Mosley
322 Foreign Exchange
gave rise to federal interventions, it is important to focus on what these acts, institutions, and
tools mean to have an established pathway for public, private, and not-for-profit actors to produce
and finance housing and enterprises. The CRA requires federal regulators to ensure that the
financial institutions they oversee meet the credit needs of the communities they serve, including
low- and moderate-income neighborhoods.
14
The Act’s regulations were substantially revised in
1995 to strengthen and expand its reach and effectiveness.
15
The revised regulations provided
a greater statistically measured performance in banks’ lending; the changes required banks to
perform harder to get their grades (Erickson, 2009; Fishbein, 2003). The National Community
Reinvestment Corporation (NCRC, 2018) reports that banks have invested nearly $2 trillion in
small enterprise and community development loans over the past 20 years. “About 85 percent of
LIHTC investments come from banks, and CRA is a primary motivator,” says National Association
of Affordable Housing Lenders’ (NAAHL) President and CEO Benson Roberts, adding, “It’s unlikely
that LIHTC would have gained traction without CRA.”
16
CRA, which is under review as of this writing, is cited as a key element encouraging private
investments into underserved areas. While many stakeholders agree that CRA needs to be
improved, it is also important to note the impact when there is no CRA. A recent paper points to
consistent research results that lenders are “responsive to the incentives that CRA provides, and
that CRA designations matter in a changing financial landscape” (Ding, Lee, and Bostic, 2018:
2). In looking at small business lending for example, the study concluded that banks—from a
CRA lens—are sensitive to communities deemed low- to moderate-income (LMI), and borrowers
operating there may be treated more favorably (Ding, Lee, and Bostic, 2018).
The LIHTC is widely regarded as the underpinning of financing U.S. affordable rental housing.
In the New Zealand report (Mosley, 2018), the author touted the LIHTC as a successful model of
using a tax mechanism, and thus incentivizing private capital, to develop and preserve affordable
housing. Its flexible structure ensures local priorities are addressed in a highly competitive
investor-pricing, cost-efficient process. The long-term certainty of the LIHTC, leveraging of federal
housing programs like the USHUD HOME Investment Partnership Program, and Housing Choice
Vouchers has provided a level of funding certainty for developers, lenders, and investors, helping to
ensure pipelines of affordable units in cities, rural areas, and Indian Country. Used throughout the
United States, between 1987 and 2015, the LIHTC helped finance the development of 2.3 million
homes in 38,000 projects (HUD, 2017). The Federal Housing Administration’s (FHA) mortgage
insurance program provides mortgage credit for large private multifamily rental properties,
including LIHTC projects; in FY15 alone, mortgage insurance for rental and cooperative housing
covered 192 projects that included 30,412 units for almost $3 billion. (HUD, n.d.) Collectively,
LIHTC, CRA, HUD’s HOME, FHA programs and voucher subsidies provide an affordable housing
ecosystem. Banks provide equity and mortgage financing via LIHTC and CRA. Financing gaps are
addressed by HOME, housing trust funds, and other sources. Vouchers help low-income families
reliably afford rent. The net result is a complex, layered, public-private funding and financing
14
For more information, see https://www.federalreserve.gov/consumerscommunities/cra_about.htm.
15
Darryl E. Getter, 2019, The Eectiveness of the Community Reinvestment Act: Congressional Research Service
Report for Congress.
16
Comms with Benson Roberts, 2019.