Comment Detail

Comment

To the Federal Housing Finance Agency,
I have just reviewed your amendment for the Affordable Housing Program as a part of my Public Policy and Advocacy class. Part of the assignment is to submit our comment to the agency whose regulation we reviewed, showing advocacy for or against the proposal. Admittedly, when I first reviewed the summary of your proposal, I was quite skeptical that it gave too much authority to the banks with regard to where they allocate their AHP funds. However, I think this is a good change to the current regulation because it allows for banks to create more homeownership set-aside programs, which would help benefit more people like veterans and low-income families. Additionally, I think the elimination of the retention agreement for owner-occupied units will be greatly beneficial to the banks because it gets rid of the difficult process they currently face of tracking small amounts of money. This will improve operational efficiency substantially, and I certainly hope this portion of the proposal goes through to streamline the process for the banks. You requested comments on whether or not a notice of sale should be provided to the applicant and the bank itself. It is my understanding that this is a common practice for banks, and I think this would help the process move along quicker. I think as long as the applicant agrees, there should be no reason why the notice of sale cannot go to both the applicant (designee) and the bank simultaneously. I liked this proposal because there was a focus on alleviating some of the processes that were just unnecessary or made things more difficult. I would advocate for this proposal because it benefits both the banks and the applicants.