Assessing the Feasibility of Comprehensively Evaluating Duty to Serve’s Impacts

Preserving affordable housing, reducing inequality in homeownership, and reaching underserved populations in the U.S. are significant priorities for the Federal Housing Finance Agency (FHFA) and the Government-Sponsored Enterprises Fannie Mae and Freddie Mac (collectively known as the “Enterprises”). Duty to Serve (DTS) is a federal regulation administered by FHFA requiring the Enterprises to finance affordable housing for low- and moderate-income American households in three underserved markets: manufactured housing, affordable housing preservation, and rural housing. The inaugural plan cycle began in 2018; however, there has never been a significant evaluation of DTS’ impact made public by FHFA or third parties, until now.

Through interviews with content matter experts, we determined “comparators,” which are standard of measurements to assess Fannie Mae and Freddie Mac against their DTS objectives in reaching underserved markets. We used these comparators as a starting point in our search for data to measure the Enterprises’ progress and to identify information gaps in the DTS process. Unfortunately, limitations on publicly available data and the plans’ vague objectives precluded a thorough evaluation of the Enterprises’ impact on underserved markets. Based on a review of previous and current DTS plans, a survey of FHFA reports, and qualitative research methods (e.g. interviews), we concluded that Fannie Mae and Freddie Mac must make improvements to their plans and FHFA must enhance its evaluation procedures in order for an informed analysis of DTS effectiveness to be conducted. In this paper, we recommend that FHFA adjust evaluation metrics in a way that encourages substantial DTS progress and addresses data transparency issues, specifically at the objective level. Additionally, we recommend that the Enterprises better define the aims and projected outcomes of objectives in their DTS plans.