Comment on the FHFA’s Small Multifamily Subgoal
David J. Reiss, Brooklyn Law School
Jeffrey Lederman, Brooklyn Law School
Abstract
As the FHFA sets the housing goals for 2015-2017, it should focus on maximizing the creation and preservation of affordable housing. Less efficient proposed subgoals should be rejected unless the FHFA has explicitly identified a compelling rationale to adopt them. The FHFA has not identified one in the case of the proposed small multifamily subgoal. Thus, it should be withdrawn.
