PROJECT 2025 POLICIES AND THE HOUSING MARKET

With all the cuts to government agencies like HUD, CFPB and GSA, what impact is the Project 2025 mandate having on the housing market?

The Project 2025 Mandate

Trump may be sitting in the Oval Office, but Project 2025 is dictating policy. The playbook Trump insisted he’d never heard of is responsible for more than half of his actions thus far. The person reshaping the United States is Russell Vought, the architect of Project 2025, and current Office of Management and Budget Director. Vought wrote of his government role that “the Director must view his job as the best, most comprehensive approximation of the President’s mind” and that OMB should be “involved in all aspects of the White House policy process–powerful enough to override implementing agencies’ bureaucracies.”

The 922 page Project 2025 policy manual was developed by more than 140 veterans of  Trump’s first term in the White House, as authors and contributors, many of whom have returned to execute the Heritage Foundation’s government takeover.

As of this writing, here are some of the executive actions and policy measures taken by the Trump administration that closely align with–or exceed–Project 2025 recommendations:

1. Reinstatement of Schedule F, reclassifying federal employees to facilitate the replacement of career civil servants with political appointees
2. Dismantling the U.S. Agency for International Development (USAID)
3. Promoting fossil fuels through foreign aid
4. Issuance of over 50 executive orders implementing policies that, in many cases, surpass Project 2025’s recommendations
5. Elimination of Diversity, Equity, and Inclusion (DEI) mandates by removing DEI requirements at the federal level
6. Recognition of only two genders. Defining gender strictly as male and female in federal policies
7. Hindrance of labor-related agencies by firing key members of the National Labor Relations Board (NLRB) and the Equal Employment Opportunity Commission (EEOC), leading to operational paralysis
8. Disbanding of an FBI task force on foreign influence, reducing efforts to counteract foreign interference
9. Significant staffing cuts at the U.S. Cybersecurity and Infrastructure Security Agency (CISA), reducing the agency’s capacity to address cybersecurity threats
10. Attempt to end birthright citizenship via executive order
11. Appointing individuals involved in Project 2025 to influential roles within the administration
12. Executive orders to reduce federal regulations
13. Reduction of federal workforce
14. Mandating that for each new rule proposed, agencies must identify at least ten existing regulations to repeal
15. Issuing orders that directly impact global health policies and initiatives

Which actions being taken and advised by Project 2025 that will impact America’s housing market?

Between January 20 and February 28, 2025, the Trump administration has implemented several housing-related policy changes aligned with Project 2025’s objectives:

• Appointment of Scott Turner as HUD Secretary to advance the Opportunity Zones tax dodge for wealthy real estate investors, align with multifamily developers to privatize public housing, enact policies that oppose expansion of affordable housing and programs for the homeless, and encourage discrimination in housing
• Staffing cuts that eliminate up to 4,000 positions within HUD, impacting programs related to disaster recovery, rental subsidies, discrimination investigations, and support for first-time homebuyers
• Suspension of federal grants and assistance
• Freezing housing program funds. An executive action was initiated to suspend federal grants and financial assistance, including vital housing programs. A U.S. District Court judge granted a temporary restraining order on February 3, 2025, halting the freeze pending further review
• HUD delayed implementing changes to the HOME Investment Partnerships (HOME) program regulations initially set to take effect on February 5, 2025. Implementation has been postponed to April 20, 2025, to allow for further review and realignment with the Trump administration’s policy objectives
• In line with Project 2025’s recommendations, the administration has moved to repeal the Affirmatively Furthering Fair Housing (AFFH) regulation in an effort to reduce federal oversight in local housing policies, potentially impacting efforts to address housing discrimination
• Privatization of GSEs Fannie Mae and Freddie Mac. Consistent with Project 2025’s housing provisions, the administration has announced intentions to end the conservatorships of Fannie Mae and Freddie Mac, transitioning them into private entities, likely leading to higher mortgage costs for consumers
• Project 2025 calls for the complete dissolution of the Consumer Finance Protection Bureau. The Trump admiistration took a number of steps to comply. The administration placed CFPB leaders who planned to cut the bureau’s workforce in three phases: 1. Eliminate probationary and term employees 2. Make 1,200 layoffs 3. 60-90 days later fire the remaining skeleton crew of a few hundred workers.  The CFPB came under seige as planned. Trump fired Rohit Chopra and named Scott Bessent as acting director in January. Bessent sent staff home, immediately paused investigations, probes, litigation, rulemaking, and public communications, ordering staff not to make/approve filings or appearances by the Bureau in any litigation, other than to seek a pause to proceedings (February 3, 2025). Trump then replaced Bessent with Russell Vought, who canceled the lease on the bureau’s hedquarters, and ordered staff not to commence or take additional investigative activities related to or settle enforcement actions, and not to open any new investigations, to cease any pending investigations and all supervision and examination activity, also to cease all stakeholder engagement. Trump then nominated Jonathan McKernan as new Director of the CFPB (pending confirmation). Vought attempted to defund the agency (CFPB is funded via Federal Reserve budget requests, not appropriations, a process upheld as constitutional in 2024 by the Supreme Court), but several lawsuits have curtailed his actions. While Vought did place most CFPB staff on indefinite leave, firings and the refunding of funds to the Federal Reserve were halted by the courts. On Feb 16th, the Trump administration agreed to pause layoffs and funnding cuts. Court actions are pending to March 14th.

Holland & Knight CFPB      Five Men And A Phone      CNBC      SBPC

How Hobbling CFPB Will Impact Consumers

Changes to CFPB by the Trump administration will have significant negative consequences:

• Reduced enforcement can lead to more unfair lending practices and consumer exploitation
• Halted rulemaking will impact new consumer protection rules, including those limiting credit card late fees, overdraft penalties, and prohibiting abusive contract terms. This leaves consumers vulnerable to predatory practices
• Loss of financial recoveries in ongoing enforcement actions worth billions of dollars in potential consumer refunds are now in jeopardy, including cases against Capital One, Zelle, and Cash App
• Proposed rules to expand protections for electronic fund transfers and prohibit certain unfair contract terms have been halted, weakening consumer safeguards. Consumers may be exposed to risks in emerging payment systems and unfair agreements
• Companies may revert to poor practices related to hidden fees, junk fees and lax consumer data privacy
• Reduced access to legal remedies means consumers will face more hurdles in pursuing legal action against financial institutions, credit providers and debt collectors

The administration’s actions against the CFPB make consumers less informed, vulnerable to corruption and predatory practices, and limit their options for redress. They reveal that the Trump administration, and those in Congress supporting it, are anti-consumer. Per an article by The Brennan Center: “President Trump campaigned on providing economic relief to working Americans, promising to “drive down prices” on day one. His running mate, JD Vance, made his name with a message of economic populism, writing in his 2016 memoir that the nation needs “a leader who is not in the pocket of big business, but answers to the working man, union and nonunion alike.” It’s striking, then, that the administration is attempting to shutter the Consumer Financial Protection Bureau (CFPB), the federal agency whose mission is to protect consumers from the sort of deceptive and abusive financial practices that led to the 2008 financial crisis, in which millions of Americans lost their homes and life savings.” 

If the CFPB were to be dissolved, some of its functions would be assumed by banking regulators, but not in the same manner. The Federal Reserve, Office of the Comptroller of the Currency (OCC), and Federal Deposit Insurance Corporation (FDIC) would resume oversight of consumer protection laws for banks, roles which they failed to adequately perform previously, making the creation of CFPB necessary.

There would be no supervision of non-bank financial institutions because the CFPB is the only federal regulator of nonbank mortgage lenders.

CFPB is also the only authority equipped to provide enforcement against abusive financial practices. The Federal Trade Commission might assume this role, but is unlikely to perform it as well.

Oversight of major financial institutions like JPMorgan and Wells Fargo for consumer protection compliance would wane or cease

The unique CFPB consumer complaint system handles about 25,000 weekly complaints. There is no provision for reassigning these.

Responsibility for rulemaking relating to consumer financial products would be distributed among existing regulators, who are unlikely to pursue the task with any enthusiasm.

Enforcement of the 18 consumer financial laws consolidated under the CFPB by the Dodd-Frank Act  would need to be reassigned to other agencies for enforcement, or be abandoned.

In exiting his role as head of CFPB, Rohit Chopra  released a report advising states on consumer protections.

The Brennan Center

Project 2025 Outlines Steps to Reshape FHA

• FHA leadership should increase the mortgage insurance premium (MIP) for all products above 20-year terms and maintain MIP for all products below 20-year terms and all refinances;

• FHA should encourage wealth-building home ownership opportunities, accomplished best through shorter duration mortgages. Ideally, Congress would contemplate a fundamental revision of FHA’s statutory restriction of single-family housing mortgage insurance to first-time homebuyers. This would include (with support from HUD leadership):

  1. Moving the Home Equity Conversion Mortgages (HECM) program to its own special risk insurance fund

  2. Revising loan limit determinations

  3. Providing statutory flexibility for shorter-term products that amortize principal earlier and faster. Statutorily restricting eligibility for first-time homebuyers and abandoning the affirmative obligation authorities erected for the single-family housing programs across federal agencies and government-sponsored enterprises.

FHA is slated for a massive reduction in staff, with cited numbers as high as 40% of the agency’s workforce. This could impact loan processing and underwriting, as well as limiting access to affordable housing lending options for first-time home buyers and low-income families. If cuts are made to rental assistance and Housing First programs, there could be a huge reduction in affordable housing, ultimately leading to significant increases in homelessness, even among veterans and seniors.

Project 2025 Recommends Abolishing The CFPB and Privatizing Fannie & Freddie

• Abolish the CFPB: “Congress should abolish the CFPB and reverse Dodd–Frank Section 1061, thus returning the consumer protection function of the CFPB to banking regulators and the Federal Trade Commission.”
• Release Fannie Mae and Freddie Mac: “Treasury should take the lead in ending the conservatorship.”

Banking regulators and the CFPB protect consumers in different ways. Eliminating the CFPB would harm consumers and make it more difficult to prevent fraud by banks, mortgage lenders, originators and services, credit card companies, payday lenders, private student lenders, credit reporting agencies, debt collection companies, and others.

An upcoming post on this site will examine privatization plans by this administration for Fannie Mae and Freddie Mac. There is no upside for consumers in that scenario, and mortgage costs will rise as a result.

Project 2025 seeks to devolve and substantially gut HUD

Cuts to HUD are in line with steps outlined in the Heritage Foundation’s ultra-conservative playbook, designed to reduce or eliminate affordable housing; specifically public housing, housing assistance vouchers, first-time homebuyer assistance, and financial programs tailored toward minority homeowners.

It recommends policies that would transform HUD into a profit-generating, privatized enterprise, at the expense of those it was created to serve.

“What they want to do is be a development arm of the federal government and a boon to private enterprise that would be incredibly harmful to tenants and the recipients of housing policy,” said Noëlle Porter, director of government affairs at the National Housing Law Project, a housing law and advocacy center.

The policies detailed in Chapter 15 of Project 2025 strip rights and protections from immigrants, women, elderly people, and other vulnerable, already marginalized, populations—including veterans.

Porter says the overhaul would “ensure that HUD’s mission does not improve the quality of life or build inclusive and sustainable communities free from discrimination. It would entirely dedicate the office of Housing and Urban Development to tax credits and mortgage boosts and regulatory cuts for developers and owners.”

Here’s what Project 2025 says about HUD:

• The HUD Secretary should move the HUD Real Estate Assessment Center (REAC) from PIH to the Office of Housing, which already implements property standards in its multifamily housing lending programs through the multifamily accelerated processing (MAP) lending guidelines. Giving HUD the authority to streamline the enforcement of compliance with housing standards across the federal government and flexibility for physical inspections through private accreditation should also be considered.

• HUD should maintain its requested budget authority for modernization initiatives that are applicable to the Office of the Chief Information Officer and program offices across the department.

• Congress could consider a wholesale overhaul of HUD that contemplates devolving many HUD functions to states and localities with any remaining federal functions consolidated to other federal agencies (for example, by transferring loan guarantee programs to SBA; moving Indian housing programs to the Department of the Interior; moving rental assistance, mortgage insurance programs, and GNMA to a redesignated Housing and Home Finance Agency). Generally, this reform path could consolidate some programs, eliminate others that have failed to produce meaningful long-run results, and narrow the scope of many programs so that they are closer to what they were when they were created.

Here Are Project 2025’s First-Day and First Year Administrative Reform mandates:

(PG 503)

A new conservative Administration can and should implement the following reforms that focus on both people and process. Implementation of these reforms simply requires courageous political leadership across all of HUD’s key appointed positions.

• HUD political leadership should immediately assign all delegated powers to politically appointed PDAS, DAS, and other office leadership positions;

• Change any current career leadership positions into political and non-career appointment positions;

• Use Senior Executive Service (SES) transfers to install motivated and aligned leadership.

• The President should issue an executive order making the HUD Secretary a member of the Committee on Foreign Investment in the U.S., which will gain broader oversight authorities to address foreign threats, particularly from China with oversight of foreign ownership of real estate in both rental and ownership markets of single-family and multifamily housing, with trillions worth of real estate secured across HUD’s portfolio

• The Secretary should initiate a HUD task force consisting of politically appointed personnel to identify and reverse all actions taken by the Biden Administration to advance progressive ideology*

• The Office of the Secretary or the leadership in the Office of General Counsel should conduct a thorough review of all subregulatory guidance that has been instituted outside of the Administrative Procedure Act (APA).

Additionally, departmental leadership should:
1. Immediately end the Biden Administration’s Property Appraisal and Valuation Equity (PAVE) policies and reverse any Biden Administration actions that threaten to undermine the integrity of real estate appraisals;

2. Repeal climate change initiatives and spending in the department’s budget request.

3. Repeal the Affirmatively Furthering Fair Housing (AFFH) regulation re-instituted under the Biden Administration30 and any other uses of special purpose credit authorities to further equity.

4. Eliminate the new Housing Supply Fund.

How Does Project 2025 Dismantle HUD Protections?

Dismante protections for currently protected classes, and specific protections for marital status, economic status, health status and immigration status. (PG 508)

The Office of the Secretary should recommence proposed regulation put forward under the [first] Trump Administration that would prohibit noncitizens, including all mixed-status families, from living in all federally assisted housing.33 HUD’s statutory obligations include providing housing for American citizens who are in need. HUD reforms must also ensure alignment with reforms implemented by other federal agencies where immigration status impacts public programs, certainly to include any reforms in the Public Charge regulatory framework administered by the U.S. Department of Homeland Security (DHS). Local welfare organizations, not
the federal government, should step up to provide welfare for the housing of noncitizens.

• The Office of the Secretary should execute regulatory and sub-regulatory guidance actions, across HUD programs and applicable to all relevant stakeholders, that would restrict program eligibility when admission would threaten the protection of the life and health of individuals and fail to encourage upward mobility and economic advancement through household self- sufficiency. Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.

• Notwithstanding administrative reforms, Congress should enact legislation that protects life and eliminates provisions in federal housing and welfare benefits policies that discourage work, marriage, and meaningful paths to upward economic mobility.

• The AS or PDAS for the Office of Policy Development and Research should suspend all external research and evaluation grants in the Office of Policy Development and Research and end or realign to another office any functions that are not involved in the collection and use of data and survey administration functions and do not facilitate the execution of regulatory impact analysis studies.

The U.S. Department of Housing and Urban Development (HUD) workforce is being cut by 50% according to Housing Wire.

Bloomberg Law reports that the staff of 9,600 people being targeted are those who enforce civil rights laws, compule housing market data, and focus on post-disaster recovery and rebuilding.

Federal Housing Administration (FHA) is reportedly facing cuts of up to 40% of its staff, which could lead to a significant reduction in lending and hamper its ability to implement its new loss mitigation framework, which research estimates could cut the transition rate from serious mortgage delinquency to foreclosure by 46%. Currently, lenders have until February 2026 to implement the new framework.

The FHA provides mortgage insurance on loans made by FHA-approved lenders, expanding consumers’ access to home ownership. FHA insures mortgages on single family homes, multifamily properties, residential care facilities, and hospitals throughout the U.S. and its territories.

Enterprise Community Partners President and CEO Shaun Donovan, former HUD secretary and White House budget director, warned that cuts will impact market stability and increase home prices:

“Record high housing costs are putting the squeeze on families in every part of this country – from big cities to the suburbs to rural and Tribal lands and everywhere in between. At a time of record high inflation, housing is the largest component of cost growth in America. Arbitrarily severing funding streams and firing professional, impartial staff will only serve to destabilize our housing system and drive up costs for both renters and owners.”

Project 2025 Mandates Unaffordable Housing & Increased Homelessness

Housing Prices Will Go Up = Unaffordability

HUD’s workforce is being cut by 50%, which will significantly impact offices responsible for civil rights enforcement, housing market data, and disaster recovery funding. A new task force within HUD will evaluate spending and identify additional cost-cutting measures. Essentially, under the newly-apppointed HUD Secretary Scott Turner, the agency will begin to cannibalize itself.

Antonio Gaines, president of HUD Council 222 of the American Federation of Government Employees, said the HUD office experiencing the greatest losses is charged with managing programs related to homelessness, affordable housing and disaster recovery. Other targeted offices enforce civil rights laws, and research housing issues and HUD programs.

How does all this affect consumers and housing prices?  Cutting HUD staff and funding can lead to higher home prices by significantly reducing the availability of affordable housing. HUD plays a key role in supporting programs that provide rental assistance and facilitate low income housing development, which then puts upward pressure on the overall housing market because fewer affordable homes are available.

HUD programs for first-time homebuyers provide down payment assistance and mortgage insurance.

Housing Instability Will Increase = Homelessness

In a statement issued February 14 2025, the National Low Income Housing Coalition said housing instability, rent increases and homelessness would result from the staffing and funding cuts:

“President Trump’s directive will cause more people across the nation – in rural, urban, and suburban communities alike – to struggle to afford high housing costs and be at risk of housing instability, eviction, and, in the worst cases, homelessness,” said NLIHC President and CEO Renee Willis. “At a time when housing costs are far out of reach for renters and when homelessness is at an all-time high, our communities cannot afford for the Trump administration to decimate the federal agency tasked with helping low-income households remain stably housed.”

Terminating HUD staff will make it significantly harder for states and communities to access the congressionally approved federal investments needed to address their most pressing housing and homelessness challenges, including key federal resources used to:

• Provide rental assistance to help low-income households afford their homes.
• Build and preserve affordable rental housing for low-income households.
• Address and prevent homelessness, which has reached its highest level on record.
• Operate and maintain public housing and other affordable housing for millions of seniors, people with disabilities, and families with young children.
• Revitalize neighborhoods, promote economic development, and improve community facilities, including infrastructure and services in low-income communities.
• Reform restrictive zoning and land use regulations that inflate housing costs.
  Investigate and enforce fair housing and civil rights laws.
• Rebuild housing and infrastructure after major disasters and mitigate future harm.

As a direct consequence, homeless shelters will close their doors, communities will stop construction on new projects to build housing and community centers, households receiving rental assistance will face immediate rent increases and evictions, and communities, families, and small businesses impacted by disasters will be unable to rebuild, Willis said in summary.

Who Authored This Malignant Section Of Project 2025?

Referendum On Carson’s Term As HUD Secretary

Time and time again, Carson’s policies were determined to be biased and unfair, just as he himself was found to be unknowledgable, unfit and uncaring by many.

The Heritage Foundation is now attempting to indirectly legislate though a discredited, unelected author, resurrecting failed policies in order to again harm and disenfranchise Americans they consider unworthy of rights, protections and opportunities.

For The Record: What Actions Did the Biden Administration Take On HUD?

• COVID-19: HUD extended COVID-19 forbearance and foreclosure and eviction moratoria. HUD issued guidance to HUD recipients on how HUD funding can be used to support vaccination efforts, and engaged in partnerships on vaccination clinics.

• ARP: HUD made a $450M investment to provide American Rescue Plan funding to Native

  American communities across the nation. HUD awarded $5M in ARP funding to address the housing needs of low-income Native Hawaiian families. HUD is assisting the Treasury Department with implementation of the Emergency Rental Assistance Program.

• Homelessness: HUD allocated $5B in American Rescue Plan funds to increase affordable housing to address homelessness. Additionally, HUD awarded $2.5B to renew support to thousands of local homeless assistance programs across the nation. HUD also took steps to allocate $5B – roughly 70,000 vouchers – to people experiencing or at risk of experiencing homelessness. Secretary Fudge and VA Secretary McDonough issued a joint statement affirming their commitment to ending Veteran homelessness. HUD reaffirmed its policy that ensures equal access to homeless services for LGBTQ+ people.

• Affordable Housing: HUD made an allocation of $700M through the Housing Trust Fund to help states produce more affordable housing for extremely and very low-income households.

  Equity and Fair Housing: HUD announced that it will enforce the Fair Housing Act to prohibit discrimination on the basis of sexual orientation and gender identity. HUD began examining its “disparate impact” and Affirmatively Furthering Fair Housing (AFFH) rules. HUD took steps to implement the executive order on equity. Additionally, HUD stood up an equity leadership team across the Department and began equity assessments as an agency priority.

• Public Housing: HUD awarded $2.7B to improve and preserve the nation’s public housing. Funding was awarded to nearly 2,900 public housing authorities (PHAs) in all 50 states, as well as the District of Columbia, Guam, Puerto Rico and the U.S. Virgin Islands. HUD awarded an additional $13.7M to PHAs for emergency safety and security improvements.

• Puerto Rico: HUD has unlocked $14B dollars of the more than $20B in federal disaster recovery & resilience funding for Puerto Rico. This includes the removal of onerous restrictions unique to Puerto Rico that limited the island’s access to CDBG disaster recovery funds that were allocated following Hurricane Maria in September 2017 and the release of CDBG mitigation funds for improving the island’s resilience to future storms.

• Tribal Communities: HUD awarded more than $742M for affordable housing activities in Tribal communities. Additionally, HUD awarded more than $36M to support public housing and Native American residents in achieving economic and housing stability.

• Healthy Homes: HUD awarded $5M to promote lead hazard reduction and weatherization programs.

• Disaster Assistance: HUD implemented federal disaster assistance for the State of Texas to provide support to homeowners and homebuyers in areas affected by the severe winter storm.

• Jobs: HUD worked with its partners to add 360 businesses to the Section 3 Business registry, expanding access to employment opportunities for HUD-assisted individuals.

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