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  • Comment Detail

  • Date: 05/01/18
    First Name: Jannease
    Last Name: Seastrunk
    Organization: Red River Bank
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA83

  • Comment

    AHP is a critical component of our community development efforts in all the markets we serve. Very few of the projects our bank sponsors are LIHTC projects and the proposed changes may significantly hamper our ability to support community development locally. More significantly impact future plans to participate in LIHTC projects locally. The current process is one of the few that is totally transparent. We commend the FHFA for working to update the AHP regulation. However, in light of the concerns above, we respectfully ask that you reconsider and/or eliminate parts of the proposed amendments, especially the required outcomes framework.