Comment Detail

Comment

• Limit AHP’s need for subsidy review to looking at the development budget to confirm a project’s gap, instead of also looking at the project’s cash flow.
• Social services should be an allowable operating expense, in alignment with other project funders and best practices in the affordable housing industry.
• AHP should not be put in the position of determining how much permanent debt a project can or should take on.
• Reduce documentation requirements for scoring categories and benchmarks.
• Other providers of gap funding only require submission of one application. However, AHP requires not only an application to receive an award of funds, but also when requesting disbursement of funds, and again once the project is completed. This is overly burdensome and not in alignment with other funding programs.
• Standard affordable projects are frequently over benchmark on Operating Budget and Construction Cost benchmarks. It would be more efficient if FHLB would revisit what are reasonable benchmarks rather than requiring most projects to justify why they are over the benchmarks.
• Recognize that AHP is typically a small part of a project’s financing and should be able to be more flexible and deferential to larger funder requirements and benchmarks. For example, projects have had to submit a number of quarterly reports to AHP despite not yet having started construction.
• Revise scoring criteria so that non-PSH projects have the ability to competitively compete for funds.