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  • Comment Detail

  • Date: 04/25/18
    First Name: Don
    Last Name: Alexander
    Organization: Alexander & Hale Development
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    1. I feel like this the process is occurring very quickly. I would like to have more time to think about the ramifications of these changes before making comments. The comment period in too short

    2. I have a good deal of experience in applying for and using the AHP program to serve our community. I am in Tennessee so I use the Cincinnati Bank. They do an excellent job of using their Advisory Board to provide input as to how best to run the programs, and how best to hit targeted populations. Rather than the Federal Housing Finance Agency dictating priorities you should see that all Banks follow the Cincinnati model.
    3. I am amazed that the Agency would ask the Bank to re-rank applications. This is one of the aspects of these changes I wish I had more time to consider how this might impact the program. On the surface it seems that this could result in weaker application awarded. it may increase the recapture rate. It also seems that if I do not application that fits into a priority I will be competing for 45% of the funds rather than 100%. It does not seem like the priorities of the community at being considered. It seems arbitrary and without regard to the needs of the community.
    4. One of the great features of this program in the ability of the sponsor to create programs that serve the needs of the community. If the agency is setting the priorities it seems that will stifle that creative efforts. Soon all projects will be the same