NCSHA Comments on FHFA Affordable Housing Program Amendments
On June 12, 2018, NCSHA submitted comments to the Federal Housing Finance Agency (FHFA) on its proposed rule amending the Federal Home Loan Banks’ (FHLBs) Affordable Housing Program (AHP). The comments express support for FHFA’s goal to modernize the AHP regulations to allow the FHLBs more flexibility and discretion in how they allocate their funding, while stating concerns about certain provisions of the proposed rule that could work against that purpose. In particular, NCSHA argues that FHFA should rescind its proposal to enact an outcomes-based framework on AHP that would require 55 percent of AHP funds to meet certain prescribed housing activities, which would reduce the FHLBs’ flexibility and hinder their efforts to meet the unique housing needs of their markets. The comment also asks FHFA to explore how AHP can better work with federal and state affordable housing programs through reduced monitoring requirements.