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Comment

I've had the opportunity to work on affordable housing transactions as both development consultant and owner and the following theme has emerged regarding member bank participation:

1) Many member banks do not offer both equity investment and permanent debt, so it creates a rather small pool of member banks that we can select from to maximize those points (especially compared to other regions). Developers are left with a tough decision to make in terms of marrying themselves to a member bank for points, that may not be a great fit for the actual performance of the deal (lower equity pricing, higher rates, etc.). Additionally, many member banks are capped at the number of applications they will support, so the pool tends to shrink in terms of selection options.

I would love to see an amendment to the member bank participation section that factors in this reality and reduces the trade off.

Thank you,