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  • Comment Detail

  • Date: 07/15/24
    First Name: Francis
    Last Name: Vargas
    Email: FVargas@altmanco.com
    Organization Type: organization
    Organization: Elon Affordable Housing LLC

  • Comment

    The AHP program has been a tremendous support and needed resource for thousands of affordable housing units. Through their respective Implementation Plans, FHLB's have made several key areas a priority for funding through it's scoring system. However as the process is highly competitive, it becomes difficult to structure a project while competing for points. I would recommend that FHLB consider targeting it's priorities through set asides, similar to the LIHTC program. That way you don't have projects just "checking the box" to get points and that those applicants who specialize on addressing the priorities outlined by the FHLBs can submit competitive applications.

    Secondly I would consider two additional areas of focus in the Implementation Program:

    1. MBE/WBE participation - Consider awarding points to MBE/WBE participation (third party or self certification) in the development team.
    2. Environmental Standards/Green building - Consider awarding point for green building practices to encourage more environmentally sound development.

    Thank you!