if it is purchased, developed, rehabilitated, or preserved in conjunction with a federal, state, local, or tribal government affordable housing program or subsidy, with the bona fide intent of providing affordable housing. this definition is intended to capture a wide variety of subsidies, including tax credit programs ( such as the low - income housing tax credit ), federal government direct - 8subsidies, and state and local government direct subsidies for the production or preservation of affordable housing. these programs could be for rental housing or homeownership. the suggested language is also intended to capture programs that do not provide monetary subsidies, but that have the express intent of producing or preserving affordable housing, such as a loan in support of a land bank program. in addition, many stakeholders have noted the importance of preserving unsubsidized housing that is affordable to lmi households and ensuring units retain their affordability in gentrifying areas. in response to these concerns, the anpr seeks to clarify the criteria under which banks can receive cra consideration for investing in unsubsidized, or naturally - occurring, affordable housing. we are also considering other options to ensure that housing - related community development financing activities maintain long - term affordability, limit displacement, and encourage affordable housing located in all communities. as experts in this field, we look forward to receiving your feedback on what specific data sources and criteria we should consider to promote the preservation of naturally - occurring, affordable housing. fifth, the anpr seeks feedback on the appropriate cra treatment of mortgagebacked securities ( mbs ) that are backed by loans that finance subsidized multifamily rental housing, loans for mixed - income housing that includes affordable housing for lmi families, or loans to lmi borrowers. while issuance of qualifying mbs can improve liquidity, and thereby increase capacity for lenders that make home mortgage loans to lmi borrowers, some stakeholders have expressed concern that mbs purchases may be undertaken in lieu of other more impactful community development financing activities that may require greater effort. - 9finally, the anpr seeks feedback on extending to cdfis the status that is extended to minority depository institutions, women - owned financial institutions, and low - income credit unions. such an approach would effectively give banks cra consideration for loans, investments, or services in conjunction with a cdfi anywhere in the country. additionally, the anpr discusses granting automatic cra community development consideration

including higher home prices and stricter lending standards. 5 for those who have purchased a home, higher home prices have translated into higher debt levels relative to household income. for renters, available subsidies or programs for affordable housing have fallen short of the need, particularly in higher cost cities, while new higher - end rental housing has increased significantly since the financial crisis. the high cost of renting leaves many families paying a higher share of their income for housing. american community survey data from 2019 show that 45 percent of renter households spend more than 30 percent of their monthly income on rent. 6 while 22 percent of renters pay more than half of their income toward rent, this figure jumps to nearly 38 percent for renters earning below $ 50, 000. 7 this leaves families with little to no room to save for emergencies, such as the covid - 19 pandemic. this growing shortage underscores the importance of the incentives provided by the cra for the production and rehabilitation of affordable housing. with the demand for affordable units significantly exceeding supply, it is essential to strengthen the incentives for these loans and investments as part of cra modernization. increasing access to affordable housing is critical to creating opportunities for homeownership for lmi households and with it the chance to build wealth through home see elliot anenberg, aurel hizmo, edward kung, and raven molloy, “ measuring mortgage credit availability : a frontier estimation approach, ” journal of applied economics, 34 ( 6 ), 865 - 882 ; laurie goodman, jun zhu, taz george, “ four million mortgage loans missing from 2009 to 2013 due to tight credit standards, ” urban wire : housing and housing finance ( blog ), urban institute, april 2, 2015, https : / / www. urban. org / urban - wire / four - million - mortgage - loans - missing - 2009 - 2013 - due - tight - creditstandards. united states census bureau, american community survey ( 2019 acs 1 - year estimates, table : b25074 ), https : / / data. census. gov / cedsci / all? q = acs % 20table % 20b25074, % 201year % 20data % 20for % 202019. see united states census bureau, american community survey in note 6. - 4equity. here too, cra plays a role, not only in providing incentives for the provision of affordable housing