Comment Detail

Comment

• For donated land - Tribal Projects - a land lease should qualify for points, especially when it is an LIHTC project as the GP is not related since they only own .01% of the project?
• Tribes should be considered separately from the States they are in as this would enable them to compete in any district and still be considered a part of that district, this is especially true if they border a district and bank in that district?
• With LIHTC projects, the AHP funds sometimes are not awarded until after a project has closed with its investor. Many times, the investor received a promise from the Tribe, that if the AHP funds are now awarded, that the Tribe will provide the entire amount of the loan. If the AHP is awarded, the funds are used to pay down the Tribe’s contribution (construction loan). We need to make sure that the Tribe is not penalized for closing on the financing ahead of the award. Some FHLB districts are more familiar with this structure than other districts.
• It is oftentimes difficult for banks to loan to projects on tribal trust land; therefore, it puts the Tribes at a disadvantage if there are points for bank contributions/loans. How can we ensure that Tribes are still competitive in these districts?
• With Fannie and Freddy’s duty to serve, Tribes are specifically listed as underserved communities. Is there any way for the FHLB to also recognize and encourage awards in the underserved communities (which are underserved because of their economics, location, and inability to access capital)?