Comment Detail

Comment

The City of Boulder, Colorado supports efforts to expand access to mortgage financing for participants in shared equity affordable homeownership programs. These programs include community land trusts, deed-restricted programs designed for lasting affordability (such as many local inclusionary zoning policies), and shared appreciation loan programs. The city’s program includes approximately 800 units with permanent affordability deed restrictions enforced by the city and provides homeownership opportunities to an average of 70 low-, moderate- and middle-income households annually.

The city fully supports the incorporation of “Long-term Affordable Homeownership” under the “Affordable Housing Preservation” underserved market and of “Shared Equity Homeownership” as a “Regulatory Activity” under “Affordable Housing Preservation.” The city has evaluated Question 65 (Should affordable homeownership be preserved for longer than 30 years to qualify for Duty to Serve credit and, if so, for how long?) and comments that that 30 year affordability terms are sufficient in the shared equity homeownership definition because the other parts of the definition will ensure that affordability is preserved. The definition could be strengthened by clarifying that the entity administering the program must have an adopted policy or mission that establishes a commitment to permanent affordability. The qualifying statement, “or as long as permitted under state law” should be removed to avoid ambiguities about what is or isn’t permitted by state law. Leaving it in could unintentionally undermine the intent of the Rule.

Thank you for considering the City of Boulder’s comments.