On February 14, 2024, the Department of Treasury released an NPRM to combat the illicit finance risks from anonymous companies and all-cash real estate transactions. This rule would help local, state, and federal governments address the rapid and high-volume shifts in ownership of housing stock that are difficult to trace and track. As residential real estate ownership structures continue to evolve, local jurisdictions struggle to understand who owns their housing stock. This, in turn, has serious implications for tenants, prospective homebuyers, current homeowners, and local landlords who are impacted daily by absentee landlords that disrupt the fabric of our communities. 

On April 16, 2024, PolicyLink submitted the following comment supporting the Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury in expanding Anti-Money Laundering requirements to a broader category of investment advisors and collecting and reporting residential beneficial ownership data. The proposed rule will support efforts to identify predatory actors in the housing market, develop policy to halt their activity, and shift the benefits of ownership and housing stability back to the people who need it most: households who live and work in our communities.

We look forward to continuing to support the administration in regulating the residential real estate market to advance housing justice for the 100 million.

In April, HUD released a NPRM on reducing barriers to HUD-assisted Housing, namely reducing the barriers that criminal records pose on people trying to access HUD-assisted housing like public housing. This NPRM has been lauded by PolicyLink partners across the field as ground-breaking work from HUD. 

This NPRM came before the strong and comprehensive guidance that HUD released in late April. Although the guidance is more comprehensive, the NPRM still follows similar principles as the guidance. Specifically, the proposed rule tries to establish more equitable standards for HUD-assisted housing providers to evaluate criminal records when making housing decisions related to admission, eviction, and program termination.  

On June 10, 2024, we submitted the following comment supporting HUD’s role to regulate the usage of criminal records in housing decisions with brief recommendations that would improve clarity, consistency, and the impact of the proposed rule. 

We look forward to continuing to support the administration in regulating housing practices to support more fair, just, and equitable housing markets.