Skip to main content

  • Comment Detail

  • Date: 12/08/14
    First Name: Judith
    Last Name: Eakin
    Organization: North Hills Affordable Housing dba HEARTH
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA39

  • Comment

    North Hills Affordable Housing dba HEARTH is an affordable housing partner that works closely with community lenders and FHLBank Pittsburgh. We know the crucial role FHLBanks serve in providing funding for community banks. This proposed rule would alter the relationship between FHLBanks and their member banks and potentially harm affordable housing.

    Three years ago, HEARTH had to leave the property we had occupied for 16 years due to a sale. With the help of FHLBank Pittsburgh, we were able to rehabilitate an abandoned property and create 20 apartments of affordable housing for women and children experiencing homelessness.

    This rule 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. This will no doubt result in decreased lending by the FHLBanks which will hurt earnings. Ten percent of the net earnings of each FHLBank are directed to fund its Affordable Housing Program (AHP). Since 1990, FHLBank Pittsburgh has provided approximately $183 million in AHP grant awards to create more than 28,000 units of housing for low or very low-income residents. Should current and prospective membership in an FHLBank be threatened, FHLBank Pittsburgh’s ability to provide AHP grants to affordable housing partners will be diminished. Fewer funds will thus be available to provide AHP grants to support very-low and low-income housing at a time when homelessness is increasing. This will decrease the opportunity to develop additional housing for those in need.

    There exists a stable partnership between banks, affordable housing groups and FHLBanks through the AHP program that keeps at-risk families, veterans, senior citizens and people with disabilities from falling through the cracks.

    The neighborhoods we serve require access to credit to build new housing, rehab existing stock and stimulate community investment. An arbitrary asset test for continued FHLBank membership will achieve the opposite effect and hurt communities in the process. As a stakeholder in this process, HEARTH strongly urges the FHFA to withdraw RIN 2590-AA39.
    Comments