Comment Detail
Date: 04/27/18 First Name: Senghor Last Name: Manns Organization: Harrisburg Housing Authority City: N/A State: N/A Attachment: N/A Number: RIN-2590-AA83 Comment
April 27, 2018
Submitted Electronically
Alfred M. Pollard, General Counsel
Attn: Comments/RIN 2590-AA83
Federal Housing Finance Agency
400 Seventh Street SW
Eighth Floor
Washington, D.C. 20219Re: AHP Notice of Proposed Rule – Comment period extension request
Dear Mr. Pollard:
I am writing to request additional time to comment on the Federal Housing Finance Agency’s (“FHFA”) proposed Affordable Housing Program Amendments (“Proposed Rule”) issued on March 14, 2018, with a 60-day comment period ending May 14, 2018. The Proposed Rule introduces new and complex requirements that would result in significant changes to the Affordable Housing Program (“the AHP”). The Harrisburg Housing Authority (HHA) serves over 5,000 people in the City of Harrisburg, PA. As a provider of quality low-income housing to those individuals, we have utilized the AHP program to assist financially in the development or rehabilitation of affordable housing in Harrisburg. Moreover, in the interest of full disclosure, HHA's Chief Executive Officer, Senghor Manns, is a member of the FHLBank of Pittsburgh’s Affordable Housing Advisory Council.
Given the importance of the AHP to FHLB members, program sponsors, stakeholders, and the communities they serve, adequate time is needed to assess and respond to the Proposed Rule. 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. For these reasons, HHA respectfully requests that the conclusion of the comment period be extended at least an additional 30 days to June 14, 2018.
We appreciate your consideration of this request.Sincerely,
Senghor A. Manns
Chief Executive Officer
Harrisburg Housing Authority