based on AMI, loans 

originated through SPCP and census tract (majority minority- or minority- census 

tract). Pooling on these more specific characteristics helps us direct capital towards

underserved markets to drive greater borrower outreach and impact. Following the

social bond principles of the widely used International Capital Market Association 

(ICMA) standards, Freddie Mac will publish a Single-Family Sustainable Bond Framework 

(including social bonds) that describes activities and/or offerings, in addition to how we 

plan to identify and manage proceeds.

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 42
Longer-Term Vision

A common theme from investor conversations has been that GSEs can set standards in 

this developing market. The role of securitization is to attract a broad, deep and durable

flow of capital into these products and programs. To do so, our best opportunity is to

leverage the liquidity of the UMBS market by pooling and disclosing securities that are 

deemed “TBA-deliverable” per the SIFMA Uniform Practices. Establishing social bonds

as another specified market within UMBS ensures that the pricing floor for any new 

programs is the UMBS cheapest-to-deliver level

Freddie Mac’s longer-term vision to enable our securities to drive additional borrower 

benefit is to segregate any incremental pay-ups (relative to TBA) from social bond 

investors. We could earmark proceeds for down payment assistance or for borrower

hardship assistance. We could also consider issuing corporate debt specifically

designated to fund the development of more loan offerings to meet the needs of 

underserved borrowers. Raising social corporate debt could also subsidize our social

products if the debt prices advantageously. Our expectation is that the marketplace and

Goals

Period Key Action Items Goals

Year 1 – 2022 • Finalize our Sustainable Bond Framework

• Obtain Second Party Opinion (SPO) from Sustainalytics on the framework

• Issue the Sustainable Bond Framework

• Continued analysis of potential corporate debt issuance to support Equity 

Program

• Plan for operationalizing Reserve Fund into Sustainable Bond Program

• Transition from issuing Affordable Bonds to issuing social bonds

• Issue $3 Billion in Affordable Housing Bonds

Year 2 – 2023 • Continue to purchase SPCP loans and issue social bonds with appropriate 

disclosures

• Continue to analyze and implement an optimal securitization strategy

• Securitize SPCP loans into social bonds

• Publish Impact Report (covering 2022 issuance and any relevant 2021 issuance)

Year 3 – 2024 • Continue to analyze and refine securitization strategy

• Update the Sustainable Bond Framework as needed

• Publish Impact Report

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

regulators will progressively raise the bar for how proceeds are managed and impact 

the borrower. To that end, we will work with the marketplace to add transparency to

the management of those funds, including the issuance of annual impact reports.

Freddie Mac will proceed by building out our baseline program of securitizing loans 

under existing and new lending programs. The GSEs’ scale and standard setting

ability should position us to lead the market in social bond issuance. Creation of new

loan and securities offerings and products to meet underserved borrower needs 

will help expand our reach and impact in the Sustainable Homeownership area. The

key to success will be understanding and meeting ever-expanding capital market 

requirements, while staying unquestionably within legal and regulatory boundaries.

EQUITABLE HOUSING FINANCE PLAN 43
5.7: Affirmative Marketing Plan

Our three-year marketing strategy is designed to help advance equity in housing finance 

and help decrease barriers to sustainable housing opportunities for both renters and 

future and current homeowners

While many of the problems and barriers laid out in this document are well known to 

policymakers and industry experts, a widespread lack of understanding remains among 

consumers and others. Therefore, our external communications strategy will accomplish

the following goals.  

Consumers

• Raise broad public awareness of the benefits of participating in the housing market 

through homeownership, refinancing, affordable renting and in other ways. 

• Educate, engage and empower consumers with financial capability tools tailored 

to their housing situation or needs (e.g., CreditSmart and My Hom

• Promote foreclosure prevention and disaster relief resources to increase 

sustainable homeownership

• Partner with various organizations, both inside and outside the housing ecosystem, 

to increase the effectiveness of our efforts

Industry

• Raise public and industry understanding of Freddie Mac products and 

initiatives that are designed to advance equity in the housing industry

• Increase awareness of approaches and activities that would help mitigate tight 

housing supply

• Promote research, data and subject matter expertise to expand understanding of 

the causes and solutions to issues challenging Black and Latino communities

“Sometimes it feels like you’re on an island by yourself.... 

In my family, I was the first homeowner, so it felt like I was 

just thrown into the sharks and it was terrible.”

– Former homeowner, Freddie Mac ethnographic research

Our Actions

Freddie Mac’s marketing activities will deliver a comprehensive, multi-channel marketing 

approach that aligns with focus areas outlined in this plan. Doing so will enable the

strategic engagement of desired audiences who can benefit from sustainable and 

equitable housing finance. Our marketing activities will include

• Message development

• External stakeholder outreach

• Outreach to consumers through media

• Enhanced digital communications using web, social media and email channels

• Educational tools and events for consumers

• Paid media opportunities

• Amplification in targeted communities nationwide

Marketing and Research 

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 44
Goals

Period Key Action Items Goals 

Year 1 – 2022 Develop a corporate-wide affirmative marketing initiative to reach underserved 

markets and consumers within those pre-defined markets we deem as high-impact 

opportunities, including:

• Education and Outreach

• Strategic Partnership and Community Engagement

• Products and Services

• Paid, Organic and Digital 

• Launch outreach campaigns on housing equity

• Launch consumer engagement and education programs, events and resources

• Measure those campaigns via uniform reporting

Year 2 – 2023 • Expand nationwide marketing campaigns and initiatives to reach more borrowers 

and underserved markets utilizing many of the key tactics stated in Year 1

o Continue to enhance marketing outreach in alignment with key focus areas and 

tactics outlined in this plan

• Same as above

Year 3 – 2024 • Further enhance marketing campaigns in alignment with key focus areas and tactics 

outlined in this plan

• Same as above

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 45
5.8: Equity Research Agenda

We commit to the following 21 research projects over the course of this plan. 

Research Topic Description Focus Area

Homeownership Gaps and 

Academic Achievement

Reducing academic achievement gaps is identified as an important long-term strategy to reduce 

homeownership gaps. We will use regression analysis to explore the extent to which educational

disparities contribute to the racial homeownership gap between white, Black and Latino households.

We will use the National Longitudinal Survey of Youth as a data source.

Closing the Homeownership Gap

Mortgage Market Experiences 

of Black and Latino Borrowers 

Little research has been done to understand the racial disparities mortgage borrowers experience that 

may perpetuate racial wealth gaps. We will investigate mortgage market experiences of Black and

Latino versus Non-Latino white borrowers. This will include an analysis of perceptions, knowledge,

shopping experience, satisfaction and expectations, as well as various sources of down payment, 

using the National Survey of Mortgage Originations (NSMO) and National Mortgage Database 

(NMDB) as data sources

Closing the Homeownership Gap

First-Time Buyer Affordability 

Index

The current pandemic has negatively impacted the affordability of first-time homebuyers, especially 

the low- to moderate-income and families in historically underserved communities, due to high 

house prices and low housing inventory. We plan to construct a novel index to calculate trends in

local affordability of future borrowers by various racial/ethnic and AMI buckets and to publish a white 

paper and interactive dashboard, using credit bureau(s) data, and the National Mortgage Database 

(NMDB) as data sources

Closing the Homeownership Gap

Black Indigenous 

Homeownership

Assess the motivations and barriers to homeownership for Black Indigenous communities, including 

(a) quantitative research on the number and geographic location of Black Indigenous communities in 

America, (b) insights on household characteristics, homebuyer behaviors, and social and economic 

benefits, and (c) current programs or policies that either facilitate or hinder Black Indigenous 

homeownership

Closing the Homeownership Gap

“I felt like as an African American woman I was just a 

number to the [real estate professional], and I didn’t 

want to feel that way.”

– Homebuyer, Freddie Mac ethnographic research

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 46
Research Topic Description Focus Area

Homeownership Sustainability Homeownership sustainability focuses on predicting the ability of a household to maintain 

homeownership, which materially differs from modeling mortgage default. Understanding what

factors drive sustainable homeownership is important at the individual level, as it is associated with 

upward mobility and wealth accumulation, and, at the societal level, with civic and community 

involvement and neighborhood stability. This research will use internal Freddie Mac data (particularly

updated credit data) and, possibly, the National Mortgage Database (NMDB)

Eliminate Disparities in Community Experience

Trends in Student Loan Debt 

Among Future Borrowers from 

Communities of Color

Existing research points to student loan debt obligations as an important barrier to homeownership in 

communities of color, especially for Black millennials. We will investigate the student loan debt trends

and the extent to which it is negatively impacting the debt-to-income ratios and mortgage readiness 

of Black future borrowers, using credit bureau(s) data and the American Community Survey (ACS) as 

data sources

Eliminate Disparities in Community Experience

Impact of Mortgage Market 

Experiences on Loan Choice of 

Black and Latino Borrowers

Nearly 40 percent of FHA loans originated to Black and Latino borrowers can potentially fit into 

the conventional credit box. We will conduct research to better understand the extent to which

mortgage market experience of minority borrowers determine their loan choice, among other factors, 

using the National Survey of Mortgage Originations (NSMO) and the National Mortgage Database 

(NMDB) as data sources

Eliminate Disparities in Community Experience

Interactive Dashboard: Credit 

and Debt Profile of Future Black 

& Latino Borrowers 

Credit profiles of consumers have been changing after the pandemic. For example, credit scores have

gone up due to low delinquencies and low utilization rates. We plan to build an interactive dashboard

to track various trends in real time (income, credit scores, balances and delinquencies by various debttypes, mortgage ownership and readiness status, etc.), using credit bureau data as a data sourc

Eliminate Disparities in Community Experience

Understanding Financial 

Well-Being of Middle-Income 

Black Borrowers Since The 

Financial Crisis

Black homeowners have been hit particularly hard by the foreclosure crisis of late 2000s. However,

little work has been done to distinguish the experience of Black communities with varying income 

levels, education or geographic diversity. We want to examine the financial well-being of middleincome Black households, who became first-time buyers at different points in time post-financial crisis,

using credit bureau data as a data source

Eliminate Disparities in Community Experience

21 research projects over the course of this plan (Continued)

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 47
Research Topic Description Focus Area

Youth Financial Education Research can inform how to proactively equip young people in Black and Latino communities 

with tools needed to become financially capable and sound, emphasizing the need for personal 

financial education and management. This research will identify what is currently missing from early

educational programming as well as ways to better educate and reach the Black and Latino younger 

community to help young people build pathways towards financial success. We will use primary

quantitative consumer polling as a data source

Eliminate Disparities in Community Experience

Identify and Implement 

Enhanced Baseline Tenant 

Protections

As a first step in addressing disparities in tenant protections and tenants’ rights, we will conduct indepth research on the amount, availability, and degree of core tenant protections in all 50 states and 

Washington, D.C. and U.S. territories. In addition, we will explore the potential implications of t

variations on renters by race and ethnicity, particularly Black and Latino renter households

As a result of this research, we will work with market stakeholders to identify marketable tenant 

protection enhancements that could be applied to properties obtaining new multifamily GSE loans, 

develop a plan to encourage adoption of these enhanced protections over time on new multifamily 

GSE transactions, and then implement these protections across our loan offerings in a manner that can 

foster scaled adoption and, ideally, establish a higher market standard for tenant protections

Increase Renter Opportunities

Analyze Housing Choice 

Voucher Availability, Efficacy 

and Acceptance

Freddie Mac will research the usage and efficacy of Housing Choice Vouchers (HCV) nationwide 

in providing access to opportunity using geographic, policy and data analysis. We will publish a

paper that analyzes the severity and prevalence of factors that inhibit use of HCVs, especially in high 

opportunity areas, and investigates where vouchers can and cannot likely support rent levels

After publication, we intend to engage with market stakeholders including HUD, housing authorities 

and multifamily owners and property managers to consider strategies that could increase the efficacy 

and acceptance of HCVs and how these strategies could be advanced through Freddie Mac loan 

offerings

Increase Renter Opportunities

Housing Choice Vouchers for 

Homeownership

The HCV homeownership program can enable eligible families to use the voucher for home purchase 

and to receive financial assistance towards homeownership expenses. We plan to investigate the

extent to which HCV program can promote homeownership for eligible families

Closing the Homeownership Gap

Analyze Credit Building Data 

to Assess Impact and Potential 

Improvements

In order to identify potential changes to our credit building program, drive market adoption, and 

monitor progress, we will measure the inherent impact of the program utilizing Credit Bureau data on 

renters in Freddie Mac financed properties to capture credit scores before and after rent reporting, 

controlling for other potential drivers to isolate the rent reporting impact

This research can inform changes to the program and/or broader market adoption

Increase Renter Opportunities

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

21 research projects over the course of this plan (Continued)

EQUITABLE HOUSING FINANCE PLAN 48
Research Topic Description Focus Area

Analyze LIHTC Properties at 

Risk of Lost Affordability

Freddie Mac will analyze the magnitude of Low-Income Housing Tax Credits (LIHTC) property 

affordability loss as well as where it is most likely to occur. We will publish the results of this research

in a paper that identifies markets where LIHTC properties are at greater risk of lost affordability and 

examines these findings in the context of available public subsidy such as private activity bond and 

state-level LIHTC allocations

This research will inform loan offering enhancement and applications described in section 6.9 in order

to preserve at risk LIHTC properties

Quality & Quantity of Affordable Housing Supply

Analyze and Identify Affordable 

Rental Housing Needs 

Freddie Mac will conduct research and develop tools to evaluate the differences in affordability 

characteristics in select markets across the country

Analysis can be used to inform market decisions regarding supply of affordable housing. Through this

work we will (a) explore the market and/or sub-market affordable housing profile at various income 

levels and (b) examine the feasibility of funding necessary to develop that housing in terms of debt 

financing, equity investment and public subsidy required

Quality & Quantity of Affordable Housing Supply

Sizing Affordable and Aging 

Housing Supply in Diverse Rich 

and Low-Income Areas

In order to study where the biggest gaps in housing supply are compared to the demand, we will 

identify top MSAs with the fastest growing population (i.e., by various race/ethnicity and incom

buckets) in the last 10 years and affordable housing supply shortage in these areas. We will use

decennial census and Multiple Listing Services (MLS) as data sources

Quality & Quantity of Affordable Housing Supply

Analyze and Address Potential 

Appraisal Disparities in 

Multifamily Housing

In order to identify and address potential appraisal disparities in multifamily housing, Freddie Mac will 

research the existence and severity of appraisal inequalities for multifamily properties in communities 

or neighborhoods in which a high number of diverse households reside. To do so we will leverage

existing literature, analyze appraisal and demographic data and investigate potential root causes of 

any results showing such disparities exist

Underinvestment Within Formerly Redlined Areas

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

21 research projects over the course of this plan (Continued)

EQUITABLE HOUSING FINANCE PLAN 49
Research Topic Description Focus Area

Appraisal Gap Analyses In 2021, Freddie Mac released a research note confirming that appraisals are more likely to come 

in under contract price in Black and Latino communities. We continue this research to explore root

cause(s) that contribute to this gap, and to consider if, how and why automated valuation might be 

part of the solutions. Freddie Mac leveraged the Uniform Collateral Data Portal (UCDP) as a data

source to inform the work and in May 2022, published its second research note titled “Racial & Ethnic 

Valuation Gaps in Home Purchase Appraisals - A Modeling Approach” 52

Underinvestment Within Formerly Redlined Areas

Racial Segregation and 

Mortgage Market Outcome 

To understand the impact of racial segregation on Black borrowers’ residential wealth accumulation 

propensity and various mechanisms behind that, we will investigate the relationship between racial 

segregation and mortgage market outcomes. More importantly, we will investigate various channels

through which neighborhood segregation may have disparate impact on Black borrowers’ propensity 

to accumulate wealth (e.g., lack of investment in residential development, aging housing stock, ban

deserts and limited access to financial information), using the National Mortgage Database, census 

data, Bureau of Labor Statistics data, and FHFA HPI as data sources

Underinvestment Within Formerly Redlined Areas

Historical Redlining Analysis To identify areas that are currently underserved so we can be efficient and in implementing the tactics 

within our equity plan, we will conduct research looking at historical, redlined areas and overlay them 

with various definitions of minority. We will investigate disparities in key economic factors across these

definitions using HOLC maps, census data, credit bureau data, HMDA, and the National Mortgage 

Database (NMDB) as data sources

Underinvestment Within Formerly Redlined Areas

52 https://www.freddiemac.com/research/insight/20220510-racial-ethnic-valuation-gaps-home-purchase-appraisals-modeling-approa

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

21 research projects over the course of this plan (Continued)

EQUITABLE HOUSING FINANCE PLAN 50
SECTION 6

Broad Interventions 

to Address Systemic 

Barriers to 

Equitable Housing

This section of the Equitable Housing Finance Plan outlines our approach 

to broadly addressing systemic barriers to equitable housing. It focuses

on solutions that address the homeownership gap and systemic 

underinvestment in formerly redlined areas, increase and improve the 

quality of affordable housing supply and increase opportunities for renters
6.1: Improve Fairness in Credit Scoring

Market Challenges and Barriers

The mortgage industry relies upon FICO to assess borrowers’ creditworthiness and as 

an input to most automated underwriting systems (AUS). Freddie Mac has been

evaluating the potential to expand access to credit for historically underserved borrowers 

through use of alternative credit scores, as well as using alternative data for credit 

assessments. We also are working to remove reliance on third party credit scores in

the company’s AUS

Our Actions

We are developing a version of the company’s AUS that does not rely upon third party 

credit scores. We also intend to investigate and develop a plan to leverage alternative

credit data where appropriate

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period Key Action Items Goals 

Year 1 – 2022 • Develop plan of alternative credit data sources and begin analysis. • Reduce disparities through implementation of a newer AUS version leveraging more

advanced modeling techniques

Year 2 – 2023 • Implement an AUS version without third party credit scores

• Continue development of newer versions of internal underwriting and 

costing models using advanced modeling techniques

• Continue research for the use of alternative credit data

• Remove reliance on third party credit scores within Freddie Mac’s AUS

Year 3 – 2024 • Continue development of newer versions of underwriting (relying on 

trended and other alternative data) and costing models using advanced 

modeling techniques

• Complete an analysis on viability of the use of trended and other alternative data

EQUITABLE HOUSING FINANCE PLAN 52
6.2: Improve Fairness in Underwriting 

Market Challenges and Barriers

Many people in communities of color manage finances through cash transactions

Cash transactions are outside of the credit system, making it more difficult for potential 

borrowers to receive financing since the lending process does not capture cash 

transactions. This cash-rich environment creates income that can be tracked through

bank account data from third-party service providers. Additionally, objectively

responsible behavior, like pursuing continued education, or paying cash for a used car 

instead of leasing a new one, may not help Black or Latino homebuyers enhance credit 

because they occur outside of the credit system

Our Actions

Freddie Mac will actively pursue technological and credit policy analysis to determine 

the most effective methods of incorporating this financial information into the lending 

process to assess borrower account data and patterns to increase access to credit for 

underserved borrowers. 

Goals

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

“You know, I’m not a big fan of the credit card. 

[I prefer to] save your money up and buy it... 

Take your time, buy things as you like them... 

the credit card business is predatory.”

– Current homeowner, Freddie Mac ethnographic research

Period Key Action Items Goals

Year 1 – 2022 • Explore use of cash flow metrics to support the evaluation of a borrower’s 

ability to repay

• Evaluate other cash flow metrics in the industry

• Analyze impact to accept rate gap for underrepresented borrowers

Year 2 – 2023 • Begin research and development on integrating cash flow data into our AUS. • Same as abov

Year 3 – 2024 • Integrate cash flow data into our AUS.​• Same as abo

EQUITABLE HOUSING FINANCE PLAN 53
6.3: Solutions to Foster Appraisal Equit

Activity 1: Appraisal Industry Engagement

Market Challenges and Barriers

The appraiser community of practice at times does not reflect the racial and ethnic 

diversity of the homeowner community it serves. For example, 89 percent of all property

appraisers and assessors are white, with 2 percent identifying as Black and 5 percent as 

Latino

53 Entry into the profession can be difficult, particularly satisfying the state-required 

qualification criteria and obtaining the experience required prior to licensure as a trainee

Furthermore, trainees have a difficult time obtaining supervising appraisers. These factors

may contribute to a homogeneous current population of appraisers

Freddie Mac has a unique opportunity to engage the appraisal industry on the topic of 

equitable housing, as demonstrated by its 2021 research paper identifying appraisal 

gaps within minority census tracts

Our Actions

Freddie Mac will explore opportunities to address appraisal and valuation equity 

concerns and take steps to ensure fair valuation and mitigate potential for discrimination

To support the continued efforts to increase diversity among residential appraisers, 

Freddie Mac has committed to partner with The Appraisal Institute through its Appraiser 

Diversity Initiative (ADI). This initiative provides scholarship opportunities to new entrants

in training to become appraisers. Freddie Mac has joined the ADI effort as a core partner,

joining the Appraisal Institute, Fannie Mae and the Urban League with a commitment to 

(a) provide advisor mentor resources to assist scholarship winners, (b) actively engage in 

recruiting and marketing efforts with the Appraisal Institute to invite new entrants and 

(c) to engage the appraisal industry broadly to solicit industry sponsorship opportunities

53 https://www.urban.org/urban-wire/increasing-diversity-appraisal-profession-combined-short-term-solutions-can-helpaddress-valuation-bias-homeowners-col

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 54
Freddie Mac will also partner with the housing industry to address the concerns raised 

about race and ethnicity-based appraisal gaps. For example, Freddie Mac joined

the Office of the Comptroller of the Currency (OCC) Project REACh (Roundtable for 

Economic Access and Change) effort. The goal of the project is to bring together leaders

from banking, business, technology and national civil rights organizations to develop 

strategies to reduce specific barriers that prevent full, equal and fair participation in the 

nation’s economy. Through this work, Freddie Mac is co-leading a valuation workstream

with representatives from lenders and the OCC

Additionally, Freddie Mac commits to providing input to the Appraisal Foundation’s 

Appraisal Standards Board (ASB) and its Appraisal Qualification Board (AQB) with respect 

to establishing, improving and promulgating uniform standards of professional appraisal 

Goals

Period Key Action Items Goals

Year 1 – 2022 • Active leadership in ADI effort with a commitment to (a) provide advisor mentor 

resources to assist scholarship winners, (b) actively engage in recruiting and 

marketing efforts with the Appraisal Institute to invite new entrants and (c) to engage 

the appraisal industry broadly to solicit industry sponsorship opportunities

• Leadership in Project REACh

• Input and participation in ASB and AQB

• Continued leadership in ADI, Project REACh, ASB and AQB

• Work with FHFA to identify and expedite implementation of prioritized valuation 

equity proposals

• Work with FHFA to identify additional research topics related to valuation equity and 

publish and broadly distribute such research

Year 2 – 2023 • Continued engagement in the ADI

• Evaluate guidance / rule gaps (regulatory and GSE), determine if an appraisal bias 

study is feasible and evaluate whether bias exists in AVM design or data

• Continue participation in TAFAC (The Appraisal Foundation Advisory Council) to 

inform improvements

• Review and comment on exposure drafts and proposed changes to USPAP

• Continued commitment to mentor and support diverse new appraiser entrants 

through the ADI

• Continued engagement with OCC Project REACh's appraisal and valuation 

subgroup

Year 3 – 2024 • Continued engagement in the ADI. • Same as 202

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

practice, as well as the qualification criteria and minimum education required for new 

appraisers. For example, Freddie Mac has dedicated representatives participating in

TAFAC (The Appraisal Foundation Advisory Council), through which it can provide input 

to both ASB and AQB. Freddie Mac hopes to promote appraisal standards, provide

objective and unbiased appraisals and ensure that qualifying criteria does not provide 

barriers to entry

EQUITABLE HOUSING FINANCE PLAN 55
Activity 2: Develop Appraiser Quality Monitoring

Market Challenges and Barriers

Freddie Mac research finds that Black and Latino communities are more likely to receive 

home appraisal values below market contract price (Appraisal Gap)

54 Greater focus 

is needed to enhance tools such as Loan Collateral Advisor® (LCA) to assist lenders in 

identifying poor quality appraisals as well as defining and implementing the Freddie Mac 

appraiser monitoring framework

Our Actions

Freddie Mac will develop an Appraiser Quality Monitoring framework that leverages 

modern technology features. As well as staff internal team leveraging tools to identify,

assess, monitor and mitigate risks such as Appraisal Gap. The framework will include

feedback communications to appraisers and lenders to remediate observed trends

54 http://www.freddiemac.com/research/insight/20210920_home_appraisals.pa

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period Key Action Items Goals

Year 1 – 2022 • Create and staff dedicated AQM team (with associated technology tools). • Define AQM framewor

Year 2 – 2023 • Refine AQM framework as warranted. • Execute against AQM framewor

Year 3 – 2024 • Refine AQM framework as warranted. • Execute against AQM framewor

EQUITABLE HOUSING FINANCE PLAN 56
Activity 3: Enhance LCA to Better Detect Potential Undervaluation 

and Use of Biased Wording 

Our Actions

Freddie Mac’s research indicates appraisals in minority census tracts are more likely to 

receive an appraised value below the contract price, as compared to appraisals in nonminority census tracts. Undervaluation could impact buyers, sellers and the communities

they live in, and this occurs more often in minority, compared to non-minority 

communities. Undervaluation also could lead to increased risks to Freddie Mac and

the lenders who sell loans to Freddie Mac

Freddie Mac will focus on several enhancements to LCA to assist us and our lenders 

in identifying and reviewing appraisals that may be at a higher risk for inappropriate 

undervaluation or use of biased words or phrases (e.g., pride of ownership, crim

ridden, etc.

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period Key Action Items Goals

Year 1 – 2022 • Enhance LCA to better detect potential undervaluation

• Develop plan to assist lenders in detecting subjective and/or biased 

wording in appraisal reports

• Deploy LCA version with enhanced undervaluation detection capability

Year 2 – 2023 • Monitor performance of undervaluation rule in LCA

• Enhance LCA to detect subjective/biased text in appraisal reports

• Announce and implement strategy to eliminate inappropriate language in appraisal reports

Year 3 – 2024 • Monitor performance

EQUITABLE HOUSING FINANCE PLAN 57
Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Activity 4: Analyze and Address Potential Appraisal Disparities 

in Multifamily Housing

Market Challenges and Barriers

In September 2021, Freddie Mac published research showing substantial appraisal 

valuation gaps for single-family homes. The research found that “appraisers’ opinions of

value are more likely to fall below the contract price in Black and Latino census tracts, and 

the extent of the gap increases as the percentage of Black or Latino people in the tract 

increases.” These results for the single-family market manifest across various analyses

presented in the paper. This research begs the question, does a similar gap exist for

multifamily properties?

Appraisals are engaged, developed and reported differently for multifamily lending 

than for single-family (i.e., reliance on the property’s income generation and investmen

potential in addition to comparability to similar properties that sold), but Freddie Mac’s 

prior research on single-family appraisal disparities demonstrates that there is potential 

for disparities in multifamily appraisals as well, and provides some insight into how 

a similar study could be developed to test undervaluation of multifamily property in 

minority concentrated areas

Our Actions

Freddie Mac will research the potential existence and severity of appraisal inequalities 

for multifamily properties in communities or neighborhoods in which a high number of 

minority households reside. Freddie Mac will do this by reviewing existing literature,

analyzing appraisal and demographic data and investigating potential root causes of any 

results showing that such disparities exist. In our research paper, we will

• Review background and existing research on this topic

• Present data-driven findings on potential gaps in appraisal values

• Discuss potential causes and solutions, depending on the nature of the problem

Once published, we will convene market stakeholders to examine opportunities and 

develop a plan to address disparities in the multifamily industry appraisal process and 

standards

Goals

Period Key Action Items Goals

Year 2 – 2023 • Conduct research. • Publish researc

Year 3 – 2024 • Convene market stakeholders and develop a plan to address potential 

appraisal disparities identified in research

• Develop a plan to address identified disparities

EQUITABLE HOUSING FINANCE PLAN 58
6.4: Provide Capital for Very Small Multifamily

Properties by Expanding “Linked Loan” Parameters 

Market Challenges and Barriers

The rental housing stock in historically underinvested communities is often diverse, 

ranging from single-family homes, 2-4-unit properties, very small 5+ unit properties 

and larger buildings. While larger properties are straightforward to finance, very small

properties are often too small to finance cost-effectively through traditional lenders

This can make developing these properties in such communities prohibitively difficult 

and expensive, especially for emerging developers, as they would have to rely on a 

variety of lenders and loan products, with many inconsistencies in process, requirements 

and terms. An emerging developer who starts by investing in 1-4-unit properties but

then scales wealth and experience and enters the 5+ unit space will rapidly become 

constrained by the inability to refinance their portfolio to continue growing both in scale 

and impact in their communities

Emerging developers who operate a range of properties need a single, cost-effective 

form of financing. Freddie Mac can support this blend of properties in our Small

Balance Loan program on a limited basis today under “linked loan” parameters that 

allow us to finance a collection of small properties on contiguous sites, but more can be 

done. Expanding our capabilities will likely have a material impact on both emerging

minority borrowers and underinvested minority communities, as 2-4-unit buildings are a 

particularly important component of the housing stock in communities of color. Black and

Latino communities have greater representation both as tenants and landlords in 2-4-unit 

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

rental housing. According to the Urban Institute, the property type with the most Black

and Latino owners is 2-4 unit properties: 13 percent of owners are Black, and 15 percent 

are Latino

55 Black and Latino-headed households are also more likely to rent units in 

2-to-4-unit buildings than any other type of structure. In Chicago, for example, 73.

percent of all 2-4-unit rentals are occupied by households headed by a person of color

56

As such, better meeting these small rental properties’ needs will help us better meet 

these targeted underserved communities’ needs

Our Actions

We intend to expand our “linked loan” parameters to allow financing of noncontiguous 

2-4-unit rental properties. We will test the capabilities and impact of the program,

focusing on, but not limiting availability to, historically underinvested communities

Today, we allow 2-4-unit buildings, but they must be contiguous and of “like” quality 

to 5+ unit properties. Our expansion would include non-contiguous properties no

more than three miles apart. This distance would allow for both consistent property

management and flexibility for emerging and smaller developers to grow their portfolios 

and support their communities. Emerging developers would also benefit from our

Develop the Developer curriculum and other services funded through our community 

support investments described above and below

55 https://www.housingstudies.org/releases/preservation-la

56 https://www.housingstudies.org/releases/characteristics-2-4-stock-chicago-neighborhood

Goals

Period Key Action Items Goals

Year 1 – 2022 • Develop updated “linked loan” parameters

• Educate Optigo lenders on changes

• Publish updated parameters in a term sheet

• Publish updated program parameters

EQUITABLE HOUSING FINANCE PLAN 59
6.5: Support Renter and Multifamily Borrower

Resource Organizations 

Market Challenges and Barriers

Access to tenant support services, such as legal aid or financial and housing counseling 

can be vital for renters who are experiencing challenging life events or housing stability 

issues. For example, according to a recent study by the Institute for Housing Studies

at DePaul University, lower-wage, hourly workers have faced increased risk of job 

loss and reduced incomes from the COVID-19 pandemic. These workers are more

likely to be minorities, renters and already face housing-cost burdens — underscoring 

the importance of support for tenants and small property owners in underserved 

communities

57 However, support is not consistently available and, if available, tenants 

may not know how to access the support they need. Further, organizations that

provide tenant support services may not have the resources to meet all the needs in the 

communities they serve

A lack of access to support and resources has a grave impact on the financial health and 

future of renters in underserved communities. If a tenant faces missing a rental payment

due to loss of income or has a dispute with their landlord, they might not know where 

to turn for help. Tenants in difficult situations might not go to their landlord with a

problem for fear of eviction. Tenants living in units where landlords are unresponsive to

maintenance issues that are potentially putting their health and wellbeing at risk may not 

know what to do. If left unaddressed, these challenges can lead to poor credit, eviction

and health issues that are harmful to a tenant’s wellbeing and stability

Consistent and straightforward access to tenant support services can be of vital 

importance in helping people stay in their homes or ensure rental units are in good 

repair. Stability of housing for renters can also foster greater community stability, which

can be an important factor in measuring quality of life, increasing investment and 

addressing undervaluation in formerly redlined areas, racially or ethnically concentrated 

areas of poverty (R/ECAPs) and other underinvested communities. Borrowers can also

benefit from supportive services. Given the proper resources and funding, informed

borrowers are better able to support tenants, and this support can lead to more 

sustained occupancy, stability and financial benefits to both borrowers and tenants

57 https://www.housingstudies.org/releases/preservation-la

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 60
Goals

Period Key Action Items Goals

Year 1 – 2022 • Identify community organizations with which to develop partnerships

• Review impact reports of community organizations

• Solidify community partnership agreements

• Promote access to community organization services through our website

• Support at least four community organizations in varying underserved markets

• Launch website resource portal

• Poll renters and borrowers in at least four distinct communities

Year 2 – 2023 • Identify new community organizations with which to develop partnerships

• Continue to review impact reports of community organizations

• Support at least seven community organizations in varying underserved markets

• Poll renters and borrowers in at least four distinct communities

Year 3 – 2024 • Identify new community organizations with which to develop partnerships

• Continue to review impact reports of community organizations

• Support at least seven community organizations in varying underserved markets

• Poll renters and borrowers in at least four distinct communities

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Our Actions

To provide additional support and protection for renters, Freddie Mac will work to further 

support local community organizations in targeted underserved areas that are already 

established but need more resources to (a) support underserved minority renters and/

or (b) support underserved borrowers and property managers. These organizations

might provide resources such as enforcing and improving tenant protections and 

rights, legal services for rental disputes, housing discrimination and eviction protection 

resources. Additionally, organizations that support underserved borrowers might have

influence over property owners to engage in more equitable practices surrounding rental 

applications, screenings, rebuttals, repayment and evictions. Community organizations

could also provide social services to renters, such as educational support on necessary 

due diligence when finding an apartment, as we also intend to do through our 

CreditSmart® program. We will partner with some of these renter resource organizations

to better serve tenants and understand needs and challenges they are facing

By providing financial support to community organizations, underserved tenants and 

borrowers have an opportunity to become better informed, protected and assisted. In

exchange for funds, our community partners will provide Freddie Mac with impact reports 

and access to renter and community sentiments to ensure our ongoing efforts continue to 

meet the needs of the communities. By doing so, we will be able to better understand the

barriers and challenges renters in underserved communities face, address their needs and 

challenges, and adjust the action items in our Equitable Housing Finance Plan as such

We can use this information to scale programs further or tailor our loan offerings to better 

support these community organizations. Outreach and lessons learned through our

engagement with community organizations will allow us to provide support for renters and 

borrowers across a range of issues, improving renter outcomes and property stability

EQUITABLE HOUSING FINANCE PLAN 61
6.6: Develop Multifamily Correspondent Lender

Program for Community Development Financial 

Institutions, Minority Depository Institutions and 

Small Lenders

Market Challenges and Barriers

Community Development Financial Institutions (CDFIs), minority depository institutions 

(MDIs) and smaller regional banks or small financial institutions (SFIs) have a unique 

place in the market. These institutions often have specialty programs and a great level

of expertise with programs and financing directed towards the hardest-to-serve areas in 

their states and communities

Per research from the Carsey School of Public Policy at the University of New Hampshire, 

CDFIs are delivering most of their lending to low-income and minority borrowers58 in 

historically underserved markets and hard-to-finance properties, such as multifamily 

buildings with fewer than 20 units, which are typically too small for larger lenders to 

pursue. CDFIs, MDIs and SFIs provide necessary investment in minority communities by

preserving the affordable housing stock and helping to improve the quality of life of the 

minority renters they serve

While these institutions play a vital role, they are often constrained in how much lending 

they can do because of either limited balance sheet size or borrower or geographic 

concentration challenges. They would benefit from greater access to capital so they can

increase their impact and gain more exposure to the processes and requirements (both 

procedural and technical) that enable them to access that capital. As their borrowers

grow and succeed, they can become too big to rely on small financial institutions who are 

more adept at making smaller targeted loans, but do not typically support the larger loans 

necessary for growing borrowers to acquire and operate larger properties. Without greater

access to capital, these institutions can no longer serve their more successful borrowers

58 https://www.cdfifund.gov/Documents/CDFIs%20Stepping%20into%20the%20Breach%20Impact%20Evaluation%

Report.pd

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Our Actions

Throughout our Equitable Housing Finance Plan, we propose specific activities that 

involve providing securitization options for these institutions. These securitization

vehicles are effective in many circumstances but are not necessarily the best fit for all 

institutions, particularly smaller institutions that may not have existing securitization 

experience or have limited ability to aggregate larger volumes of loans on their balance 

sheet. Many of these institutions and the communities they serve would benefit most

from the ability to sell individual loans to Freddie Mac. Typically, it is challenging for

Freddie Mac to maintain relationships with lenders that do not operate at scale. Likewise,

it is challenging for small lenders to develop the infrastructure required to sell loans 

directly to Freddie Mac

To empower these lenders and help them grow in scale and impact, we will develop a 

program that bridges the gap between these lenders and Freddie Mac. By leveraging

our existing multifamily lender network as intermediaries, we will develop a small 

multifamily lender mentoring and correspondent relationship program

Under this program we will first identify lenders from our Optigo network who are 

willing and able to support smaller lending institutions. We will develop a “playbook” of

guidelines and standards for these Optigo lenders to interface with and support smaller 

lending institutions. This playbook will include a menu of different support tactics and

economic parameters. From there, we will (a) match incoming lender requests from these

small institutions with the list of qualified Optigo lenders and monitor progress, and 

(b) conduct our own outreach and events to identify additional potential small lenders

We will start with a small number of correspondent relationships to refine parameters 

and develop our playbook. Over time we will continue to expand and refine the list of

qualified Optigo lenders and expand this correspondent relationship program through 

ongoing outreach and pairing

As we work with our Optigo lenders to develop this correspondent lender program, 

we will continue to leverage our existing suite of seasoned and affordable loan pool 

offerings, as well as the new offerings described through our Equitable Housing Finance 

Plan, to provide liquidity to CDFIs, MDIs and SFIs

EQUITABLE HOUSING FINANCE PLAN 62
Goals

Period Key Action Items Goals

Year 1 – 2022 • Conduct outreach to CDFIs, MDIs, and CDFIs to understand their 

unique challenges and needs

• Conduct outreach to Optigo lenders

• Analyze feedback to understand the feasibility and challenges of 

providing liquidity or other support to CDFIs, MDIs and other SFIs

• Develop draft “playbook” for Optigo lenders engaging with 

correspondent lenders

• Identify at least one Optigo lender to commit to supporting small lending institutions

• Engage at least one correspondent lender

Year 2 – 2023 • Establish correspondent relationship(s) to identify opportunities for 

improvement before expanding availability

• Publish playbook for Optigo lenders to leverage in supporting small 

lending institutions. Playbook to include best practices and economic

limits/requirements around warehouse lines for aggregating collateral, 

due diligence requirements, servicing resources, ongoing consulting and 

education resources

• Increase number of correspondent lenders and Optigo lenders engaged 

in the program

• Continue outreach and engagement with CDFIs, MDIs and small lenders

• Identify at least one additional Optigo lender to commit to supporting small lending 

institutions

• Grow correspondent network to at least three lenders

Year 3 – 2024 • Refine playbook for Optigo lenders based on experience and feedback as 

needed

• Increase number of correspondent lenders and Optigo lenders engaged 

in the program

• Continue outreach and engagement with CDFIs, MDIs and small lenders

• Identify at least one additional Optigo lender to commit to supporting small lending 

institutions

• Grow correspondent network to at least five lenders

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 63
6.7: Facilitate Ground-Up Construction and Adaptive

Reuse of Affordable and Middle-Income Rental Housing 

for Individuals and Families 

Market Challenges and Barriers

The Joint Center for Housing Studies of Harvard University estimates that the U.S. need

to produce 4.6 million new apartment units by 2030 to keep up with demand, which

equates to a development pace that has been achieved three times in the past thirty 

years

59 There has been an uptick in construction activity in recent years, however, much 

of this has been focused on high-rent Class A properties. According to the National

Low Income Housing Coalition, there is a systemic national shortage of rental housing 

affordable for renters with household incomes below 50 percent of AMI, with all but 

two states reporting a cumulative shortage. Fifteen states and DC have shortages of

80 percent AMI affordable rental housing, and seven states with high-cost metropolitan 

areas — California, Florida, Hawaii, Massachusetts, New Jersey, New York and Oregon 

— have cumulative shortages at the median income. This shortage disproportionately

affects Black and Latino renters, as 73 percent of Black renters and 68 percent of Latino 

renters have incomes at 80 percent AMI or below

60

It is estimated that as of 2018, 10 percent of new units built have asking rents at levels 

considered to be affordable for half the rental population

61 Although the Low-Income 

Housing Tax Credit (LIHTC) program has been effective at creating new affordable 

supply, the program produces fewer than 50,000 new units annually and many states 

are constrained by LIHTC and private activity bond volume caps. The need for increased

supply is compounded by the expiration of the regulatory agreements for these 

LIHTC properties. An estimated 718,000 units are expected to be released from these

agreements by 2030

62

59 The State of the Nation’s Housing 2021. Joint Center for Housing Studies of Harvard Universit

60 https://reports.nlihc.org/sites/default/files/gap/Gap-Report_2021.

61 Per Freddie Mac’s internal analysis and Harvard’s Joint Center for Housing Studies’ State of the Nation’s Housing 2019.

“With most new construction targeting the high end of the market, there has been some potential for excess supply to 

filter down to lower rent levels.

62 PAHRC and NLIHC tabulation of NHPD, January 2020

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

In addition to the many public barriers to developing new affordable housing 

described in our Equitable Housing Finance Plan, such as restrictive land use 

and zoning policies to local objections to neighborhood changes, there are also 

substantial economic and procedural challenges to developing new affordable 

housing. These are perhaps most acute in high opportunity areas, which tend to

also be high-rent and high-cost areas

Uncertainty in financing — from rates to loan duration — results from project delays in 

permits, construction, lease-up and other factors, all of which complicate development

The cost of construction materials and labor grew by 57 percent from 2000 to 2016 and, 

according to recent surveys, 100 percent of respondents have seen price increases in 

materials on recent projects. Land prices increased 96 percent during the same period

and there remains a limited amount of development sites that are entitled for multifamily 

use. Furthermore, projects face an average of a four-month delay in the entitlement

process and those delays lead to an estimated rental increase of $125 per month. This

rising cost environment continues to drive increased rental rates, further exacerbating 

the affordability crises

63 64

Financing uncertainties and high construction costs limit the market’s ability to create 

affordable rentals and increase the quality of housing. Freddie Mac aims to address these

issues through the expanded use of forward commitments and the purchase of certain 

construction-to-permanent loans

63 NMHC Construction Survey (Round 8): NMHC | NMHC Construction Survey (Round 8)

64 The Housing Affordability Toolkit. NMH

59 The State of the Nation’s Housing 2021. Joint Center for Housing Studies of Harvard Universit

60 https://reports.nlihc.org/sites/default/files/gap/Gap-Report_2021.

61 Per Freddie Mac’s internal analysis and Harvard’s Joint Center for Housing Studies’ State of the Nation’s Housing 2019.

“With most new construction targeting the high end of the market, there has been some potential for excess supply to 

filter down to lower rent levels.

62 PAHRC and NLIHC tabulation of NHPD, January 2020

63 NMHC Construction Survey (Round 8): NMHC | NMHC Construction Survey (Round 8)

64 The Housing Affordability Toolkit. NMH

EQUITABLE HOUSING FINANCE PLAN 64
Our Actions

Freddie Mac intends to support the construction of new affordable housing and the 

adaptive reuse of existing non-residential structures — both with and without public 

subsidy — in three ways:

• Leverage and expand our forward commitment construction take-out loan offerings

• Provide liquidity to small institutions in the ground-up affordable construction to 

permanent lending market

• Develop a construction-to-permanent loan purchase offering

These approaches will be focused on improving the economic feasibility of creating 

affordable and middle-income rental housing and has a strong impact on those most 

affected by the housing shortage, including underserved racial and ethnic groups

Action 1: Forward Commitments

Forward commitments provide developers and construction lenders with a muchneeded sense of certainty. Developers benefit because funding terms on their long-term

permanent loan are locked in, while construction lenders benefit through the certainty 

that their short-term construction loan will be paid off. This makes it easier for them to

lend on new construction projects

Freddie Mac has funded forward commitments since the early 2000s, primarily with a 

focus on properties with LIHTC. By doing this, Freddie Mac has provided developers

with permanent financing terms for newly constructed or substantially rehabilitated 

affordable multifamily properties prior to construction completion and stabilization

However, new construction of LIHTC properties is not enough to close the affordable 

housing gap

To further aid the construction of affordable rental housing, Freddie Mac began 

offering forward commitments on properties with other public subsidy and affordability 

restrictions without LIHTC. Under our Equitable Housing Finance Plan, we intend to take

the lessons we have learned in our years of experience to expand the use and, where 

necessary, flexibility of our forward commitment offerings

The forward commitment program also allows us to support innovative construction 

methods that can help reduce construction time, cost and mitigate the risks of 

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

“Building material cost is the largest challenge in the 

short run, with a $30k–$40k cost increase in a typical 

Single-Family house coming from increases in lumber 

costs and other materials”

– Developer, California, Freddie Mac ethnographic research

construction lending. Through our forward program, we intend to establish standards

for lending on properties built with novel construction methods such as mass timber, 

panelized construction or modular construction, as well as specialized housing, such as 

supportive housing for persons who formerly experienced homelessness or affordable 

build-to-rent, single-family housing rental communities

If there are no governmental affordability restrictions on these new properties, we 

will require affordability to be preserved on a meaningful portion of the units through 

restrictions in the Freddie Mac loan agreement

Action 2: Construction Loan Sponsored Securitization

We intend to analyze the feasibility of and develop terms for supporting the construction 

lending market by credit enhancing and sponsoring the securitization of thirdparty ground-up construction-to-permanent debt on traditional and modular multifamily 

properties. We will focus on properties that have units affordable to low- and moderateincome renters, a population that is disproportionately Black and Latino. These loan

would be originated and funded by experienced construction lenders, CDFIs and/

or Duty to Serve qualifying small financial institutions. In addition to directly supporting

the creation of new supply, these transactions will increase social bond issuance and 

provide the liquidity needed to scale key market participants that are active in creating 

new affordable supply

EQUITABLE HOUSING FINANCE PLAN 65
Action 3: Construction-to-Permanent Loan Purchase Offering 

We intend to analyze the feasibility of, and develop a loan purchase offering for, groundup construction financing. This offering will facilitate increased development of new and

affordable supply, as well as spur liquidity and more efficient financing for a fragmented 

segment of the market

Freddie Mac will also develop a platform to directly purchase construction-to-permanent 

loans for affordable and middle-income multifamily and build-for-rent developments

This program will target new developments with units that are affordable to tenants 

earning a maximum of 80 percent, 100 percent and 120 percent AMI in standard, 

cost-burdened and very cost-burdened markets. The parameters of our program will

include requirements that explicitly promote equitable housing such as a requirement to 

offer credit-building and financial-capability training to renters, a requirement to accept 

housing choice vouchers where market conditions allow or considerations for disabilityinclusive design

In developing this offering, we will research and further establish a Freddie Mac 

framework for equitable multifamily housing development. This framework would build

from foundational concepts of equitable development established by public advocacy 

groups, and private research institutions that focus on quality-of-life outcomes for 

communities of color, including access to transportation, living-wage opportunities, 

quality education and meaningful community engagement in the development process

In this new offering, construction projects that fall within this equitable development 

framework, would be prioritized

Through our forward commitments, securitizations and this novel construction-topermanent loan purchase program, Freddie Mac aims to mitigate obstacles to new 

construction to alleviate a shortage of rental units, increase affordability and further 

equitable housing

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 66
Goals

Period  Key Action Items  Goals 

 Year 1 – 2022 Forward commitment 

• Formalize underwriting flexibilities for forward commitments

• Develop standards for underwriting novel construction methods

• Promote offerings to our lender network

Construction Loan Sponsored Securitization 

• Analyze the feasibility to develop this offering

Construction-to-Permanent Loan Purchase

• Analyze the feasibility to develop this offering

• Commit to fund 15,000 units across these initiatives. 

 Year 2 – 2023 Forward commitment 

• Increase forward commitments

Construction Loan Sponsored Securitization 

• Engage with market stakeholders and develop parameters for credit enhancement and 

securitization of construction loans originated by small lenders

• Publish term sheet

Construction-to-Permanent Loan Purchase

• Engage with market stakeholders and develop parameters for construction loan offering

• Research and establish equitable development framework 

• Identify lenders to originate and service construction loans

• Commit to fund 20,000 units across these initiatives. 

 Year 3 – 2024 Forward commitment 

• Increase forward commitments

Construction Loan Sponsored Securitization 

• Execute first securitization of construction loans

Construction-to-Permanent Loan Purchase

• Launch offering and publish term sheet

• Begin purchasing construction loans

• Commit to fund 30,000 units across these initiatives (assumes 

implementation of offerings in 2023 and 2024). 

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 67
6.8: Rehabilitate Affordable Rental Housing

Market Challenges and Barriers

Safe, decent, affordable housing is a basic need. Nationally there is a profound

shortage of affordable housing, and much of the existing affordable housing 

stock needs rehabilitation or is at risk of conversion to market rate. While major public

programs such as LIHTC and Section 8 typically ensure a reasonable level of quality, 

outside of these programs there is less assurance

Public housing has suffered considerably from underfunding and resulting disrepair

The U.S. Government Accountability Office study estimates that $70 billion is require

to address the backlog of maintenance in the existing public housing rental supply 

alone. 65 Affordable property without public subsidy and regulatory agreements —

Naturally Occurring Affordable Housing (NOAH) — are often older and may have varying 

levels of deferred maintenance as well

66 Thirty-nine percent of renter households live 

in units built prior to 1970, which are more likely to have material issues relative to new 

rental units

As the severity of climate change continues to increase, so does the risk to property 

quality. Severe storms and weather events pose a threat to those living in the most

vulnerable areas. These residents, and those living in older, lower quality housing, are

disproportionately minority households

These challenges are especially apparent in smaller properties (5-50 units), which 

represent a significant source of naturally occurring low- and middle-income housing

According to the American Housing Survey (2019), approximately 50 percent of the 

U.S. population is housed in properties with 2-49 units, which also represent the mos

affordable housing segment for both owners and renters. These properties tend to be

more affordable to renters than both single-family and larger multifamily properties

67

65 https://www.gao.gov/products/gao-20-4

66 Slide 16 of the CoStar Report: https://2os2f877tnl1dvtmc3wy0aq1-wpengine.netdna-ssl.com/wp-content/uploads/ULIDocuments/ULI_NAAHL_Presentation.pdf shows a majority were built in the 1960s and 19

67 https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3449

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Despite their need for liquidity, small multifamily investors may not benefit from the 

access to equity that their larger counterparts have, and therefore, face greater barriers 

to investing in the rehabilitation of their properties. Terms for small multifamily renovation

loans often carry higher interest rates and require full recourse obligations, which put 

greater financial risk and pressure on the property owner

It is not enough to preserve the affordability of these properties. We must also find

ways to preserve and improve the quality of these rental homes and guard against 

environmental events that threaten the lives and livelihoods of residents in these 

properties and communities.  

Our Actions

Freddie Mac aims to provide financing through rehabilitation loans to improve the 

quality of affordable, decent, safe and sanitary housing, including properties available 

in racially or ethnically concentrated areas of poverty, formerly redlined areas and other 

geographic areas of underinvestment

We have identified five potential loan offering enhancements to support the 

rehabilitation of affordable housing. 

Action 1: Expand Eligible Uses of Our Preservation Rehabilitation Loan Offering

Properties that require substantial rehabilitation require specialized financing. Today,

Freddie Mac provides liquidity for financing on properties receiving new LIHTCs to 

support rehabilitation and to preserve long-term affordability. However, there are

additional opportunities to support rehabilitation on properties not receiving new 

tax credits. Examples of this include public housing, Section 8 Project-Based Rental

Assistance, and various state and local programs. We intend to expand our Preservation

Rehabilitation loan offering eligibility criteria to support these properties engaging 

in substantial rehabilitation, so long as they preserve affordability either through a 

regulatory agreement or through rent restrictions in the Freddie Mac loan agreement

EQUITABLE HOUSING FINANCE PLAN 68
Action 2: Develop “Bridge to Rehab” Loan Offering

Current owners of older properties may not be able to commit to necessary rehabilitation 

and may instead sell these properties to new owners. To support new owners who plan

to rehabilitate these properties, we intend to develop offering terms for a “Bridge to 

Rehab” loan to allow the new owner to acquire the property to preserve its affordability 

and commit to rehabilitation under our Preservation Rehab offering. We anticipate that

this will increase the ability of borrowers to acquire and rehabilitate older properties 

and compete with developers seeking to acquire older properties and, after substantial 

renovation, increase rents beyond affordable levels

Action 3: Expand Liquidity to Institutions Providing Rehabilitation Loans

Freddie Mac currently offers several seasoned and affordable loan pool securitization 

options to institutions that provide rehabilitation loans, such as small and minorityowned banks and CDFIs. Freddie Mac will provide greater flexibility in these offerings

to accommodate properties undergoing rehabilitation. These institutions are often

vital sources of capital to fund the rehabilitation of small and/or affordable properties

Expanding rehabilitation collateral eligibility will provide a valuable source of 

liquidity to small and medium-sized lending institutions that support improvement of 

affordable housing, including affordable housing located in in racially or ethnically 

concentrated areas of poverty, formerly redlined areas and other geographic 

areas of underinvestment

Action 4: Incentivize Climate Resiliency Property Improvements

For both affordable and conventional properties, Freddie Mac will design and 

implement incentives for owners of multifamily properties in areas vulnerable to the 

effects of climate change. These properties tend to be in historically underserved

communities. These incentives will allow owners to make capital improvements that

enhance resiliency to natural disasters and promote sustainability

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Action 5: Enhance Small Balance Loan Program for Rehabilitation

We will enhance our Small Balance Loan program, which serves small properties often 

owned by smaller, community-based developers, in two ways:  

• We will design and implement incentives for property owners who commit to set 

aside funds to make certain property improvements while maintaining affordability

We will establish parameters around required capital improvement, budget size and 

scope, as well as unit-affordability thresholds post-renovation, to ensure that the 

properties financed under these incentive programs remain affordable

• We currently offer advance permanent financing terms for small balance loans exiting 

rehabilitation bridge financing. We will expand this offering by arranging for the loan to

be funded by the Optigo lender prior to full stabilization of the property, with Freddie 

Mac delaying its purchase of the mortgage until stabilization. This would help reduce

the financial burden and uncertainty of bridge loans for small multifamily borrowers

EQUITABLE HOUSING FINANCE PLAN 69
Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period  Key Action Items Goals

 Year 1 – 2022  Preservation Rehabilitation Loan Offering 

• Expand Preservation Rehab eligibility standards

• Update term sheet and market to our Optigo lender network

Bridge to Rehab 

• Design Bridge to Rehab product offering

• Publish term sheet and market to our Optigo lender network

Liquidity to Institutions ProvidingRehabilitation Loans 

• Create standards for expanded pool of eligible lenders

• Conduct outreach and communication with lenders

• Fund 5,000 units of rehabilitated properties

• Of the 5,000-unit goal, fund 2,500 units of rehab in underinvested communities 

(50% of total goal)

 Year 2 – 2023  Climate Resiliency 

• Establish borrower incentives and resiliency improvement standards

• Publish term sheet and market to our Optigo lender network

SBL Rehabilitation 

• Establish enhanced incentives and parameters for property owners and 

capital improvement requirements

• Fund 12,000 units in rehabbed properties (assuming implementation of offerings in 2023). 

• Of the 12,000-unit goal, fund 6,000 units for rehab in underinvested communities 

(50% of total goal)

 Year 3 – 2024  • Increase loan purchases preserving property quality. • Fund 20,000 units in rehabbed properties (assuming implementation of offerings in 2023

• Of the 20,000-unit goal, fund 10,000 units for rehab in underinvested communities 

(50% of total goal)

EQUITABLE HOUSING FINANCE PLAN 70
6.9: Explore and Implement Methods to Preserve

At-Risk Affordable Housing through Freddie Mac 

Affordability Restrictions 

Market Challenges and Barriers

Over the past decade, rental housing has become considerably less affordable, as rent 

prices have risen faster than incomes. The inadequate supply of affordable housing and

rent pressures have been exacerbated by market conditions leading to displacement 

of tenants and other affordability challenges. There are already signs that the COVID-19

pandemic has worsened these challenges, particularly for minority renters. While rents

decreased in many markets temporarily in 2020, rent levels are already approaching 

or exceeding pre-pandemic levels in many markets, and rent growth rates are upwards 

of 10 percent annually in the summer of 2021

68  As stimulus, unemployment benefits 

and rent support wear off — and as new supply to the market continues to be limited 

and generally not affordable — rent growth could continue its long-term trajectory of 

outpacing income growth

To address the growing supply gap, it is necessary to not just create new affordable 

housing, but also preserve the existing affordable housing that is at risk of becoming 

unaffordable due to deterioration or conversion to higher rents. At-risk housing consists

of both properties with public subsidies, such as LIHTC, that are nearing the end of their 

affordability restrictions and unsubsidized NOAH properties. Per analysis from the National

Low Income Housing Coalition, more than 130,000 LIHTC units could reach the end of 

their affordability restriction by 2024. NOAH properties are likely at greater risk of lost

affordability, as they have no restrictions whatsoever

68 As reported by RealPage, Yardi Matrix and Witten Advisors.

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 71
The risk of lost affordability and displacement is particularly acute for Black and Latino 

renter households, which are disproportionately represented in NOAH and LIHTC 

properties. As of 2019, more than 30 percent of LIHTC households were Black and

15.5 percent were Latino, compared to 27.7 percent being whi

69 While national 

demographic data is limited on NOAH property residents, McKinsey research from 2020 

shows that 62 percent of NOAH units in Los Angeles County are in “zip codes where 

more than half of residents are people of color.”7

Federal programs such as LIHTC and Section 8 are vital to creating and preserving 

affordable housing, but they are not adequately funded to address the entirety of our 

nation’s supply challenges. Too often, those motivated to purchase at-risk affordable

housing and keep it affordable must compete with buyers whose intention is to increase 

rents. Additional and deliberate preservation efforts leveraging private capital are

necessary to address this issue

Our Actions

Freddie Mac aims to address these threats to affordability by expanding existing and 

exploring new loan offerings that mandate affordability restrictions through Freddie 

Mac’s loan agreement. This approach will allow private investment capital to be directed

toward preserving affordability and will allow limited public subsidy to be applied where 

it is most needed and most effective

Freddie Mac has identified three principal loan offering concepts that can enable us to 

preserve thousands of units of at-risk affordable housing over the first three years of our 

Equitable Housing Finance Plan

Action 1: Expand Tenant Advancement Loans

Freddie Mac will seek to expand both the volume and borrower network who engage in 

its Tenant Advancement Loans such as through its Tenant Advancement Master Financing 

Commitment, which allow us to support property owners who have integrated social 

impact practices into their business models

69 HUD LIHTC Data: https://www.huduser.gov/portal/Datasets/lihtc/2019-LIHTC-Tenant-Tables.

70 Preserving the largest and most at-risk supply of affordable housing |McKinsey 

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

These practices include both providing tenant social services at properties and preserving 

affordable housing through rent restrictions enforced by the Freddie Mac loan agreement

In its expansion efforts, Freddie Mac will continue to engage property owners who perform 

needs assessments to determine which services are offered at the apartment communities 

we finance. We also expect the owners’ management plan to include dedicated staff or

a retained non-profit to engage meaningfully with the resident community and practice 

cultural competence to best serve diverse tenant bases. To date, Freddie Mac has funded

approximately $1.1 billion in Tenant Advancement Commitments across four sponsor

Loans Freddie Mac purchased under these Commitments have resulted in 4,720 units 

restricted through the Freddie Mac loan agreement at 80 percent AMI and 100 units 

restricted at 60 percent AMI. Further, 40 percent of properties financed were in or close

to a High Opportunity Area (as defined by FHFA in the Duty to Serve regulation) and 36 

percent were in or close to a R/ECAP. Under our Equitable Housing Finance Plan, we will

expand the use and impact of this offering

Incentives in the form of credit flexibility and advantageous pricing assist missionfocused borrowers in their efforts to acquire market-rate multifamily properties. Without

incentives, rents typically rise to market-clearing levels, risking displacement of existing 

residents and removing naturally occurring affordable units from the rental supply

Greater incentives for rent restrictions will be considered for properties located in high 

opportunity areas and/or areas of greater risk for lost affordability. In exchange for these

benefits, we will also require reporting on tenant services. This will better enable Freddie

Mac to attract impact-motivated investment capital through our Impact Bond program

Action 2: Preserve LIHTC At Risk

For LIHTC properties where the affordability restrictions expire during the Freddie 

Mac loan term, we will explore ways to incentivize borrowers to preserve the 

affordability beyond the period of regulatory restriction. To receive our incentives,

owners would be expected to commit to extend their current regulatory agreement or 

restrict at least 20 percent of the units at the property for the entirety of the loan term

This commitment would be enforced through the Freddie Mac loan agreement. We

would formally brand this offering and promote it through our lender network. This

offering would be informed by our research described below in section 6.1

EQUITABLE HOUSING FINANCE PLAN 72
Action 3: Preserve NOAH Properties

Freddie Mac will explore methods to preserve NOAH property affordability by working 

with Social Impact Funds, non-profits and ESG-driven capital with experience in 

affordable multifamily ownership to provide preservation-focused capital. Often the

preservation of these properties, particularly in high cost, high opportunity areas require 

additional capital beyond first-lien debt from Freddie Mac. Under this concept, we could

potentially identify and work with social impact, non-profit and ESG fund investors to 

provide mezzanine financing subordinate to a Freddie Mac-purchased and guaranteed 

first mortgage. Through the Freddie Mac loan agreement, we would expect that a

meaningful portion of the units at the property be restricted at affordable levels based on 

the market

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period  Key Action Items  Goals 

 Year 1 – 2022  Tenant Advancement Loans 

• Review first round of tenant service reporting metrics and ongoing 

rent restrictions

• Seek to increase number of new borrowers using this offering

• Purchase loans that preserve at risk housing

• Preserve 1,000 at-risk housing units through Freddie Mac rent restrictions. 

 Year 2 – 2023  At-Risk LIHTC Preservation 

• Explore and develop credit flexibilities and/or incentives to preserve 

at risk LIHTC

• Publish term sheet and market to our lender network. 

 NOAH Preservation  

• Explore and develop credit flexibilities and/or incentives 

for NOAH preservation

• Publish term sheet and market to our lender network

• Preserve 3,000 at-risk housing units through Freddie Mac rent restrictions. (Assuming

implementation of offerings in 2023). 

 Year 3 – 2024  • Increase loan purchases preserving at-risk housing.   • Preserve 6,000 at-risk housing units through Freddie Mac rent restriction

(Assuming implementation of offerings in 2023)

EQUITABLE HOUSING FINANCE PLAN 73
6.10: Analyze Low-Income Housing Tax Credit

Properties at Risk of Lost Affordability 

Market Challenges and Barriers

The LIHTC program has grown to be one of the largest affordable rental housing 

programs in the United States. The duration of LIHTC affordability, however, is not

indefinite. The affordability restrictions on LIHTC properties last at least 15 years during

the Compliance Period. After 15 years, some properties may remain in the program for

an additional 15 years (or longer, depending on the state), during what is known as the 

Extended Use Period

Other properties, depending on the state, have the option of leaving the program and 

dropping affordability restrictions through what is known as the Qualified Contract (QC) 

process. A property can also renew LIHTC credits and restart the affordability time

Thousands of properties have exited the program through the QC process — but even 

more may leave soon by reaching the end of their Extended Use periods

Expiring affordability is an urgent issue, potentially impacting hundreds of thousands of 

affordable units in the next several years and disproportionately affecting minority renters

As of 2019, more than 30 percent of LIHTC households were Black and 15.5 percent

were Latino, compared with 27.7 percent being whit

71

71 HUD LIHTC Data: https://www.huduser.gov/portal/Datasets/lihtc/2019-LIHTC-Tenant-Tables.p

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Understanding where and how this issue is developing will provide valuable insight on 

how and where states can prioritize limited resources for greatest impact through LIHTC, 

private activity bonds and other subsidy programs and how Freddie Mac can leverage 

our loan offerings and preservation activities under our Equitable Housing efforts. 

Our Actions

Freddie Mac will analyze the magnitude of LIHTC property affordability loss as well as 

where it is most likely to occur. While other research has been conducted on this topic,

our work will provide a more market-specific assessment of risk to affordability of units 

when restrictions expire. We will publish the results of this research in a paper that

identifies markets where LIHTC properties are at greater risk of lost affordability and 

examines these findings in the context of available public subsidy such as private activity 

bond and state-level LIHTC allocations

In addition to publication, we will leverage this research in our efforts described above 

in Section 6.9 to increase the preservation of at-risk LIHTC properties through Freddie

Mac loans on properties seeking to extend affordability through new LIHTC or through 

Freddie Mac loans on properties that may exit the LIHTC program but will commit to 

preserve affordability through the Freddie Mac loan agreement

Goals

Period  Key Action Items  Goals 

 Year 1 – 2022  • Publish paper

• Leverage research to inform loan offering enhancements and application 

described above in section 6.

• Publish paper and enhance loan offerings as described above

EQUITABLE HOUSING FINANCE PLAN 74
6.11: Analyze and Identify Affordable

Rental Housing Needs 

Market Challenges and Barriers

Nationally, there is a profound shortage of affordable and available rental housing

According to the National Low Income Housing Coalition, there are 37 affordable and 

available homes for every 100 extremely low-income renter households nationwide. This

shortage extends to every state in the country, and it disproportionately affects minority 

households. Twenty percent of Black households and 14 percent of Latino households

are extremely low-income renters, while 6 percent of white non-Latino households are 

extremely low-income renters

72 The shortage is not limited to extremely low-income 

renters. In 48 states, the shortage extends to renters making 50 percent of AMI, and in

15 states and Washington, DC it extends to renters making 80 percent of AMI. Nearly

half of these renters are cost-burdened, meaning they spend more than 30 percent of 

their income on rent

Closing the gap of affordable and available housing is complicated by high costs of 

construction, land, labor and materials and by zoning that often restricts construction of 

new rental housing, particularly in areas of high opportunity. As a result, building new

rental housing that is affordable to those making less than the AMI is often not possible 

without public subsidy, and that public subsidy is limited. The federal government

subsidizes rents for around 4.4 million households per year, but more households qualify

for assistance than receive it

73 Even when a subsidy is available, public support is often 

not. Local groups often impede new development of affordable housing, especially in

areas of higher opportunity, where public opposition can delay projects for years or stop 

them altogether

72 https://reports.nlihc.org/sites/default/files/gap/Gap-Report_2021.

73 “Rental Housing: As More Households Rent, the Poorest Face Affordability and Housing Quality Challenges.” United

States Government Accountability Office

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 75
In broad terms, addressing this challenge is extremely daunting. It is made more

challenging by the fact that it is very difficult to gauge the need and the cost at more 

local levels. Further, it is important to not just create and preserve affordable housing,

but to do so in ways that further opportunity for renters — to provide access to affordable 

housing in areas of opportunity and to productively invest in formerly redlined 

communities and racially and ethnically concentrated areas of poverty. These challenges

make identifying goals for both the preservation of existing affordable units that may be 

at risk and the creation of new units at best time consuming and resource intensive and 

at worst nearly impossible. Without data and goals, it is harder to gain public support for

the funding to support either (a) the creation of new affordable housing and the zoning 

changes that may be necessary to enable it, or (b) the preservation of existing affordable 

housing that may be at risk of becoming unaffordable or obsolete

Our Actions

Freddie Mac will conduct research and develop tools to evaluate the differences in 

affordability characteristics in select markets across the country. Analysis can be used

to inform market decisions regarding supply of affordable housing. Through this work,

we will (a) explore the market and/or sub-market affordable housing profile at various 

income levels and (b) examine the feasibility of funding necessary to develop that 

housing in terms of debt financing, equity investment, and public subsidy required

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

The results of this analysis will take two forms:

• We will publish a paper analyzing the work and its key findings to help policymakers 

and capital providers better understand the local affordability housing needs

• We will also incorporate data and findings into a web-based tool that allows policy 

makers and capital providers to leverage understanding from our analysis and 

examine these needs in select markets across the country

In conducting our research and leveraging this tool, Freddie Mac will engage with 

stakeholders such as researchers, developers and localities to refine our analysis and best 

meet their needs

Once published, Freddie Mac will promote these materials and actively seek 

opportunities to work with stakeholders to leverage these materials in support of the 

many activities in our Equitable Housing Finance Plan to both create and preserve 

affordable housing in areas of opportunity and in formerly redlined areas and R/ECAPs

Because of the broad scope of this work and potential in-depth research and analysis 

required, it will likely take three years to complete

Goals

Period Key Action Items Goals

Year 1 – 2022 • Engage with market stakeholders

• Conduct research and analysis

• Identify and collect the data

• Conduct research

Year 2 – 2023 • Publish paper

• Engage with market stakeholders.Begin incorporating data into a webbased too

• Publish paper

Year 3 – 2024 • Complete incorporation of data into a web-based tool

• Publish tool

• Publish tool

EQUITABLE HOUSING FINANCE PLAN 76
6.12: Financial Empowerment for Renters: Credit

Building Through On-time Rent Reporting, CreditSmart 

and Equity Building for Renters 

Market Challenges and Barriers

Individuals with lower credit scores or those who are credit invisible face greater barriers 

to housing opportunity and wealth building than those with higher credit scores

These individuals may face higher risk of being screened out of rental applications 

(i.e., tenant screening services often rely on credit scores as a factor) and have greate

difficulty accessing credit, thus hindering their ability to obtain a mortgage, rent a 

house or apartment, buy a car, get insurance and even secure employment. This

challenge disproportionately affects Black and Latino households. Per research from

the Consumer Financial Protection Bureau, one in five Black consumers and one in nine 

Latino consumers have a FICO score of 620 or less. This compares to one in 19 white

consumers

74

The single largest and most consistent debt payment that most renter households 

make — their rent — is not captured in today’s traditional credit scoring model. Renters

have much lower credit scores (638 – “Poor”) than homebuyers (717 – “Good”) — and 

an even larger disparity is seen when scores are stratified by race. Poor credit scores

directly contribute to the growing wealth gap that exists today and can be harmful to 

renters’ financial future. Renters can benefit from both financial capability resources and

an efficient process that captures credit data to better help them manage their finances, 

plan for the future and achieve homeownership capabilities

Additionally, renters, unlike homeowners, do not build equity through their living 

arrangement. This also contributes to the wealth gap between renters and homebuyers

and makes it more difficult for renters to accumulate wealth and eventually become 

homeowners themselves — effectively contributing to the homeownership gap as well

Within the multifamily housing industry, Freddie Mac is looking to provide renters 

opportunities to a) increase or build their credit scores and b) build equity. We are

74 https://www.forbes.com/advisor/credit-cards/from-inherent-racial-bias-to-incorrect-data-the-problems-with-currentcredit-scoring-model

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

“I had so many problems because my credit wasn’t like 

700 or 800. But my bill pay history was 100%. Maybe 

you have some hardships in life, but if your payments 

are 100% now...I thought that was a little harsh and 

discouraging.”

– Prospective homebuyer, Freddie Mac ethnographic research

working to provide tenants with a service that allows for reporting of on-time rents 

to the three major credit bureaus to establish stronger credit scores. Stronger credit

scores open doors for tenants such as access to short-term credit options for emergency 

situations, qualifying for lower interest rates resulting in higher savings, providing 

economic mobility and improving their opportunity to become homeowners

Freddie Mac also intends to learn from owner/operators in the multifamily housing 

space that have begun identifying certain opportunities for renters to build wealth 

based on their living arrangements. Through outreach and research efforts, we intend

to identify standards for equity building opportunities for renters and develop a 

model of incentivizing this behavior to work at greater scale. The output of our work

in equity building opportunities for renters will tie closely to our Tenant Advancement 

Commitment discussed elsewhere in our Equitable Housing Finance Plan

EQUITABLE HOUSING FINANCE PLAN 77
Our Actions

Freddie Mac announced in November 2021 that it is programmatically incentivizing 

multifamily borrowers to report on-time rent payments to credit bureaus. As we

implement this program, we will increase the share of loans purchased that use this 

credit-building feature over time

In 2021, we began to test this capability by engaging a FinTech firm that provides 

software to capture on-time rent payments and report them to the three major credit 

bureaus. As of 3/31/22, Freddie Mac has already enrolled more than 20 sponsors,

526 properties and over 50,000 units with participants who own and operate properties 

with rent and income restrictions, 5–50-unit properties and larger market-rate properties

Renters at these properties with existing credit who saw an improvement have seen an 

average credit score increase of 41 points and these resources have created credit scores 

for over 15,000 renters who were previously credit invisible. In the next three years, we

intend to engage in the following three actions

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Action 1: Increase Rent Reporting for Credit Building

Partner with FinTech firm(s) to encourage multifamily borrower adoption of on-time 

rent reporting to strengthen renters’ credit scores. Freddie Mac’s goal is to make rent

reporting an industry standard and ultimately scale rental data submitted to the credit 

bureaus so it is no longer considered alternative credit data and can therefore be utilized 

in credit scoring models

Action 2: Introduce CreditSmart for Renters

CreditSmart® — Freddie Mac’s proprietary financial empowerment curriculum — is 

free and robust. Concepts start with setting financial goals and put the power in the

consumers’ hands to better understand concepts ranging from how to build a household 

budget, to saving for rainy day expenditures, to buying or leasing a vehicle. For renters,

CreditSmart can guide users through creating household budgets, determining 

how much to spend on rent and what their tenant rights and obligations are before 

entering into a lease. We intend to conduct targeted, deliberate outreach to renters by

incentivizing our borrowers, lenders and community organizations to offer these in-person 

coaching sessions and/or digital self-guided curriculum at the individual property level

Action 3: Research Credit Building Program Impacts

Freddie Mac will measure the inherent impact of our credit building program utilizing 

Credit Bureau data on renters in Freddie Mac-financed properties to capture credit 

scores before and after rent reporting, controlling for other potential drivers to isolate the 

rent reporting impact. This research can inform changes to the program and/or broader

market adoption

Freddie Mac also intends to identify and build out a core set of equity-building features 

— ranging from rent rebates to savings incentives for renters — that borrowers can 

implement at the property level. We will build incentives for those sets of features

into our loan offerings, with a specific focus on serving those most in need of these 

options. These features could be layered into offerings our sponsors are already using

through Freddie Mac to further increase the impact these offerings can have on tenant 

advancement and equity growth

EQUITABLE HOUSING FINANCE PLAN 78
Goals

Period Key Action Items Goals

Year 1 – 2022 Credit Building:

• Develop plans to increase scalability and adoption by promoting borrower adoption of rent reporting and 

addressing any program shortcomings

• Monitor and analyze available data to find ways to improve the program

CreditSmart:

• Begin renter and borrower outreach of the CreditSmart curriculum; encourage and find ways to incentivize 

borrowers and partners to promote the curriculum to their renters

• Require CreditSmart for certain high-impact loan offerings (e.g., Tenant Advancement Commitmen

Equity Building:

• Identify a core set of equity building features for renters that borrowers are currently using and determine if they 

are feasible and scalable

Credit Building:

• Make credit building available to 100,000 new units

CreditSmart:

• Implement strategy to deliberately market CreditSmart 

at multifamily properties

• Enroll at least five partner corporations in CreditSmart 

coach training

Year 2 – 2023 Credit Building:

• Increase scalability and borrower adoption of rent reporting

• Address any program shortcomings

• Monitor and analyze available data to find ways to improve the program

CreditSmart:

• Expand renter, borrower and community outreach of the CreditSmart curriculum

Equity Building:

• Launch program or loan offering, with a specific focus on serving those most in need of these options

Credit Building:

• Make credit building available to 100,000 new units

CreditSmart:

• Enroll at least five new partner organizations in 

CreditSmart coach training

• Offer the CreditSmart course to at least 5,000 renters

Equity Building:

• Execute at least one transaction that offers a distinct 

equity building structure or offering

Year 3 – 2024 Credit Building:

• Increase scalability and borrower adoption of rent reporting

• Address any program shortcomings

• Monitor and analyze available data to find ways to improve the program

CreditSmart:

• Expand renter, borrower and community outreach of the CreditSmart curriculum

Equity Building:

• Review incentives, impact and refine programs as needed

• Explore additional equity building features

Credit Building:

• Make credit building available to 100,000 new units

CreditSmart:

• Enroll at least five new partner organizations in 

CreditSmart coach training

• Offer the CreditSmart course to at least 10,000 renters

Equity Building:

• Increase equity building loan volume (specific targets to 

be set in 2023)

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 79
6.13: Identify and Implement Enhanced Baseline Tenant

Protections 

Market Challenges and Barriers

Landlord-tenant relationships are governed by state and local laws. While many states

may base their laws on the Uniform Residential Landlord and Tenant Act (URLTA) or the 

Model Residential Landlord-Tenant Code, there is significant inconsistency in these 

laws across the country

75 Consequently, there is significant inconsistency in renter 

experiences and their rights as tenants. The jurisdictional disparities affect not just tenant

rights, but also tenant life outcomes, as evictions or excessive late fees, for example, can 

have long-term and persistent negative impacts

These disparities are apparent when comparing states such as Texas and New York, 

where both the level of discretion afforded to landlords and the grace periods for rent 

payments vary considerably

In Texas, the landlord has great discretion with respect to late payments and eviction

Rent is considered late the day after it is due. If included in the lease, the landlord may

collect a late fee following a full two-day grace period after the rent due date. No such

grace period is required, though, to provide an eviction notice. The landlord may

choose, but is not obligated, to provide the tenant a notice of missed rent along with the 

eviction notice. Once written, notice to vacate is given and the tenant is required to move

out of the property within three days (including weekends and holidays) even if no notice 

of missed rent is provided

76

By contrast, in New York, a landlord must wait five days after the rent due date before 

providing the tenant written notice by certified mail of the missed payment. If the landlord

chooses to pursue eviction for non-payment, they must first provide a written 14-day 

notice to pay. The renter then has 14 days to make the missed payment. The renter ca

either make the payment or move out. If the renter fails to make the missed rent payment

and remains in the unit, the landlord can proceed with the eviction process

77

75 https://www.law.cornell.edu/wex/landlord-tenant_

76 https://www.nolo.com/legal-encyclopedia/eviction-notices-nonpayment-rent-texas.html and https://

ipropertymanagement.com/laws/texas-eviction-proces

77 https://www.nolo.com/legal-encyclopedia/eviction-notices-nonpayment-rent-new-york.html and https://

ipropertymanagement.com/laws/new-York-eviction-proces

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 80
Inconsistent eviction protections throughout the United States and U.S. territorie

disproportionately impact minority renter households, particularly Black renter 

households. Per analysis from the Eviction Lab at Princeton University

• Black renters experienced the highest average rates of eviction filing (6.2 percent) and

eviction judgement (3.4 percent

• By contrast, the average eviction filing rate among white renters was 3.4 percent and

the average eviction rate was 2.0 percen

• Nearly one in four Black renters lived in a county in which the Black eviction rate was 

more than double the white eviction rate

78

Addressing these disparities and enabling an enhanced baseline of tenant protections 

with less opportunity for discretion in applying minimum standards can meaningfully 

address disparities in evictions and tenant life outcomes

78 https://evictionlab.org/demographics-of-eviction

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Our Actions

Freddie Mac will address disparities in tenant protections and tenants’ rights in two ways

First, we will conduct in-depth research on the amount, availability and degree of core 

tenant protections in all 50 states and Washington, D.C. and U.S. territories and 

potential implications of those variations on renters by race and ethnicity, particularly 

Black and Latino renter households. We will publish this research and promote it to our

lender and borrower network and to other market stakeholders, as appropriate

Second, after completing and publishing our research, Freddie Mac will work with 

market stakeholders, including tenants’ rights advocates, multifamily developers/

owners, property managers and FHFA to:

• Identify marketable tenant protection enhancements that could be applied to 

properties obtaining new multifamily GSE loans

• Develop a plan to encourage adoption of these enhanced protections over time on 

new multifamily GSE transactions

We will then implement these protections across our loan offerings in a manner that 

can foster scaled adoption and, ideally, establish a higher market standard for tenant 

protections

Goals

Period Key Action Items Goals

Year 1 – 2022 • Engage with market stakeholders

• Conduct research and analysis

• Publish paper

• Publish paper

Year 2—2023 • Develop and implement incentives as appropriate for enhanced tenant 

protections

• Begin purchasing loans with enhanced tenant protections

• Gather feedback on protections from a selection of borrowers who 

obtained these loans

• Enhanced protections included in applicable loan offerings

Year 3—2024 • Increase loan purchases on properties committing to implement enhanced 

tenant protections

• Consider refinements to incentives and parameters

• Fund 10,000 Units with Enhanced Tenant Protections

EQUITABLE HOUSING FINANCE PLAN 81
6.14: Analyze Housing Choice Voucher Availability,

Efficacy and Acceptance for Renters and Homeowners

Market Challenges and Barriers

Housing Choice Vouchers provide low-income renters and homeowners both access 

to affordable housing and greater choice in where they live, potentially increasing access 

to areas of higher opportunity. The program accomplishes this goal by paying subsidies,

which are a certain portion of the total rent, directly to the landlord, and the qualified 

household pays the remainder of the rent. Although Housing Choice Vouchers already

serve 2.2 million households, or 5 million individuals, the need far outweighs voucher

availability

There are other obstacles in obtaining voucher assistance, such as different state 

requirements, the need for additional subsidy layering and source-of-income 

discrimination. Additionally, the calculation methodology used to determine what rent

levels vouchers can support can also limit their efficacy in higher cost areas that may 

afford greater access to opportunity for renters

This combination of factors limits the ultimate impact of Housing Choice Vouchers, both 

in terms of supporting households who are severely cost burdened and in furthering 

access to opportunity for renters

Our Actions

Freddie Mac will research the usage and efficacy of Housing Choice Vouchers nationwide 

in providing access to opportunity using geographic, policy and data analysis

Based on this research, Freddie Mac will publish a paper that analyzes the severity and 

prevalence of factors that inhibit use of Housing Choice Vouchers, especially in high 

opportunity areas, and investigate where vouchers can and cannot likely support rent 

levels and homeownership. We will examine

• Where vouchers are used today

• Where vouchers have the potential to be used based on market rent levels and 

program rules

• How voucher usage aligns or does not align with areas that provide access to 

opportunity

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 82
Additionally, we will consider barriers to vouchers providing greater access to 

opportunity today as well as alternative scenarios under which vouchers could provide 

that access

While much research has been conducted on Housing Choice Vouchers, this analysis 

will be specifically directed to shed light on voucher usage as it relates to neighborhood 

affordability and opportunity and may contribute to development of — or outreach 

related to — Freddie Mac loan offerings or other efforts to maximize the impact 

of Housing Choice Vouchers. After publication, we intend to engage with market

stakeholders and organizations including HUD, housing authorities and multifamily 

owners and property managers to consider strategies that could increase the efficacy and 

acceptance of Housing Choice Vouchers and how these strategies could be advanced 

through Freddie Mac loan offerings

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

Goals

Period Key Action Items Goals

Year 2 – 2023 • Publish Paper analyzing the severity and prevalence of factors that inhibit 

use of Housing Choice Vouchers

• Publish paper

Year 3 – 2024 • Convene stakeholders to develop strategies to increase Housing Choice 

Voucher efficacy and acceptance, including through Freddie Mac loan 

offerings

• Identify strategies

EQUITABLE HOUSING FINANCE PLAN 83
6.15: Reform the Single-Family Rental Market with

a Focus on Equity, Affordability and Sustainability

Market Challenges and Barriers

Access to opportunity for social and economic mobility is too often aligned with living in 

suburban areas that are dominated by single-family homes and homeownership. This is

not an accident. It is a result of historic redlining and zoning ordinances that essentially

created and preserved suburban enclaves for white households, while excluding 

Black, Latino and other minority households. While there are many definitions of “high

opportunity areas,” we refer to areas designated in state LIHTC Qualified Allocation 

Plans (QAPs) and identified in FHFA’s Duty to Serve regulation. Single-family structures

comprise 88 percent of the total housing stock in these high opportunity areas, which is 

11 percent higher than outside of these high opportunity areas

79

While closing the homeownership gap can help increase access to the benefits afforded 

by high opportunity areas, often these areas are out of reach for first-time homebuyers 

given the relatively high cost of homes. Homeownership need not be the only way for

households to access these neighborhoods, but there is often limited multifamily rental 

housing, particularly with units large enough to be optimal for families with children

Single-family rental (SFR) homes offer an important alternative to access high-opportunity 

areas and provide families with more living space with lower rent than apartments on a 

square-foot basis

The SFR market still has difficulties for minority renters. Source-of-income discrimination

can prevent renters seeking to use Housing Choice Vouchers from entering high 

opportunity areas, and media coverage of evictions among larger SFR owner-operators 

suggests disparities in eviction rates between minority and white households. We are

also mindful that, with an overall housing shortage, financing for SFRs has the potential to 

reduce opportunities for first-time homebuyers and wealth building

For SFR to be a viable method to further access to opportunity, these issues need to be 

addressed, and a greater focus on equity is required than is present in the market today

79 Per Freddie Mac analysis, this only includes the 19 states with FHFA-defined High Opportunity Areas and excludes 

counties without any High Opportunity tracts to account for lower population density in rural areas

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

EQUITABLE HOUSING FINANCE PLAN 84
Our Actions

Freddie Mac entered the SFR market in 2018-2019 under a temporarily authorized pilot 

program. During the pilot, Freddie Mac purchased over $1.3B in SFR loan volume an

financed 16,140 underlying properties. The Freddie Mac SFR pilot

• Was focused on small and middle-tier borrowers

• Contributed to affordable housing supply by demonstrating that SFRs affordable 

at 80 percent of AMI could be created and well-operated

• Provided borrowers much needed access to credit with long-term financing at 

lower rates

• Targeted borrowers who operated in the affordable segment of SFR

Freddie Mac’s SFR pilot demonstrated the value of providing targeted financing for 

affordable SFRs. Our re-entry into the SFR market will take the lessons from our pilot and

apply them with a distinct focus on furthering equitable housing, supporting strong and 

tenant-friendly management practices, facilitating opportunity for homeownership and 

furthering access to opportunity for renters

Address the 

Homeownership Gap

Address Systemic Underinvestment 

within Formerly Redlined Areas 

Finance the Creation and 

Preservation of Affordable Housing

Eliminate Disparities Among

Members of Black and Latino Communities

Increase Opportunities 

for Renters

• Freddie Mac will aim to provide access to capital and thereby opportunity, particularly 

for emerging and diverse small and middle-market SFR borrowers. Furthermore, we

would not participate in financing large SFR transactions that involve 100 percent 

market rate or luxury rental homes, or fund equity buy outs, mergers or acquisitions of 

large institutional SFR owner/operators

• We will include additional equity-focused features in the program, such as:

o Working with SFR borrowers, lenders, tenants and consumer rights groups to develop 

an initiative that allows for the eventual sale of SFR properties to tenants, thereby 

returning homeownership opportunities to the single-family housing supply

o Requiring all borrowers to report on-time rent payments to the major credit 

bureaus and provide financial empowerment educational resources, such as 

CreditSmart, to renters

o Requiring acceptance of Housing Choice Vouchers where economically feasible

o Requiring enhanced tenant protections

o Incentivizing green improvements, such as installing energy efficient appliances 

and low water usage bathroom and kitchen fixtures

Goals

Period Key Action Items Goals

Year 1 – 2022 • Complete market, feasibility, and impact analysis

• Identify program parameters based on analysis

• Complete analysis

Year 2 – 2023 Finalize offering parameters and build business infrastructure:

• Establish the SFR Optigo lender network.Develop and set equity-focused requirement

• Develop standardized loan documents, loan parameters and procedures, tenant 

protection requirements and contract with a credit building group for sponsors/

borrowers to utilize

• Establish internal staff and resources

• Finalize offering parameters

Year 3 – 2024 • Launch offering

• Begin purchasing loans

• Loan purchase target will be set once feasibility and impact analysis has been 

completed and offering parameters have been established

EQUITABLE HOUSING FINANCE PLAN 85
SECTION 7

Conclusion 
Conclusion 

The inequities facing Black and Latino communities are longstanding, and addressing 

this crisis demands long-term commitment and focus. Freddie Mac’s Equitable Housing

Finance Plan sets a course that we—and our partners throughout the industry—will 

follow and improve upon for years to come, but it is only the beginning. We believe

the actions in this plan are meaningful steps that will help us address this urgent 

national priority and deliver on our mission of equitably making home possible

“The road ahead is challenging, but not 

insurmountable. With the partnership of lenders, 

investors, policymakers and other industry 

participants, we intend to make meaningful progress 

towards an equitable housing finance system that 

provides access to wealth, opportunity and a sense 

of home to people and communities across the 

United States.” 

 

 — Michael Hutchins, President

EQUITABLE HOUSING FINANCE PLAN 87
SECTION 8

Appendix 
SECTION 8: Appendix

8.1: Consumer Research Interview & Survey

Consumer interviews (56)

Access to Housing: 28 ethnographic interviews, 8 co-design workshops, 33 co-design participants

01 Consumer Life Stage

33 Industries worked in

39 4-year degree or higher

34 Renters

27 Homeowners

17 Single mothers

21 Former homeowners

23 Traditional families

02 Consumer Backgrounds

• Black & Latino backgrounds, 

residing in urban and suburban areas

• Credit score range of 580-835, 

 with median of 699

• Most facing at least one type of 

 debt, with many owing multiple types

28

In-depth interviews 

with past, present, and 

future homeowners

33

Co-Design Participants

8

Co-Design Worshops

• Bias & discrimination faced at 

 individual and institutional levels

• Economic barriers affecting/

 preventing homeownership

• Buyer/renter sentiment across 

 stages of the homeownership 

 & rental journey

03 Key Consumer Discussion Topics

1. Race-based Down Payment 

Assistance Program

2. Alternative Credit Data Points

3. Special purpose credit programs 

 with integrated financial hardship 

 management

4. Tenant protection resources and tools

5. Alternative security deposit models

6. Homeowner finance educational tools

7. Home counseling integrations with 

special purpose credit programs

8. And more...

04 Key Concepts Tested

San Francisco

Antelope

Los Angeles

Aurora

San Diego

San Antonio

Chicago

Houston

Dallas

Omaha

Antioch

Philadelphia

Manassas

Suwanee

Land O’ Lakes

Utica

New York

Jersey City

Newark

Durham

Sanford

Miramar

Germantown

EQUITABLE HOUSING FINANCE PLAN 89
Consumer interviews (56)

Housing Supply: 28 ethnographic interviews and 2 home visits

01 Consumer Life Stage

16 Renters

3 Prospective homeowners

9 Section 8 or other government

8 Single mothers

2 Traditional families

3 Looking or training for work

3 People with disabilities

02 Key Consumer Discussion Topics

• Understanding the consumer 

 journey to obtain affordable housing

• Major challenges of the ecosystem

• Quality of current living arrangements

• Desired places of investment within 

 their neighborhoods and communities

03 Expert Backgrounds

3 Developers

3 NGO

2 Home counselors

1 Underwriter

1 Investor

1 City government policy advisor

1 Trade association

Tacoma

Portland

Phoenix

Boston

New York

Atlanta

West Palm Beach

28

Consumers, couselors 

and experts interviewed

2

Home visits

EQUITABLE HOUSING FINANCE PLAN 90
Consumer Surveys (2)

Homebuying Journey Survey: 1600 Black and Latino respondents

Primary Residence Area

Suburban 49%

Urban 39%

Rural 12%

Credit Score (Personal Rating)

Fair 23%

Good 20%

Excellent 19%

Very Good 19%

Poor 11%

Don’t Know 39%

Family Composition

Children under 6 years 12%

Multiple children

under 17 years

12%

No children residing

Two+ seniors

(60 years and older)

16%

Children (6-17 years) 28%

Living Situation

Lives with romantic partner 27%

Lives with children 25%

Lives with parents 15%

Lives with other family members 10%

Lives alone 17%

Lives with roommates 6% Homeownership Status

Own a home fully and reside in it 27%

Do not own home, but planning to 15%

Own a home with mortgage

and reside in it

14%

Do not own home, with no plans to 7%

Own a home fully and rent it out 6%

Other 4%

Own a home with mortgage

and rent it out

3%

Do not own home, but would

like to buy one

25%

Gender

Male 46%

Female 54%

Age

Under 18 0%

18-24 8%

25-34 30%

45-54 17%

55-64 10%

35-44 35%

One senior 22%

No seniors 62%

47%

Reasons for Exiting Homeownership Process

During or aer attempts to repair/boost

credit score

20%

While looking for houses that met criteria 18%

During or aer doing further research

on processing

12%

During or aer applying for loan or

requesting pre-qual

9%

Aer checking credit score 9%

While searching for agent/realtor 3%

During or aer taking a homeownership

education course

3%

Aer making an offer 3%

During the contract negotiation 2%

Appraisal or inspection 2%

While trying to save for down payment 19%

EQUITABLE HOUSING FINANCE PLAN 91
Housing Journey Survey: Overview of key findings

1. When evaluating correlation between trust indicators and organizations, 

Black Americans’ trust correlated strongest with non-profit affordable housing 

organizations, whereas white American indicators correlated most with 

government organizations

2. Black Americans are more likely to consider homeownership as a personal goal 

(43.3% compared to 33%), whereas white Americans are more likely to consider

it as a financial investment (25.3% compared to 19.3

3. Black Americans tend to rely more on the formal homeownership assistance system 

(e.g., online resources, counsellors, lenders/realtors), whereas white Americans ar

more likely to find their networks of friends and family as most important for success

4. Black Americans feel they are more likely to be influenced by and find motivation to 

pursue the homeownership process from peer testimonials, compared to 

other groups

5. Black Americans are more likely to go through credit repair prior to the lending 

process, compared to white Americans (42.4% compared to 30.9

6. Online research was the most common source for realtors amongst Black Americans 

(49.3%), with the portion of those finding realtors through word of mouth

significantly less

EQUITABLE HOUSING FINANCE PLAN 92
Housing Supply Experience Survey: 500 respondents from Low- to Moderate-Income (LMI) backgrounds

N = ~ 500

Gender

Male 46%

Female 54%

Age

Under 18 0%

18-24 4%

25-34 17%

45-54 15%

55-64 19%

65 or older 22%

35-44 23%

Income Level

Primary Residence Area

Suburban 53%

Urban 27%

Rural 19%

Household Size

4 23%

1 - self 17%

2 23%

3 23%

5 9%

6 2%

7 2%

8+ 2%

Income Category

Medium Income 2 54%

Low Income1 91%

Children under 18 years 47%

Family Composition

People with disabilities 9%

Children over 18 years 19%

None of the above 19%

Seniors (65 years old+) 24%

Race or Ethnicity

Black/African American 63%

South Asian (e.g. India,

Pakistan, Nepal,

Sri Lanka, etc.)

1%

Asian (excluding

South Asian)

5%

Pacific Islander or 

Native Hawaiian

0%

Middle Eastern 0%

Other race or ethnicity 8%

White/Caucasian 26%

Hispanic/Latinx 26%

$50,000 - $74,999 27%

$25,000 - $49,999 21%

Less than $25,000 11%

$75,000 - $99,999 23%

$100,000 - $149,999 18%

$150,000 - $199,999 0%

$200,000 or more 0%

1. Defined as <$75K for families with 2+ members in household; 2. Defined as $100K-150K for families with 2+ members in the household 

Source: Consumer Survey. September 23-27, 2021 (N = 464)

EQUITABLE HOUSING FINANCE PLAN 93
Housing Supply Experience: Overview of key findings

1. Black and Latino respondents are more likely to be renters (47% compared to 34%) 

and are twice as likely to want to become homeowners than other ethnic groups 

(31% compared to 16%)

2. Though about half of LMI homeowners and renters are aware of financial assistance 

programs, only 14% of homeowners and 27% of renters apply as most don’t believe 

they qualify

3. 49% of LMI homeowners and renters report learning of assistance programs through 

word of mouth, making it the primary channel and demonstrating the importance of 

community in this process

4. 37% of LMI homeowners and renters feel they are overburdened with rent or 

mortgage costs, in line with market findings

5. For Black and Latino respondents looking to move, more space (53%) and home 

quality (25%) are the top reasons why; in ethnography, we learned that many families 

are living in tight conditions today given the lack of affordable options to upgrade

6. Quality defined as community (88%) and basics such as sanitary living conditions 

(78%), as heard in ethnographic interviews, were reinforced in survey responses

EQUITABLE HOUSING FINANCE PLAN 94
8.2: Industry Research Interview

Freddie Mac interviewed current and former employees from industry stakeholder 

organizations on the topics of access to credit and housing supply to inform our approach 

to this equitable housing finance plan. Industry consultation is part of our ongoing

commitment to engage participants and will continue going forward. Key learnings from

these interviews are outlined in this section

Access to Credit: Overview of key learnings

Individual motivation is a relatively small piece of the puzzle. 

Closing the gap is a matter of policy more than anything else.

If the tools, products, and programs supporting Black 

homeownership remain unchanged, so will the gap. 

Manual inefficiencies and lack of transparency don’t serve

Black Americans. With the right guardrails, tech might help.

Struggles to find the right narrative hook and data to communicate 

the why and how of closing the Black homeownership gap 

shouldn’t be a barrier to action, yet they are.

Lenders and agents have the greatest impact on homebuyers’ 

experience, yet the least incentive and accountability to deliver 

equitable service.

EQUITABLE HOUSING FINANCE PLAN 95
11th St Bridge Park

BH Management

Brookings Institute

C&B Mortgage Solutions

Center for Responsible Lending

Grounded Solutions Network

Home Center LA

Home Town Lenders

HomeFree USA

Landed

Local Initiatives Support Corporation

Mortgage Bankers Association

National Association of Realtors

National Community Reinvestment Coalition

National Council of State Housing Agencies

National Fair Housing Alliance

National Housing Law Project

Neighborhood Housing Services of 

New York City

NeighborWorks America

New Cities Foundation

Prime Lending

Quicken

Security National Mortgage

Tennessee Housing Development Agency

U.S. Ba

Urban Institute

US Mortgage

Wells Fargo

Access to Credit: Organizations Interviewed

EQUITABLE HOUSING FINANCE PLAN 96
Housing Supply: Overview of key learnings

Overall shortage of affordable units, 3.5M growing by ~325K units per annum

CAGR decline in construction of affordable rental units 7&5 and starter homes since 2010 ppts

50% Percent of Black/Latino population is cost-burdened

Percent of total housing units that are accessible, 2% while 14% of all Americans have mobility disabilities

Median house price growth vs. median income growth 2X for households in the lowest two quintiles since 2010 

EQUITABLE HOUSING FINANCE PLAN 97
The Ackermann Group

Alliance Bernstein

Amazon Housing Equity Fund

Arc70

ASO Holdings

BH Management

BlackRock

Breakthrough

Bulls Dixon Equity Partners

CBRE

Century Partners

CIC

ColRich

Comunidad

Cornerstone

Cortland

CPC

Credit Builder’s Alliance

Dantes Partners

David Baker Architects

DCRE

Divvy 

Dominium Group

Eagle Property Capital

Easter Seals

Enterprise Community Capital

Experian

Fairfield

Fannie Mae

Federal Housing Finance Agency

First American Title Insurance Company 

Florida Community Development Corporation

FPA

Ginnie Mae

Ginosko Development

Goldman Sachs

Greater Washington Community Foundation 

Green Mills Group

Grounded Solutions Network

Harbor Group

Holland & Knight

Home Partners of America

Impact Community Capital

International Finance Corporation

Irvine Company

Jeffries

JLL

John Burns Real Estate Consulting

JP Morgan

The Kelsey

Keystar

Ladera Capital

Launch Capital

Laurel Street

LDG Development

LifeSTEPS

McDowell Properties

Merchants Capital

Mercy Housing

Metaprop 

MG Properties

MRK

NAHB

National Fair Housing Alliance

National Low Income Housing Coalition 

NCLC

Neighborhood Assistance Corporation of 

America 

NeighborWorks

New Urban League

New York University

Nexpoint

NFHA

Nuveen 

NYC Comptroller

OakTree

OPC

OpenPath

Orix

PAC Properties

Palladius

Park Royal Capital

Pensam

PIMCO

Premiant Development

Railfield Realty

Rainbow Housing

RealPage

RHA

RJ Development

Rule Enterprises

Security Properties

SG Companies

Sidewalk Labs

SNS Capital Partners

Southport

Starwood

Systima Capital Management

TIAA/Nuveen

Urban Institute

US Department of Housing and Urban 

Devlopment 

USC Price

Vilma Enterprises

Waterton

Wharton

Yardi

Yes! Communities

Housing Supply: Organizations Interviewed

EQUITABLE HOUSING FINANCE PLAN 98
Access to Credit

Center for Responsible Lending

Enterprise

Fairway

Fortis

Grounded Solutions Network

Home Center LA

Home Town Lenders

HomeFree USA

Housing Assistance Council

Hudson Gateway Association of Realtors

Joint Center for Housing Studies

Landed

Local Initiatives Support Corporation

Moms 4 Housing

Mortgage Bankers Association

National Association of Minority Mortgage Bankers of America

National Association of Mortgage Brokers

99