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  • Comment Detail

  • Date: 03/14/18
    First Name: Laura
    Last Name: Sandmann
    Organization: KeyBank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    An overwhelming majority of the clients I work with say that their biggest concerns and issues with the FHLBanks is that they just don't understand how affordable housing finance works when compared to all of the other funding sources out there. Ironically, the FHLB staff members blame the FHFA for restricting the ability of the individual banks to be flexible when it comes to underwriting and making exceptions. Therefore, my question to the FHFA is this...why did you feel that it was necessary at this point to change the trajectory of how the FHLBanks view the scoring system and whether homeownership or rental projects are more important in their district versus trying to be a more flexible and reasonable funding source from an underwriting perspective. I can assure you that I never get complaints from my clients that the scoring system is their biggest obstacle.