David J. Reiss and Jeffrey Lederman. "Comment on the FHFA's Small Multifamily Subgoal"

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David J. Reiss and Jeffrey Lederman. “Comment on the FHFA’s Small Multifamily Subgoal”

David J. Reiss and Jeffrey Lederman. “Comment on the FHFA’s Small Multifamily Subgoal”

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 Thus, it should be withdrawn.

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