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  • Comment Detail

  • Date: 06/12/17
    First Name: Karlos
    Last Name: Griffin
    Email: karlos.griffin@flagstar.com
    Organization Type: N/A
    Organization: Flagstar Bank

  • Comment

    My review of this program is as follows; Only one county in Michigan fits the definition of high needs as of the 2017 data provided (Isabella County), which is outside of our CRA assessment area. There are no specified Indian Tribe areas identified in Michigan. The creation of low income housing stock places a lot of focus on manufactured and mobile housing. I applaud the effort and making housing available for the poorest of the poor. The baseline pricing that would come with these homes lend itself to manufactured housing and mobile homes, so lending products to support this will be critical. I would suggest consideration of “tiny” homes as another means of housing that’s affordable and sustainable. The only question would be the size of the families and their needs.

    After reviewing the plans of both FNMA and FHLMC I feel that their approach is solid. They have focused on developing as many forms of housing as they can including multi-family rentals. It shows that they have done considerably more lending in these spaces, especially when it comes to manufactured housing versus HUD. Our involvement from a lending stand point would be predicated on our available products or wiliness to create products to support this initiative. I am hopeful that our bank will consider expanding our CRA reach to the identified county and assist in creating lending opportunities in conjunction with the Duty to Serve program.