Comment Detail

Comment

I have significant concerns about the proposed changes to the AHP scoring model. I have found the current model to work very well in a fair and straightforward manner that is predictable and transparent. The proposed outcome framework actually makes the AHP less flexible to meet local needs. The function of "re-ranking" proposals under the proposed changes makes it more difficult to have confidence that you are submitting a competitive proposal. AHP funds often help to provide important supplemental funding that is critical to the project's succeed. e.g. complementing LIHTC funding. When putting together your project pro-forma there are already a large number of variables. The current scoring system helps to reduce some of this uncertainty.

Requiring a project to set aside 50% of the unit for homeless or special needs populations imposed a significant requirement that may not always be able to be attained. Allowing the FHLBanks to amend district priorities allows for greater flexibility to fund worthy projects that has strong community impact. I recommend maintaining the minimum threshold of reserving at least 20 percent of the units for homeless and/or special needs households in order for a project to receive these points.

With regards to cash flow and debt service coverage ratios, there is already significant oversight to keep these amounts within reasonable limits while also ensuring the long-term financial viability of the project and protecting the project from volatility in the rental market and the economy.

Many projects that receive AHP funding already have significant oversight and administrative burdens from other funding sources including state housing development agencies and LIHTC investors.