• By Matthew Hodson & Debra Goldstein

It’s Not (as) Easy Being Green in 2019

The Federal Housing Finance Agency (FHFA) recently announced that the Agencies’ 2019 lending caps will remain at the same levels as 2018, with $35 billion allocated to each lenderi. There are certain loan types the Agencies can originate that do not count against their caps, and green loans remain one of those exclusions. However, there are two significant changes to the green programs for 2019. First, the projected minimum savings for both energy and water has been increased to at least 30%, with minimum energy savings of at least 15%. Second, ongoing energy and water cost reporting must now be completed through specified third-party service providers. According to FHFA, “[t]he consumption reduction threshold ensures that the benefits from green renovations are passed through to the tenants, while the added data requirement allows FHFA to assess the efficacy of the Enterprises’ green improvements programs on an ongoing basis.” ii



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