HPN applauds the FHFA for undertaking a comprehensive look at the regulations governing the AHP. The affordable housing development process has evolved a great deal in the 29 years since the AHP was created and it is timely and useful for the FHFA to assess how the regulations can be streamlined and updated. AHP subsidies are seldom the only funding that goes into a project, so it is appropriate and helpful for the FHFA to look at how AHP income targeting and monitoring requirements intersect with those of other funding sources. We appreciate the rigorous and thoughtful approach that FHFA takes to rule writing.
Before we address specific questions posed in the rule, we encourage FHFA to consider the totality of new requirements imposed by the revised regulations and whether they will improve the affordable housing delivery system. FHFA should be thinking about how AHP grants can fill gaps in the current system.