Comments on proposed amendments to the Federal Home Loan Banks’ Affordable Housing Program

Andrew Jakabovics ,
Enterprise Community Partners, Inc.
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Comments on the Federal Housing Finance Agency’s proposed Affordable Housing Program (AHP) rule for the Federal Home Loan Bank.

Enterprise Community Partners has submitted comments on proposed amendments to the Federal Home Loan Banks’ Affordable Housing Program (AHP). This letter recommends:

  • Extending the simplification of the compliance regime to the underwriting process, consistent with AHP’s relatively small share of overall development costs.
  • Adopting the flexibility shown by other funding sources to address fluctuating costs during the development process and comparable discretion at the Bank level to address deficiencies.
  • Retaining the current caps on homeownership set-asides, consistent with substantial need for increasing the supply of affordable rental housing.
  • Providing additional, detailed guidance to Banks on developing their new scoring systems in order to achieve the flexibility intended by the proposed rule.

We believe that the rulemaking process now under way offers an opportunity to make the overall development process and compliance period more efficient and cost effective and look forward to ongoing engagement with FHFA as they finalize the rule.

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