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  • Comment Detail

  • Date: 06/12/18
    First Name: Joshua
    Last Name: Canale
    Organization: Moka Corporation
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    We believe that the current scoring criteria capture the intent of the program and allow needed units to be provided in our communities. The proposed changes decrease the likelihood of success for small community providers.

    Member Banks should be allowed to consider a modification as a cure solution pursuant to the Bank’s implementation plan rather than requiring a cure period before a modification. This delays the resolution of non-compliance.

    Homeownership properties receiving AHP assistance should have a retention period. The fact that misuse is not being detected in the system demonstrates the success of this practice, and should not be interpreted as a lack of need for it.

    Income verification at the initial monitoring phase is needed to verify compliance with the application but the proposed relief of this monitoring and reporting burden during the long term monitoring period would greatly help the administration of project sponsors.