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  • Comment Detail

  • Date: 06/11/18
    First Name: Kevin
    Last Name: Hanley
    Organization: The Residences at Wood Street
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    Thank you for the opportunity to comment on the recently released changes to the Federal Home Loan Banks’ Affordable Housing Program (“AHP”). I am the Executive Director of The Residences at Wood Street, a 501c(3) in Pittsburgh, Pennsylvania, whose mission is to provide supportive, affordable housing to low-income adults. Residences was awarded an AHP Grant (via member PNC Bank) in 2016 which led to approximately $750,000 of investment in critical building infrastructure, supporting 259 units of single room occupancy housing at our property.

    While I believe that I understand the rationale for your proposed changes, the outcomes-based framework as currently conceived establishes criteria that disregards local priorities and reduces local control of much needed community development funds. The current scoring-based system – with its robust, regionally specific implementation plan - provides transparency and accountability that would be lost in the proposed regime. Simply put, the current system isn’t broken, and is not in need of being fixed.

    I appreciate that you and your staff are reviewing and seeking improvement to current regulations; and, I commend you for your efforts to revise the AHP system. But I respectfully ask that you reconsider the outcomes-based framework as proposed.

    Thank you for your time and thoughtful consideration.