ATTACHMENT "B-2" WHEREAS, this industry recognizes the urgent need for a balanced budget and a halt to inflation and expects to bear its share of the concomitant burdens, but it does not intend to be sacrificed quietly on the altar of bureaucratic ineptitude, and WHEREAS, we believe that nothing less than immediate action will retrieve the situation and the failure to act now will result in money shortages and housing shortages for the American people for many years to come; and WHEREAS, we are at a watershed in housing policy and the NOW, THEREFORE, BE IT RESOLVED, that NAHB gives a vote of no confidence in this Administration's Housing Policy and in the actions of those charged with administering this policy, and BE IT FURTHER RESOLVED, that NAHB urges the President of the BE IT FURTHER RESOLVED, that NAHB urges the Congress of the United States to preserve the ability of the Nation's thrift institutions to provide an adequate level of mortgage funds. NAHB RESOLUTION ATTACHMENT "C" September 22, 1973 COMMITTEE FOR HOUSING LOW INCOME FAMILIES OPPORTUNITIES FOR LOW INCOME FAMILIES WHEREAS, the President, in his recommendations for housing submitted to the Congress on September 19, 1973, proposed a system of direct cash payments to remedy the housing needs of America's low and moderate-income families, and WHEREAS, the President has not made a practical recommendation for a homeownership program designed to meet the housing requirements of low and moderate-income families, and WHEREAS, the date for implementation of this proposal is not until 1975 or later and cannot adequately answer the Nation's current, unmet housing needs, NOW, THEREFORE, BE IT RESOLVED, that the Administration be requested to release sufficient 235 funds to provide the Nation's low and moderate-income families with the opportunity to purchase homes of their own until a workable alternative is adopted and implemented, and BE IT FURTHER RESOLVED, that the NAHB reaffirms its support for all the Federal housing subsidy programs, urges HUD to release all impounded housing and community development funds, and urges the Congress to provide sufficient additional funds to keep these programs operating at a level consistent with the National Housing Goals until amendatory or new programs are enacted which are capable of meeting the housing needs of the Nation's low and moderate-income families. COMMENTS BY THE NATIONAL ASSOCIATION OF HOME BUILDERS ON H. R. 10688 (1) The findings proposed in section 102 are entirely inappropriate in that the present Federal housing subsidy programs have, in the last few years, been very successful despite a few difficulties and failures. No demonstration has been made that cash assistance or housing allowances is a more appropriate mechanism at an acceptable cost, as would be stated in these findings. (2) The proposed amendments, in section 103, to Title XVI of the Housing and Urban Development Act of 1968 should not be adopted. There is no way in which maximum use of the existing housing stock will enable low and moderate income families to obtain decent housing. Furthermore, major reliance upon the disciplines and economy of a free housing market just will not work in providing housing for low and moderate income families. These approaches have been tried in the past and failed. The proposal to eliminate the present 10-year goals and the goal for "the elimination of all substandard housing" are completely uncalled for and the present language of Title XVI should be retained. (3) The proposed rewrite, in section 104, of section 504 of the Housing and Urban Development Act of 1970 (the authorization of the housing allowance or cash assistance research program) should contain greater safeguards on the expenditure of public funds and the scope of what could be undertaken. This bill would grant HUD an entirely openended authorization. It seems particularly inappropriate that HUD should, at this stage of its involvement in providing housing assistance to the nation, need authority to spend funds to determine "the definition of safe and sanitary housing," as is contained in the proposed section 504(b)(1)(C). - 2 There should be some outside limit on the amount of funds which could be appropriated annually for this expanded experiment. Since it is an experiment, we further question the appropriateness of providing money for the purpose of developing "necessary administrative arrangements for a cash assistance program" until some decision has been made by the Congress as to whether to proceed with such a program. (4) The proposal contained in section 105 to permit HUD to use any or all of the available funds for the public housing program to carry out its housing allowance experiment should not be enacted. This raid on already inadequate public housing funds would sanction a cessation of the provision of needed additional public housing units, through either new construction or leasing. (5) The following comments relate to the provisions of section 201 which would be entitled the "Revised National Housing Act" and the section references relate to the sections of the proposed RNHA: a) The provision in section 101 (n), permitting the advance of mortgage proceeds to cover the cost of materials and building components which have been purchased for a project but are located at a site other than the mortgage property, should have certain safeguards built into it to protect the government's interests. As a minimum, such safeguards should require that title to these off-site items rest in the mortgagor; that there is adequate security to protect the government's interest; and the provision should be limited to assembled components specifically identified for incorporation into the mortgaged property. There seems to be no justification for advances to cover materials which can be delivered easily to the project site. b) c) We question the desirability in section 102(b) of giving HUD carte blanche authority to vary the terms of, and the extent of, FHA insurance. Any such exploration of new techniques of providing mortgage insurance should be done on a limited experimental basis until it is demonstrated as a satisfactory replacement of proven methods. Section 103, in giving the Secretary of HUD complete discretion to establish loan-to-value ratios for the various FHA singlefamily and multifamily programs, goes too far. While some adjustment is necessary in the present ratios for unsubsidized single-family mortgages, we believe that the setting of these - 3 d) e) ratios should remain with the Congress. The present ratios for multifamily programs have proven to be acceptable and workable, as have those for the single-family programs prior to the recent extremely high inflationary increases in housing costs. We urge that the present system of statutory ratios be retained and propose that adjustments, along the lines of those approved last year, be made to the present section 203(b) ratios to reflect necessary higher mortgage limits. We believe that it is inappropriate to permit a free market In the 1970 Housing and Urban Development Act, Congress directed that the FHA insurance funds, as well as other funds connected with FHA operations, be invested, to the maximum extent feasible, in direct or guaranteed U. S. obligations, the proceeds of which will be used to directly support the residential mortgage market. The proposed section 201 (f) does not retain this provision. Furthermore, we understand that HUD has failed to carry out the express intent of Congress in the 1970 Act. We urge that the 1970 provision be retained and that the Congress direct HUD to follow it. In times of mortgage credit shortages, such as the present, the reserves of FHA, amounting to over $1 billion, would be extremely helpful if invested in housingrelated obligations. 24-038 74 pt. 1 58 |