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  • Comment Detail

  • Date: 08/19/24
    First Name: Angela
    Last Name: Steele
    Email: asteele@sherickpm.com
    Organization Type: organization
    Organization: Stone Sherick Consulting Group

  • Comment

    As a consultant to affordable housing developers, I rely on the FHLBank AHP program to finance multifamily rental and homeownership projects for low-income individuals and families. I have worked with the AHP program for many years and have several recommendations for improving the application process.

    1. Allow for separate application rounds for rental and owner-occupied projects. I have seen how FHLBanks struggle to balance points for these two project types, resulting in alternatively favoring one project type over the other. Allowing for separate funding rounds would ensure that sufficient rental and owner-occupied projects are funded each year, as both project types are needed.
    2. Invest in the creation of streamlined and user-friendly application portals that allow all parties to the application to create profiles. There is much variation between FHLBanks in the quality and flexibility of online application portals. FHFA should invest in improving and streamlining all online application systems so they are intuitive and functional. Allowing all parties to an application (i.e. consultant, supportive services provider, provider of donated land) to create profiles, input information, and enter electronic signatures, would streamline the application and review process and reduce errors.
    3. Include investments in LIHTC, NMTC and HPTC for points under Member Financial Participation. These are critical sources of equity for affordable housing developments that often come from FHLB Members, but do not receive consideration for AHP. Including equity sources would streamline the financing process for developers, who could now look for a single funder, and incentivize more participation in the AHP program, and membership in FHLBank, by equity investors seeking to provide more financing opportunities to developers.

    Thank you for your consideration of these comments. The AHP program is critical to successful affordable housing development across the country and I look forward to continued partnership with FHLBanks and their Members.