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  • Comment Detail

  • Date: 05/02/18
    First Name: Brady
    Last Name: Burt
    Organization: The Park National Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    As a member shareholder, board member and someone who is passionate about improving lives in our communities through better housing, I have some concerns about the proposed changes to the Affordable Housing Program (“AHP”).
    The FHLB of Cincinnati Board has and continues to delegate to a Committee of the Board, the responsibility for oversight of the AHP. This has been very effective and efficient from an operational and Corporate Governance perspective. The Proposed Rule states that a “Bank’s board of directors may not delegate to a committee of the board, Bank officers, or other Bank employees the responsibility to meet with the Advisory Council at the quarterly meetings required by the Bank Act.” This would reduce efficiency and effectiveness of the AHP as well as the Board of the FHLB.
    Specific to Questions 6 and 7 – The FHLBanks should have discretion to require and retention mechanism on owner occupied properties at its discretion.
    The proposed 55 percent regulatory outcome approach is too prescriptive and the penalties (reimbursement of the AHP pool) too severe. Instead, the FHLBanks favor a scoring based approach that incents certain types of projects without punishing the FHLBanks for failure to meet certain FHFA prescribed outcomes.
    The FHFA should allow the FHLBanks, their Boards and Affordable Housing Advisory Committees to determine the appropriate housing needs to be addressed within their District.
    Despite the FHFA’s best efforts, I believe the current regulation better serves the housing needs of the Fifth District than implementing the Proposed Rule.