Comment Detail

Comment

Provide adequate staffing for technical assistance and guidance for AHP applicants throughout the entire application process. Many FHLBs provide ongoing and timely feedback and assistance to applicants and have knowledgeable staff readily available to answer project-specific questions up through to the application deadline. However, some FHLBs severely restrict any assistance provided, requiring formal written requests to be submitted within a limited time and months before the application deadline. This results in applications being submitted with avoidable flaws, especially from new sponsors who are not familiar with AHP and could not anticipate the types of questions they should have been asking in advance. It also results in increased staff time needed to perform feasibility underwriting and subsequently in awarded projects that may end up struggling to successfully complete their project under the AHP requirements and guidelines. FHLBs staffing levels should reflect the priority and importance of AHP.

Provide online application systems that are intuitive to navigate and incorporate detailed guidance within the system that is easily accessible. Incorporate as many certifications as possible within the online application interface, reserving additional attachments for critical third-party endorsements only. Harmonize necessary form and attachment formats to ensure a uniform requirement of information, which can mitigate confusion and errors. Embed requests for application details within the online system rather than in separate supplementary forms, which sometimes result in incomplete information being unintendedly submitted due to formatting inconsistencies.

Adhere strictly to the program’s most current approved Implementation Plan and published materials for the funding round. In case of discrepancies, it would be beneficial to default to the original guidelines, addressing modifications in subsequent rounds. If scoring criteria are modified during the application period or just before the deadline, sponsors can find that their project no longer scores sufficiently, and their time and money spent on the application to date could be in vain. Post-deadline alterations, which allow only certain applications to be modified for enhanced scoring, should be avoided to maintain equitable treatment of all applicants.

Provide transparency related to awarded scores and submitted applications for previous rounds. While previous scores may not be reflective of current round scoring potential due to a number of factors, including changes in the scoring rubric, funding availability, and number and type of applications submitted, this information is critical to would-be applicants and sponsors in initially vetting the competitiveness of their projects. The AHP application has historically been incredibly complicated and labor intensive. Understandably so, sponsors want to be able to determine if it is worth their time and resources to undertake an AHP application prior to committing the necessary resources to do so. This is especially true for smaller organizations and communities with limited resources and staffing capacity. FHLB Indianapolis’ detailed annual application reports should serve as a best practice and model for the FHLB system.

Align and harmonize AHP feasibility standards across the entire system. Sponsors are often encouraged by FHLBs to submit applications to multiple FHLB branches to fill financing gaps for their projects. If the scoring aligns well enough with a project to make it competitive through 2 or more FHLBs in a funding round, the project then faces an additional hurdle of navigating the nuances and differences in financial feasibility standards between the different FHLBs. While scoring rubrics that reflect the priorities and needs within each FHLB district is understandable, the sometimes vast differences in financial feasibility standards seem like an unnecessary complication.

Provide scoring and subsidy limits within AHP that levels the competitiveness between rental and homeownership applications. Many FHLBs have adopted scoring rubrics and subsidy limitations that provide a significant advantage to rental projects as opposed to homeownership projects. In fact, there are FHLBs that often do not award any AHP funds in a round to projects developing housing for owner-occupants. Given the now longstanding trend nationwide of the severe underproduction of for-sale units that continues to price low-income families out of homeownership, FHLB investment seems to be significantly lagging in addressing this critical need. AHP set-aside programs like down payment assistance funds are becoming increasingly inadequate in an environment of rising prices, low inventory, and high interest rates. Simply put, AHP should be encouraging the production of new affordable for-sale housing rather than heavily favoring rental development only.