Page 55 - May-June 2018 GSE Report Flip Book

FEDERAL HOME LOAN BANK
MAJAYN-UAJRUYNE20210818
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The outcomes-based framework around which the proposed rule is built significantly changes the AHP from a program that rewards those projects most aligned with priorities in a scoring framework
The proposed outcome requirements may reduce the pool and diversity of sponsors.
The minimum requirements for special needs and homeless populations are excessive.
The minimum requirement for very-low income households is excessive.
The proposed outcomes-based framework penalizes the FHLBanks if outcome requirements are not met.
Re-ranking of applications reduces the AHP’s transparency.
The American Bankers Association urged FHFA to reconsider its approach to modifying the FHLBs’ Affordable Housing Program. The proposed “complex, highly prescriptive, outcomes- based framework for awarding AHP funds that is less flexible, more complex from a compliance standpoint and less transparent,” according to the ABA. “Revisions to the AHP should focus on making the program more efficient and responsive to locally identified needs, not on imposing strict new national standards and penalties.”
“Mandating the priorities as proposed under the AHP amendment will reduce the number of developments that will score competitively to be awarded an AHP grant,” wrote Chase Bank’s Laurie Perez. “Any amendments to AHP should encourage the maximum creation of affordable housing and not discourage it.”
“The new required outcomes create a national, prescriptive program that prevents individual FHLBs from addressing the particular needs of their local communities and respective districts,” said
Ann Koosachev, National Association of Federally-Insured Credit Unions’ senior regulatory affairs counsel.
“[Certain provisions] seriously undermine FHFA’s efforts to make the AHP program more efficient and could in fact make them more cumbersome and less effective,” said Garth Rieman, National Council of State Housing Agencies’ director of housing advocacy and strategic initiatives.” (Banking Journal, American Bankers Association, 06/11/18; Correspondence, Federal Home Loan Bank System, 06/01/18; Press Release, National Association of Federally-Insured Credit Unions, 06/13/18; Press Release, National Council of State Housing Agencies, 06/14/18)
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