Skip to main content

  • Comment Detail

  • Date: 04/23/18
    First Name: Carolyn
    Last Name: O'Doherty
    Organization: Innovative Housing
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    We have a number of comments on the proposed changes to the AHP program. The rigid scoring parameters will limit the number of applicants to the AHP program and also make it harder for FHLB's to play well with needs and priorities. Requiring 50% of all units to serve homeless and/or special needs households does not align well with local preferences and can also create challenging projects to manage. We prefer to create mixed income projects both for financial stability of the project and to avoid concentrations of poverty. I would also strongly request that resident services be allowed as an ongoing operating expense. Resident services are required by all of our project partners and the cost to provide them is real. Putting together separate operating budgets to FHLB than to other funders is confusing and adds unnecessarily complexity to project sponsors. Thank you for considering our concerns.