Comment Detail

Comment

May 25, 2018

Mr. Alfred M. Pollard
General Counsel
Attn: Comments/RIN 2590-AA83
Federal Housing Finance Agency
Eighth Floor
400 Seventh St., SW
Washington, DC 20219

Dear Members of the Federal Housing Finance Agency,

As the executive director of The Coalition for the Homeless in Louisville, Kentucky and a member of the advisory board for the Federal Home Loan Bank of Cincinnati, I thank you for the opportunity to comment on the proposed changes to the FHLB Affordable Housing Program Rule.

First, I would like to say that I greatly appreciate the FHFA’s decision to create some required scoring categories while allowing local communities to design a scoring system that best fits the specific needs of their service area. However, my concern is that the proposed changes move from a system which has been very thoughtful and successful at the Federal Home Loan Bank of Cincinnati in selecting the best projects for our communities to an outcomes-based requirement system that forces the FHLBs to no longer evaluate what is best in their communities, but instead to avoid the penalties as described in Subpart G, question 41 of your listed questions. While your questions in Subpart E, questions 27-38 are important, they should be evaluated separately by each community resulting in different answers and scoring systems. Additionally, the new policies are very prescriptive making it difficult for local FHLBs or the FHFA to make changes and adapt to the market and community needs without making this type of program rule change on an annual basis.

I am very proud of the Federal Home Loan Bank of Cincinnati and their outcomes. Due to the staff’s unflagging efforts, they have consistently funded projects that serve those in greatest need and with the lowest incomes in our community. These projects leverage other funding and have great impact in our communities. My fear is that this proposal will instead require FHLB staff to focus on meeting the newly proposed outcomes forcing them to fund programs that will not require re-ranking after the fact or allocating additional funds to meet the stated outcome requirements. I understand that FHFA may want to have a greater say in the areas that determine ranking, but this can be done more effectively through the existing shared scoring structure.

I am happy to see that some up-front monitoring would be dropped, but I am more concerned that new monitoring requirements may be difficult or impossible to obtain. In response to your questions in Sub-part F, questions 39 and 40 about monitoring, I suggest that you do not require tax information and loan documents that the applicant does not have access to in assisting a client so that they can instead focus on the important documentation like client eligibility and project viability that is so important for program mission.

I agree that creation and coordination of a housing plan is important, but this could be addressed by requiring FHLBs to use existing data for planning made available through the Consolidated Plans in the region. I am also supportive of FHLBs requiring that applicants have access to services as we know these services are provided in the most successful programs when serving those with very low-incomes and high needs, but these services should not be included as part of the project financing. Finally, I am supportive of for profit entities serving on the FHLB advisory committees as we need everyone focusing on the great need for affordable housing, but I am not sure I understand the proposed requirement that the FULL board must decide allocations as it is difficult to get 100% of any body that serves multiple states to a single meeting.

Thank you again for this opportunity to comment. If you have any questions, please feel free to reach me at 502-636-9550 x 212 or nharris@louhomeless.org.

Sincerely,

Natalie Harris
Executive Director
Coalition for the Homeless
1300 S. 4th Street, Ste. 250
Louisville, KY 40208