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  • Comment Detail

  • Date: 12/30/14
    First Name: Betsy
    Last Name: Crum
    Organization: Connecticut Housing Coalition
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I am writing on behalf of the Connecticut Housing Coalition and its member organizations to respectfully request that the FHFA withdraw its proposed membership rules. As a nonprofit advocacy and membership organization dedicated to creating and preserving affordable housing in Connecticut, I believe this proposal would have a strong negative impact on the ability of the Federal Home Loan Bank system to fulfill its promise of being a robust, integral part of the housing finance system.

    Since the collapse of the financial markets in 2008 and the subsequent Great Recession, we have faced overwhelming need for affordable housing at the same time both the federal government and the private sectors have retreated from their commitment to affordable housing. The Federal Home Loan Bank of Boston has been one of the few bright spots in these years. It is a strong and reliable partner that helps us address the unmet housing needs of low- and moderate-income working families. As a "gap filler" the FHLB has been one of the few options for leveraging state funds, and for first-time homebuyers, the Equity Builder Program has no equal.

    I have sat on the FHLBB's Advisory Council for the past 6 years and have participated in the process to ensure that the Affordable Housing Program provides much needed financing. Since its inception in 1990, 937 affordable-housing initiatives have been approved for funding in New England. This translates to nearly 25,000 units of safe, decent, and affordable housing for families, including the elderly and disabled. Further, a portion of AHP financing funds the Equity Builder Program, which provides grants to members for down-payment, closing-cost, homebuyer counseling, and rehabilitation assistance for low-income households. This year alone, 105 members were approved to access $3.2 million of these funds. That kind of capital and liquidity is enormously value in keeping our recovery going.

    The FHFA proposal would shrink the amount of private capital that makes it possible for FHLBanks to provide their funding, grants, and services to those of us in the business of creating affordable housing and community investment. We have been hit hard by budget cuts, economic declines, and political opposition at local, state, and federal levels. Reducing the number of FHLBank members will undermine the financial strength of FHLBanks, and we will begin to lose one of our last, dependable mechanisms for support.

    Please do not move forward with these changes, especially now, when we are finally seeing some "light" at the end of the "tunnel" caused by the Great Recession. Thank you for the opportunity to comment.