The Consumer Federation of America submitted comments to the Federal Housing Finance Agency (FHFA) urging that Duty to Serve plans be made more ambitious, impactful, and attuned to market conditions.

The goal of Duty of Serve is not just to follow an expanding or contracting
housing market, but to help drive opportunities in underserved markets. FHFA should make more targeted equity investments, expand its
securitization access for small lenders and for more unusual mortgage
products, and significantly increase their proposed benchmarks.