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  • Comment Detail

  • Date: 12/23/14
    First Name: Frank
    Last Name: Woodruff
    Organization: Nat'l Alliance of Community Economic Dev Assocs
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Alfred M. Pollard, Esq., General Counsel
    Attention: Comments/RIN 2590-AA37
    Federal Housing Finance Agency, Fourth Floor
    400 Seventh Street SW
    Washington, D.C. 20024

    Re: Advance Notice of Proposed Rulemaking; Request for Comments – Members of the Federal Home Loan Banks

    Dear Mr. Pollard:

    We request that you reconsider the September 12, 2014 proposal published as a Notice of Proposed Rule-Making (NPR 2590/AA39). It is our belief that the proposed rule would harm access to development resources for homes affordable to America’s lower and middle class.

    As you know, each of the Home Loan banks sets aside ten percent of net earnings annually into the Affordable Housing Program (AHP), to be used to help finance development of homes that are accessible to low and middle-income Americans. AHP development funds are made available to our network only through our partners who are Home Loan bank members. AHP provides one of the largest private sources of grant funds for affordable home development.

    Local Home Loan banks bring much needed resources, expertise, and leverage to affordable home development throughout our network. That leverage yields extraordinary results as our network works to increase the development and preservation of affordable housing stock.

    The FHFA’s proposed membership rule appears to eliminate a significant number of current Home Loan bank members and therefore shrink the Home Loan banks’ resources and ability to ensure access to affordable homes for Americans. This proposal could shrink Home Loan bank advances by tens of billions of dollars.

    Our network of non-profit developers has gone through a seemingly unending cycle of austerity, having to produce at the same level while resources diminished. We are proud of what they have accomplished.

    However, the stone can only be bled so much. A severe reduction in AHP resources could have a devastating effect on the ability of low and middle income Americans to access an affordable place to live.

    We would ask respectfully to please work with us, our members, and the network of Home Loan banks to seek ways to increase support of home affordability --- and not marginalize our efforts for low-and moderate-income families, as we believe your agency’s proposal does.

    Sincerely,
    Frank Woodruff
    Executive Director
    NACEDA