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  • Comment Detail

  • Date: 12/02/14
    First Name: Peggy
    Last Name: Robertson
    Organization: Depaul USA
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Depaul USA, a non-profit organization that provides services for homeless individuals, has benefited from the Federal Home Loan Bank Affordable Housing Program. It would be regretful to have a rule that will make membership in the FHLBank less attractive to banks and credit unions since continued access to FHLBank funding will be contingent on new ongoing asset tests. If current and prospective membership in an FHLBank is threatened, FHLBank Pittsburgh’s ability to provide AHP grants to affordable housing partners will be diminished. In short, FHLBank Pittsburgh will have fewer funds available to provide AHP grants to support very-low and low-income housing, especially one of our most vulnerable populations, homeless individuals.

    Depaul USA received an award from the FHLBank AHP that will provide permanent supportive housing to 27 chronically homeless men and women who have serious physical conditions. Our relationship with vulnerable populations with urgent needs for safe and affordable housing leads us to conclude that restricting the continued access of banks and credit unions to FHLBank membership will hurt communities.

    Depaul USA, Inc. strongly urges FHFA to withdraw RIN 2590-AA39.

    Sincerely,

    Peggy Robertson
    Director of Development
    Depaul USA
    5725 Sprague Street
    Philadelphia, PA 19138