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  • Comment Detail

  • Date: 04/25/18
    First Name: Jeff
    Last Name: Curry
    Organization: JL Gray Company
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    Dear Mr. Pollard:

    As a member of the Federal Home Loan Bank of Dallas Affordable Housing Advisory Council, I am writing you to request additional time to comment on the Federal Housing Finance Agency's (FHFA) proposed rule RIN 2590-AA83, Affordable Housing Program (AHP) Amendments, which was issued on March 14, 2018, with a 60-day comment period that extends until May 14, 2018. The Proposed Rule introduces new and complex requirements that would result in significant changes to the AHP.

    As the FHFA recognizes in the Proposed Rule preamble, during FHFA’s comprehensive four-year review of the AHP, “…Banks and stakeholders uniformly expressed support for the AHP, viewing the program’s affordable housing mission favorably and acknowledging its longstanding reputation as a well-managed program and the critical role it plays in affordable housing initiatives throughout the country.” I agree that the AHP continues to serve one of the most successful and valuable private sources of funding for the financing and building of affordable housing in the United States.

    The proposed amendments represent the most extensive revisions to the AHP in over 20 years. At over 190 pages, the complexity and length of the proposed rule have presented analytical challenges even for those individuals within the FHLBank System who are most experienced in the nuances of the AHP. For less experienced stakeholders and other members of the public significantly impacted by the proposed amendments, a 60-day comment period is an unreasonably short period in which to prepare meaningful public comments.

    Additionally, an extended comment period is consistent with similar requests made by the 11 FHLBanks and their Affordable Housing Advisory Councils (AHAC) at a joint meeting with the FHFA in October 2017, in anticipation of this proposal. Therefore, I respectfully request that the conclusion of the comment period be extended.

    This time will be used to educate our partners that would be directly affect by the proposed changes and would allow them to make an informed response to the FHFA.

    I appreciate your consideration of this request.

    Sincerely,

    Jeff Curry