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  • Comment Detail

  • Date: 04/27/18
    First Name: Roy
    Last Name: Lowenstein
    Organization: Lowenstein Development, LLC
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    I have been working as a developer or consultant with the AHP program since 1994 in Ohio and surrounding states. The program works reasonably well except for some rigidity in underwriting. Some of the proposed changes at the national level raise concerns which will take more time to work out than is now available. Of particular concern are some components of the "55% rule". The proposed rule requires the majority of projects to meet at least two of the three following housing needs:

    Underserved Communities and Populations – housing for homeless households, special needs populations and other targeted populations (e.g., agricultural workers, military veterans, etc.), rural housing, households with income at or below 30 percent of AMI, etc.;
    Create Economic Opportunities – housing in combination with life skills or economic empowerment, such as, employment education or training, homebuyer counseling, child care, health services, etc.; and,
    Affordable Housing Preservation – preservation of affordable ownership and rental housing.

    This will have the effect of diminishing the funding available for more "vanilla" new construction under the LIHTC program which is where the majority of our affordable housing is coming from. Many of these projects have funding gaps which the AHP ideally fills. If we focus the majority of our attention on special needs populations and preservation projects (both very worthy goals too, but not the majority of the need), we may be making a mistake.