The Federal Home Finance Authority has proposed guidance which would terminate the use of Private Transfer Fees. Private Transfer Fees are paid each time a property is sold and are often used for community benefit programs. Private transfer fees have also been used to provide a continual source of income for developers and investors.
The FHFA has received in excess of 2,500 comments. While the FHFA is reviewing these comments the Center for Regulatory Effectiveness is asking the public and the regulated community to comment on the following public policy issues which emerge from CRE’s review of the public comments submitted to the FHFA:
1. Should the FHFA issue a rule in lieu of guidance?
2. Should the FHFA prepare an environmental impact statement on the transfer fee proposal?
3 Should there be a “carve out” for the public use of transfer fees?
CRE will analyze comments posted herein and submitt the resultant analysis to FHFA.
The Center for Regulatory Effectiveness is a regulatory watchdog founded by former members of the White House Office of Management and Budget http://thecre.com/ombpapers/OMB_Officials.htm
Please post your comments in the space provided either in the upper right corner or the space below.