In the Choice Neighborhoods Initiative, there’s a bit of a tension in terms of whether replacement units are required to be sited onsite, which often some tenants’ groups support because they don’t want to be displaced from their community, versus whether that reinforces concentrated poverty and harms fair housing objectives. Does your office get into any of these questions? And how in general do you think about balancing the right to move to opportunity, the right to be in a community, and the right not to be displaced from an existing community where you have connections?
This is an area in which we have been very involved. Among many of the allies that are usually on the same page there are different perspectives. If all we’re doing is investing in higher opportunity areas and areas that are less concentrated, what message is that to those who have lived in a community for years and lived through the toughest times? Are we saying that in order to succeed, you have to live someplace else? And are we fixing this community for somebody else to move into? It is a discussion that needs to be had and is often tailored to local needs. Our view is, we come down to choice and empowered choice — that the residents themselves need to be empowered with information, with analysis, and with the ability to move to places outside of where they are relegated. Also, if there are sufficient reasons for them to stay, such as their family has always lived there, or their church is there, or for some other reason, that they ought to be able to have that opportunity to stay, and stay in an area that has a higher quality of living, has access to good schools, and grocery stores, right there in their immediate neighborhoods.
This is one where it’s clearly not a one-size-fits-all. It’s one that requires a lot of honest discussion. We are resolved to reduce high-poverty neighborhoods, and you do that by empowering people to leave if they want to leave, but also to be able to stay with better opportunities — for education, transportation, jobs, and housing.
Recently, the National Community Reinvestment Coalition filed complaints over lenders’ unfair discriminatory policies, specifically the credit overlays that they’re putting on FHA loans, requiring higher credit scores. They say that this has a disparate impact on African-American and Latino borrowers. How are you working with those complaints, and how does the fair lending question dovetail with the broader fair housing question?
NCRC has done a tremendous service by taking up this subject. Obviously we look at all complaints on their merits, so they are getting a careful treatment from our headquarters staff and from staff around the country. Our job is to assemble a team of investigators who will expedite or move the cases forward, ideally within 100 days. If we need more time, we will take more time.
Clearly, there are important issues to be addressed, such as disparate impact against Latinos and African Americans with the raised FICO score requirements. Beyond that, I really cannot comment on any specifics of the investigation except to say that we are taking it seriously and moving forward.
It’s a very different world out there when it comes to the credit market. During the subprime boom people talked about reverse redlining and pushing predatory products in certain neighborhoods and to certain demographics. Now things have changed. How are you thinking about fair lending in general at this point, and what needs to be done to enforce it?
One part of that different world is the vast amounts of wealth that have been lost in African-American, Latino, and other communities. We are looking at the credit market to see whether some lenders go back to some of their old ways.
One area that we are looking at very, very closely is a new way of lending discrimination when it comes to women who are on maternity leave. While the federal law for family leave says that people are entitled to 12 weeks of unpaid leave, some lenders have assumed that maternity leave is unpaid, that women on maternity leave have no other income, and that there is no guarantee that there will be a job waiting for them when they return from leave. We’ve examined a number of cases from around the country and we are very close to a positive resolution that is intended to address the situation for existing victims of such policies, help us find other victims of current practices, and prevent future lending violations of the Fair Housing Act.