A lot has been made in the media of a proposed policy playbook for the current election cycle under the name “Project 2025,” a series of proposals published by conservative think tank The Heritage Foundation that would reshape many federal agencies and systems to more closely align with conservative ideology.
While not specifically mentioning Republican Party presidential nominee Donald Trump outside of references to his prior term in office, a sizable portion of the attributed authors of the playbook have either served directly in the first Trump administration or have pursued policy on its behalf.
But the official apparatus related to the Trump campaign — including Republican leaders, campaign representatives and even the candidate himself — have distanced themselves from the proposals. And Democrats have called the document an extreme policy prescription.
But with the presidential election being so close, as poll results largely fall within margins of error in most swing states, the concentration of former Trump administration officials named in the document might indicate that it could have some sway with decision makers should the election result in a Trump victory.
Practically, experts who spoke with HousingWire contend that documents like this one often have little influence on governing decisions. But Project 2025 could serve as a “menu” as incoming officials develop the policies they seek to implement.
HousingWire reached out to several former Trump administration housing officials about the likelihood of any of these policy prescriptions being pursued should the former president be elected, but all of them declined to comment.
The housing proposals
The full Project 2025 playbook comes in at a voluminous 922 pages, but the section specific to housing and policies of the U.S. Department of Housing and Urban Development (HUD) covers 14 pages. The bylined author of this section is Ben Carson, who served as HUD Secretary during the Trump administration and who was, notably, one of the few cabinet-level officials to remain in his post for the full duration of Trump’s term.
Like other areas of the document, the housing section is focused on minimizing government bureaucracy while emphasizing a need to shift American priorities to those that align with broader values of the conservative movement. These include a smaller government; self-determination in the form of limiting the scope of assistance programs; encouraging heteronormative nuclear families; and placing more agency control under political appointments rather than “career” officials who persist across administrations led by both parties.
Specifically, the overarching goals of the housing plan would seek a “reset” for HUD that would “include a broad reversal of the Biden administration’s persistent implementation of corrosive progressive ideologies across the department’s programs,” the section said. It would also redelegate authority to political appointees and determine if HUD functions under these templates would be better accomplished at other federal agencies.
The HUD secretary, under the proposal, would create a task force for the expressed purpose of identifying policy aligned with progressive ideology in order to reverse it. They would also put an immediate end to the “Property Appraisal and Valuation Equity (PAVE) policies and reverse any Biden administration actions that threaten to undermine the integrity of real estate appraisals.”
Project 2025 proposes the repeal of any climate change-related initiatives and terminology from official HUD policy and guidance. It also calls for repealing the Affirmatively Furthering Fair Housing (AFFH) regulation and changing policies to keep non-U.S. citizens from participating in HUD programs.
Interestingly — and potentially most consequential for housing — the document recommends increasing 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.” But it would also maintain current budget authority for technology modernization efforts.
The document also prescribed that under “ideal” conditions, Congress would look to fundamentally revise the Federal Housing Administration’s single-family housing mortgage insurance program and restrict availability to anyone who is not a first-time buyer.
What could happen
David Dworkin, president and CEO of the National Housing Conference (NHC), believes that context is key when assessing any of these policy proposals.
“The most important thing to understand is that these reports have been issued by the Heritage Foundation since 1980,” Dworkin said in an interview. “And they generally get the same treatment, which is they get put in a file that nobody can find again and are never referred to once an administration takes office.”
Dworkin has bipartisan political experience. He served in the George H.W. Bush administration as the U.S. Department of State’s acting deputy assistant secretary for legislative affairs. He also advised the Obama White House on housing matters for the city of Detroit and later advised Trump-era Treasury officials. He recalls a similar Heritage-authored plan during the first Bush administration that few of his colleagues paid much attention to.
The focus on Project 2025, he said, is likely reflective of the Democratic Party’s efforts to effectively use it to illustrate a disconnect between the ideologies and policy priorities of Republicans versus those of mainstream Americans.
“I think that the Democrats have done an excellent job drawing attention to these recommendations because they’re pretty extreme, which is why it’s been easy for former President Trump to disavow them,” Dworkin said. “I think that there’s a broad mix of recommendations, some of which are likely to be on any Republican HUD secretary’s agenda. Others will almost never be, and many of which [will be] in between.”
Dworkin calls the playbook an “extremely conservative, largely libertarian approach to governance, and no one should be really surprised that it seeks to dismantle the HUD infrastructure.”
As with any presidential election, the result will likely bring “significant changes” because all elections have consequences, Dworkin explained.
Scott Olson, executive director at the Community Home Lenders of America (CHLA), chose not to comment directly on Project 2025. But he did say that proposals in play do not impact the policies his organization will be pursuing.
“Regardless of what either presidential campaign is proposing, CHLA’s priorities are focused on strengthening federal mortgage programs and policies that address the significant first-time homeownership challenges we face as a result of the runup in mortgage rates the last few years,” Olson told HousingWire in a statement.
Dworkin also said the work of NHC will continue unabated, but the group will react practically based on which administration is sworn into office in January.
‘Waste of time’
One element of the playbook that Dworkin explicitly called an “incredible waste of time” is the proposal to roll back any climate change-related terminology in HUD guidance or policy.
“We have a very real crisis right now, and I am perfectly happy to let climate academics on either side of this debate argue about whether the climate change we are experiencing was man-made or not,” he said.
“Those issues are not housing issues. What is absolutely a housing issue is the devastation that is occurring throughout the country in geographies that have never experienced it before, and the intensity and regularity of ‘100-year’ floods and fires on a monthly basis.”
Climate change is a very real problem that will need to be dealt with no matter who is elected president, he added.
“Whether they name it or not, all you have to do is ask anybody in Asheville, North Carolina — which is 2,200 feet above sea level — why they suddenly have so much in common with New Orleans, Louisiana, which is 2 feet below sea level.”
