Comment Detail

Comment

Good afternoon Mr. Pollard,

Please accept this email as comments on the proposed amendments to the AHP regulation.

1. Local Scoring Discretion: The FHLB Banks are important partners in our efforts to build affordable housing. Since many of the issues that we deal with are specific to local markets, we believe that allowing individual banks maximum flexibility for addressing their issues is important. Our concern is that the FHLB we apply to may rank our project higher than another based on local needs, and then may have to pass it over for funding in order to meet less targeted FHFA goals. To this end, we would encourage FHFA to ensure that each banks have scoring discretion and that developers are able to evaluate our likelihood of getting funded by having transparent and predictable scoring that is within the control of the individual FHLB.

2. Project Modifications: the FHLB system of evaluating changes in projects in terms of their ability to score given changes to the project is a timely way to evaluate the impact of changes but not hold up the review unnecessarily. We’d urge FHFA to continue this process in lieu of the proposed “cure-first” requirement.

3. Development Team Evaluation: the current system of evaluating team members ensures that the sponsor is responsible for the success of the project. Since many of the team members may not be selected at the time of application, this is the most effective way for the FHLB’s to evaluate the project team. We’d suggest keeping the FHLB’s current practice of reviewing the development team.

4. Coordination with other Funding Sources: we have worked with several different FHLB’s and find that the ones that rely on the underwriting of the HFA administering the LIHTC’s are the most sensible to administer. The HFA’s are in a better position to evaluate based on regional trends and market-specific underwriting issues. Having a guiding set of underwriting principles allows developers to focus without having to reconcile sometimes competing criteria.

5. Long-Term Monitoring of LIHTC Projects by Sponsors: The proposal to require Sponsors to actively monitor LIHTC projects for 15 years should not be approved. A sponsor may have involvement only during the construction and leasing stage in the form of construction lending and then have no compliance interest in the project. LIHTC projects have long-term investors as well as HFA compliance departments that we answer to, and the addition of FHLB to long-term monitoring by Sponsor’s is unnecessary and unproductive as the Sponsor may no longer have an interest in the project.

Thank you for the opportunity to respond to these proposed amendments.