Skip to main content

  • Comment Detail

  • Date: 06/12/18
    First Name: Ian
    Last Name: McCormack
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    5. LIHTC non-compliance that would have a noticable effect on affordable housing provision would have to be systematic and repeated, and would be rare. Accordingly, requiring Banks to maintain a significant reporting/monitoring function would cost more than its worth. Conversely, most LIHTC non-compliance is temporary and fixed through the standard LIHTC compliance agencies, reducing the need for additional oversight by FHLBanks.