Comment Detail

Comment

Champlain Housing Trust is a Community land trust that supports the people of northwest Vermont and strengthens their communities thought the development and stewardship of permanently affordable homes. In all CHT has just over 2,700 affordable homes under its stewardship serving people from homelessness to homeownership. Five hundred and seventy of our homes our in our shared equity homeownership portfolio and the balance are primarily conventional affordable rentals, with 20% serving special needs' populations and a smaller number in zero equity co-ops. CHT has over $300M in assets under its stewardship, an annual operating budget of $10M yielding $90M in economic activity annually in new development, loans, leveraged mortgages and private investments through LIHTC.
Our shared equity portfolio has just served its 1,000th family. We have 25-30 re-sales a year and we continue to add homes as well. We add to the portfolio though acquisition and new construction, inclusionary zoning (Burlington city only), foreclosures, and condo-conversions. We use ground leases and covenants as resale controls and we have an appraisal-based model that provides sellers with $25% of market appreciation in addition to their principal pay-down and the appraised value (at 100%) for capital improvements. This formula has worked well over our 32 years in this hot market and has been the subject of many studies and evaluations. CHT won the UN World Habitat Award for its model and has just received the National Renewal Award for local innovations in community development. The state of Vermont has adopted permanent affordability as its overarching policy for the production and preservation of affordable housing and has enacted a housing affordability covenant that we use, long with ground leases where possible to preserve affordability. These covenants also protect affordability in our rentals and LIHTC projects.
Access to mortgage financing is critical to our homeowners and we applaud FHFA for including housing preservation in its 'duty to serve' activities by "undertaking Regulatory Activities that support preserving affordable homeownership for single family properties under shared equity programs that are administered by a community land trust, a non-profit organization or a state or local governmental agency." We agree with the comment made by our national network, Grounded Solutions that eligible shared equity programs must ensure affordability for 30 years, monitor the units to ensure affordability is preserved over resales and support the homeowners to promote successful homeownership. However we recommend that the rule remain silent on the term of affordability as it relates to state laws. Thirty years is sufficient to assure permanent affordability in the vast majority of circumstances due to the frequency of re-sales and because the other parts of the definition will ensure that affordability is preserved.
Thank you for the opportunity to comment. Please do not hesitate to contact us if you have any questions.