Comment on the FHFA's Small Multifamily Subgoal
This comment letter predates David Reiss's affiliation with Cornell 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 Thus, it should be withdrawn.
This paper has been withdrawn.