Recap of MA Senate Budget Action and Anticipated MACDC Next Steps for Budget Conference Agreement

May 29th, 2019 by David Bryant

Over three days last week, the Massachusetts Senate debated its FY2020 budget, and while they approved several important priorities for housing and community development, they set aside or rejected many of MACDC’s key budget priorities. 

As a reminder for you, in April the House voted to increase funding for the Small Business Technical Assistance (SBTA) program to $3 million, and we asked the Senate to increase funding to $4 million to meet the existing demand for program resources. (The Senate Ways and Means proposed level funding of $2 million, as did Governor Baker.)  Senator Diana DiZoglio offered an amendment to increase SBTA program funding to $4 million, which was defeated by voice vote.  We will work to secure the higher level funding of $3 million when the Conference Committee (composed of six legislators – three from each chamber who meet to reconcile budget funding and policy differences) begins its deliberations in June. 
The House added $750,000 to Mass Development’s Transformative Development Initiative (TDI) line item for a neighborhood stabilization initiative for a total of $1 million.  Specifically, the House “provided, that $750,000 shall be expended on a neighborhood stabilization initiative to assist local governments and their non-profit partners to implement strategic neighborhood revitalization initiatives; and provided further, that the Initiative shall be developed in consultation with the Massachusetts Association of Community Development Corporations, and the Massachusetts Institute for a New Commonwealth, Inc. and shall focus on identifying and implementing strategies for reclaiming vacant, abandoned and blighted properties and restoring them to productive use as homeownership opportunities or rental housing, as well as on capacity-building at the local level to address this need.” 
Senate Ways and Means had proposed level funding ($250,000) and Senator Brendan Crighton offered an amendment to restore the $750,000 and the language above to conform to the House passed provision. The Senate rejected the Crighton amendment and we will seek the House approved language when the Conference convenes in June. 

The House provided level funding ($2.05 million) for the Chapter 206 funding from the MA Division of Banks (line item 7006-0011) to enable homeownership education and foreclosure prevention counseling, consistent with MACDC’s request, what Governor Baker proposed, and what Senate Ways and Means has proposed.  It was pleasant surprise – and an added bonus – when Sen. Jamie Eldridge offered, and the full Senate adopted, an amendment to increase this line item by $800,000, and we will work to retain this higher level funding in the Conference report. 
he House adopted a proposal to raise the deeds recording fees from $20 to $50 to improve the state’s match to communities from the CPA Trust Fund and the Senate adopted (by unanimous record vote) an amendment by Sen. Cynthia Creem to mirror the House proposal.  MACDC has long supported Sen. Creem’s legislative efforts to increase these deeds recording fees, and we were pleased that the Senate adopted this amendment, as well as an amendment by Sen. Bruce Tarr to authorize up to $20 million of FY19 budget surplus to be transferred to the CPA Trust Fund to alleviate an expected 2019 CPA Trust Fund shortfall. 

Finally, we were very pleased that Senators Cyr and DiZoglio agreed to offer an amendment to provide $5 million to recapitalize the Get the Lead Out Loan Program.  Early in the week, Sen. Cyr decided he would withdraw this amendment from the budget debate, based upon discussions with leadership and staff, and an understanding that he could obtain this funding through other legislation.  This will remain a critical priority for MACDC this session, as current projections from MassHousing suggest, without recapitalization, as of June 30, 2020, the fund balance essentially would be zero. 
The disparate actions taken by the House and Senate will be reconciled over the next 3-4 weeks in a Conference Committee.  Your calls and emails remain vital, if we are to achieve our highest budget priorities and other goals outlined in early January. 

 So, stay tuned to further Action Alerts; there is more work for us to do! 

Thank you for your support and your advocacy.

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Urge Your Senators to Co-sponsor and Support Sen. DiZoglio’s SBTA Budget Amendment (#19)!

May 14th, 2019 by David Bryant

MACDC is grateful to the Baker administration and the Legislature for funding the Small Business Technical Assistance (SBTA) Program at $2 million in FY 2019 (line item 7002- 0040), and we are pleased that the Massachusetts House of Representatives voted to increase SBTA funding to $3 million in its budget approved in April – a proposed 50% Program increase for FY 2020.

We are not done yet, and we’ll need your help next week, as the Senate begins debate on its FY20 budget on May 21st.

Last fall, the Baker administration and the Massachusetts Growth Capital Corporation (MGCC), announced $2 million in grants to 40 organizations. The grants range from $10,000 to $120,000 and will allow CDCs and other community-based organizations to provide customized management and operational assistance, financial training, and lending services to small businesses; these resources are targeted to serving low- to moderate-income communities.

There has been growing demand for these technical assistance and program resources; last year MGCC received requests for almost $4 million, and the demand for the program has almost tripled since it was launched in 2007.
Since then, MACDC has been seeking to increase SBTA Program funding to $4 million, in as much as the January 2018 Massachusetts Gaming Commission report, "Reinvesting the Gaming Economic Development Fund," recommended strategies to fund priorities, one of which was deemed to be support for small business technical assistance and lending.

We need your help to increase funding for the SBTA Program in FY 2020. The Senate Committee on Ways and Means has recommended level funding ($2 million) for SBTA.  However, Sen. Diana DiZoglio will be offering an amendment (#19) to increase funding to $4 million.  Please, take a moment to call your state senator and ask them to co-sponsor and support the DiZoglio amendment (#19) to increase funding SBTA at $4 million.

In a $42.7 billion state budget, $4 million represents less than 1/1000th, and it is not an unreasonable amount to request to ensure that small businesses continue to grow and thrive in every community.


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State Awards $1.5 Million for Sustainable Homeownership Counseling and Foreclosure Prevention

April 30th, 2019 by Don Bianchi

On April 22, the Massachusetts Division of Banks awarded $1.5 Million in grants for Foreclosure Counseling and First-Time Homebuyer Education through the 2019 Chapter 206 Awards.  A total of 20 awards were made to 10 foreclosure prevention regional centers and 10 consumer counseling organizations which provide homebuyer education.

CDCs continue to be among the leaders in providing these essential services, with twelve of the twenty awards made to MACDC Members or coalitions which include MACDC Members.  CDCs serving urban, rural, and suburban areas across the Commonwealth are helping homebuyers acquire their first homes and assisting homeowners at risk of foreclosure in keeping their homes.

The counseling awards were created through Chapter 206 of the Acts of 2007 – a law that MACDC helped enact through our advocacy with CHAPA and MAHA.  They are funded by fees associated with the licensing of mortgage loan originators.  In 2018, the Regional Foreclosure Centers assisted almost 4,800 clients, helping 84% of these clients to avoid foreclosure.  Homebuyer education was provided to almost 2,700 clients.  This counseling helped prospective homebuyers make an educated decision on when to purchase a home.  Furthermore, it helped homebuyers secure affordable and sustainable mortgage loans- only .02% of these clients purchased a home with a subprime mortgage!

MACDC appreciates the Baker-Polito Administration’s ongoing support for this program and is grateful to the Division of Banks for its effective stewardship of this important resource.

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CDCs Invest over $800 Million in 2018 in Providing Homes, Jobs, and Other Services

April 30th, 2019 by Don Bianchi

The results are in!  MACDC just released its 2019 GOALs Report which documents the collective impact of CDCs across the Commonwealth.  For the second consecutive year, CDC investment in their communities topped $800 Million.  Through this investment, CDCs improved the communities they serve by:

  • Creating or preserving 1,535 Homes
  • Creating or preserving 4,305 Jobs
  • Providing technical assistance to 1,369 Entrepreneurs
  • Providing 84,224 Families with Housing, Jobs, or Other Services
  • Engaging 1,910 Leaders.

The Report highlights some of these impacts, including:

  • Mill Cities Community Investments helping to convene a $1 Million Emergency Fund for businesses impacted by the fires caused by a natural gas explosion in the region;
  • WATCH organizing a major grassroots campaign to increase the City of Waltham’s inclusionary housing requirements from 10% to 15%;
  • Worcester Common Ground partnering with YouthBuild to create two units of family housing built entirely by youth; and
  • NewVue Communities graduating its first cohort of Community Stewards, trained in Community Organizing.

Through these initiatives, and others, CDCS across Massachusetts act on the values that guide our work: lifting up community voice and power, building inclusive communities, and advancing economic opportunity.  As we celebrate the results from 2018, we already can’t wait to see what CDCs achieve in 2019!

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MACDC Lobby Day Draws Largest Crowd in Years

April 30th, 2019 by

On April 25, more than 200 community developers representing 43 CDCs from across the Commonwealth came together for MACDC’s Annual Lobby Day at the State House.  CDC leaders met with dozens of legislators to push for our shared agenda, including increased funding for Small Business Technical Assistance, legislation to strengthen the Community Preservation Trust Fund, and a Four-Step Agenda for addressing our housing crisis.  At noon, these leaders were joined by dozens of friends, allies and legislators in the Great Hall to hear from Senator Brendan Crighton who thanked the leaders for their advocacy and their local leadership.  CDC leaders also heard from Edison Ribeiro of Erise Builder’s Inc., a small business owner from Jamaica Plain who talked about his journey from Madison Park Vocational School High School, to working for a company whose CEO mentored him, to starting his own construction company, to getting help from JPNDC and now hiring and mentoring young people who work for him.  His inspiring story and leadership reminded us that everyone needs help, and everyone can pay it forward.

In the afternoon, the MACDC Board of Directors meet with Governor Baker for over an hour.  This was the fifth year in a row that we have had the opportunity to meet with the Governor on Lobby Day. Each of these conversations has been substantive and productive, but this year’s meeting might have been the most important.  We dedicated over half the time to talking about the book Color of Law, which we had given to the Governor at our Convention last October.  At the time, the Governor said he would read the book and discuss it with us at our next meeting. True to his word, we did just that, having a fascinating and at times emotional, conversation about racism, segregation, and what each of us can do to redress the harm caused by decades of racist federal, state, and local housing policies.

“This was one of our largest and most impactful Lobby Days in years,” said MACDC President Joseph Kriesberg.  “We thank everyone who came – especially the dozens of people who were attending their first MACDC Lobby Day.”

To see pictures from the event, go to our Facebook Page.

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Remarks by a small business owner

April 30th, 2019 by Edison Ribeiro

I’ve been working in the construction business for over 15 years. Starting as an apprentice while I was attending the Madison Park High School to journeyman under a different company, to owning my own business.

Two years ago, I needed some assistance and confidence to make my dream of owning my own business come to life. My mentor, Arnold Johnson of Crosswinds Enterprises, invited me to explore JPNDC, a community-based nonprofit that holds programs for small businesses looking to succeed in the community.

At JPNDC, I met Carlos Espinoza, the director of Small Business Services who has become my go to guy throughout this journey. Carlos started off by assisting me with writing my business plan, the layout of how I saw my business into existence today, and has helped me break barriers that challenged me to becoming a business owner.

From there Carlos has assisted me into programs targeted towards managing, bookkeeping, accounting, resources to capital and credit repair. All of these hold great importance into managing a successful business. Through the Small Business Technical Assistance Program, provided through JPNDC, it allows entrepreneurs as myself to network with successful business owners and vendors within the community. The program provides you with a mentor who has direct experience in the field and business world. Arnold Johnson has continued to mentor me along with several others within the program.

This joint effort has made it possible for me to hire six residents from the community into my business, which in return has allowed me to take on additional jobs and responsibilities. It has also given me the opportunity to give back by taking on a student from South Eastern Vocational High School through the co-op program.

Through the mentorship, business support programs, and networking, the program has also allowed me to make relationships and in return, turn those relationships into new jobs. And I believe others within the program could say the same.

I am confident that with the continued support of the program and my mentor I will continue to succeed and grow as a small business owner in Boston. I believe additional support to JPNDC, from the community, city and state will also help double or even triple these opportunities for myself, along with several other small business owners within the community and the city. 

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Supporting professionals of color in the community development field should be a top priority

April 19th, 2019 by Beyazmin Jimenez

MACDC President Joe Kriesberg and MassHousing’s Executive Director Chrystal Kornegay joined in a dialogue with students from the Institute for Nonprofit Practice to kick off a conversation on ways to increase the hiring, engagement, and retention of professionals of color in the community development and planning field. The conversation was prompted through a new partnership between the Institute for Nonprofit Practice and Santander Bank in which Santander underwrote 6 fully funded fellowships for community development professionals of color to attend the Institute for Nonprofit Practice’s Core Certificate program. The intensive year-long program equips leaders in the nonprofit sector with skills, knowledge, and networks they need to make strategic, mission-driven decisions.

The six Santander Fellows- Angie Liou, Executive Director of Asian CDC, Beyazmin Jimenez, Resident and Civic Engagement Manager at Madison Park Development Corp., Carlos Espinoza, Small Business Program Director at Jamaica Plain NDC, Katherine Martinez, Executive Director at Lena Park CDC, Dava Mallebranche, Program Representative at Metro Housing Boston, and Jason Boyd, Director of Community Organizing at Codman Square CDC- have embarked on a year-long program with the Institute and have dedicated time to exploring ways to better serve other professionals of color in the community development field.

Early on, the challenges identified by the cohort related to the need for more intentional hiring practices. Born out of the civil rights era, at a time when our federal government had begun to dramatically reduce its support of local jurisdictions, community development organizations emerged as a response to better serve the needs of residents around housing and civic engagement efforts. More than forty years later, the field of community development has expanded and grown into a large industry producing billions in revenue nationwide. With affordable housing development at its core, community development organizations have reached a crossroads here in Massachusetts where housing prices continue to skyrocket.

While many CDC’s continue to offer an array of services from small business support to homeownership counseling, real estate development remains the key source of revenue for most. Fellows identified that a key path to promotion and growth within CDC’s skewed towards real estate and project management roles, yet many of these opportunities are highly competitive and remain in the hands of mostly White candidates. In order to meet the needs and demands of our real estate development work, CDC’s need to engage in hiring practices that promote skill development opportunities for those looking to enter the field. Offering opportunities to local candidates with roots in their community, graduates from community colleges, and hiring residents with organizing backgrounds is much less common than before.

As the CDC field has grown, so has the hiring requirements for entering the field. It is not uncommon to see a job for a role at a CDC that requires a Master’s or Bachelor’s level of education mimicking the competitive skills level of the Greater Boston area and most of the state. Indeed, local universities have responded to the skills demand - Umass Boston just announced a new graduate program for Urban Planning and Community Development. Fellows feared that the shift for high-level skills would threaten CDC’s authenticity and proximity to the communities they serve. Many also questioned whether the demand for extended education relied more on risk aversion from CDC and Board leaders under pressure to hire the “right candidate”. All agreed on an emphasis on hiring practices that better reflected the commitment to diversity and inclusion.

An opportunity that may be open for exploration is developing partnerships with area universities and colleges to recruit graduates into the field of community development. CDC’s are encouraged to identify ways to tap into the vast amount of resources available at local colleges and find ways to engage candidates interested in beginning a career in community development. At the same time, there is value in finding space and resources for candidates with less traditional educational experiences who support the mission of our work and who hold ground in the communities where our work takes place. An emphasis on the "right candidate" may garner the same age-old results and limit the potential of those who are ready to take on the job but are seen as “less competitive” due to their different life experiences. Understanding racial and gender bias and how it manifests in our hiring practices is a necessary key component for board leaders and hiring managers in all our organizations.

The Fellows also expressed a need for intentional mentors and sponsors that would help identify professional opportunities and could make key introductions to enhance their leadership capacity. The need to support the advancement of professionals of color relies on establishing a known network of peers who can share experiences of workplace matters. Navigating the politics of an organization can be crucial to gaining access and having the necessary support from peers, managers, and other leaders can help professionals of color feel included and valued. The work does not end by simply hiring a person of color - intentional outreach, mentorship, and access to opportunity are key to ensuring professionals of color are viewed as a valuable resource to the organization. Executives, managers, and board members need to listen, share, and expand their privilege and social capital to better promote the ideas of people of color within their organizations. Recognizing the power dynamics that exist due to White privilege and class, we can recognize the need for more intentional focus on developing the professional pursuits of minority candidates. Finding time and dedicating organizational resources to ensuring the advancement of professionals of color should be a top priority for all CDC’s.

During our meeting with MACDC’s President and MassHousing’s Executive Director, the leaders expressed their own reflections on the future of the field. Joe Kriesberg shared his ability to navigate his career fresh out of law school and pondered on not seeing the value of keeping his network of colleagues as a source of support; he shared his admiration for the Fellows’ outlook in investing in their personal brand and developing their skills set to meet the demands of their work. A gem shared from Chrystal Kornegay relied on asking for what you want and need and not shying away from executive opportunities due to a perceived lack of experience. Indeed, Fellow Katherine Martinez shared her own career trajectory beginning as an executive assistant at her organization and rising to an executive director position. Kornegay expressed the imperative of understanding the business side of running a nonprofit; she urged the Fellows and their peers to seek professional development opportunities that cultivated these skills like financial courses and diving into the real estate business lines of the organization. Finally, the Fellows chatted about the needs of social settings that allowed for ideas to flow and establish camaraderie. Fellows envisioned growing their networks beyond the professional into a hub of creatives and rising leaders who could work together on larger issues across Greater Boston and beyond.

Our CDC’s are at a critical turning point as more long-standing leaders begin to transition out of leadership roles leaving a space and opportunity to rethink how we want our organizations to thrive into the future. Investing in professionals of color and promoting equity is a sure way to focus our attention on the changing landscape before us and will prepare our organizations for the challenges we still face.

For professionals of color in our field, we offer the following:

  • Get involved on the Board level - Boards of Directors have hiring power and determine key directions for nonprofit organizations. The skills gained as a board member can translate into job opportunities and the expansion of your professional network.
  • You are a leader now - Identify your personal skills and begin working on your personal brand. You do not need to wait to become an executive director to recognize your leadership potential. We all carry unique identities and lived experiences that are beneficial to the growth of our organizations.
  • Find your tribe - Establish a network of peers that can help support your professional growth and with whom you can share ideas. Your network does not need to only consist of high-level executives. Often, your peers can offer a blanket of support and encouragement to help you navigate your career.
  • Invest in your professional development - Training opportunities through the Mel King Institute course offerings and the Institute for Nonprofit Practice management programs can be beneficial in expanding your skill set and networks, and prepare you for the next level in your career.

Special Thank you to: Pat Kirby, Audrey Gillis, and Nate Bae Kupel at Institute for Nonprofit Practice, Joe Kriesberg and Shirronda Almeida at MACDC, Chrystal Kornegay at MassHousing, Santander Bank and all the Santander Fellows at Institute for Nonprofit Practice

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Housing report documents shortage of affordable housing – but with a silver lining

March 20th, 2019 by Joe Kriesberg

Last week, the National Low-Income Housing Coalition released, The GAP – A Shortage of Affordable Homes, its annual report documenting the shortage of housing available for low-income Americans.  The report provides many depressingly familiar statistics:

  • 7 million extremely low-income (ELI) American households (households with incomes below 30% of the Area Median Income) lack access to housing that is affordable to them, including nearly 170,000 households in Massachusetts;
  • In Massachusetts, for every 100 ELI households there are just 46 affordable homes;
  • 72 percent of households with incomes below 50% of the Area Median Income are severely cost-burdened, meaning they pay over 50% of their income to rent;
  • People of color are much more likely to be cost burdened then their white counterparts.

Clearly, we have work to do.

At the same time, if you dig a little deeper into the report, there is another lesson to be learned: smart housing policies work and pay long-term dividends. 

According to the report, Massachusetts has one of the smallest affordability gaps in the country with 46 affordable homes per 100 ELI households, compared to a national average of 37.  Massachusetts ranks 14th of the 50 states.  The Boston MSA ranks third in the nation with the lowest affordability gap, just below Providence (whose MSA includes parts of Massachusetts) and Pittsburgh.  In Boston, we have 46 affordable homes for every 100 ELI households – a dire shortage. But in L.A., they have just 18!  Dallas has 20 and Phoenix has just 21.

How is it possible that one of the most expensive regions in the country is also the third best in the country in terms of providing actual affordable homes to ELI people?  Unlike many housing studies that show Massachusetts to be one of the worst states in the country when it comes to housing affordability, this study considers government subsidized apartments and other homes with rent or price restrictions.  In fact, this report recognizes the successful efforts of affordable housing advocates, organizers, policy makers, and developers, over many decades here in Massachusetts, to produce subsidized housing.  Policies like Chapter 40B (which encourages all cities and towns to provide their fair share of affordable housing), programs like state-supported public housing, and the Massachusetts Rental Voucher Program are making a real difference.   In the City of Boston, 20% of the housing stock has long term affordability restrictions and fully one-third of Boston’s rental housing has restricted rents. One-third!

Our success relative to other states and regions should not be an excuse for complacency. It should be viewed as a reason to do more, because investing in affordable housing really does make a difference,

I was reflecting on these lessons recently when I attended CEDAC’s 40th Anniversary Celebration where Mel King was honored for his legacy in launching the community development field, and again, a few days later, at a wonderful memorial service held to celebrate the life and legacy of Amy Anthony, Governor Dukakis’ Secretary of Housing and Community Development and the founder of Preservation of Affordable Housing.  As I listened to speakers reflect on their incredible legacies, I found myself thinking about the thousands of people whose lives are healthier and happier because of what they and so many others have done over the decades.  The NLIHC report affirms that their legacy lives on in the homes they – and we – helped to create. 

As an advocate, I know that we often rely on dire statistics to generate the political will needed to spur policy change. I also know that we must confront the pessimism and cynicism that says governmental action won’t help and could make things worse.  I hope the NLIHC Report can do both – give us the encouragement and confidence to overcome this negativity, while renewing our sense of urgency that we need to adopt an ambitious housing agenda to help the millions of Americans who remain housing insecure.

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CDCs Can Access Resources to Foster Healthy Communities That are Age-and Dementia-Friendly

February 5th, 2019 by James Fuccione

Exciting new data and resources are available to support the work of Community Development Corporations to foster vibrant, healthy and thriving cities and towns across the state as well as help make connections to the growing Age- and Dementia Friendly movement.

The updated Massachusetts Healthy Aging Data Report includes “Community Profiles” reporting healthy aging indicators for all 351 cities and towns in the state (along with neighborhoods of Boston, Worcester and Springfield). The report also includes interactive maps with chronic disease indicators and customizable state maps on 12 data themes including “economic and housing variables,” “wellness and prevention,” and “safety and transportation.” These resources can be valuable in advancing conversations about what communities can do to become better places to grow up and grow old.

Massachusetts is proving itself a leader in the age- and dementia-friendly movement. So far nearly 40 Massachusetts cities and towns have earned the Age-Friendly designation from AARP or the World Health Organization—and Massachusetts is one of only three Age-Friendly States. My previous blog post outlined the natural connection between Age- and Dementia Friendly Communities and the work of CDCs. The Massachusetts Healthy Aging Collaborative is eager to be an ally in this work.

The second resource is an Economic Development Workbook developed by AARP as the sixth and final installment of a “Roadmap to Livability” workbook series. The booklet explains the economic benefit of being designated age-friendly. It also dives into smart growth and public health principles, along with examples from across the country of how being age-friendly improves the local economy and livability.

Finally, in their latest Best Practice Series, the Massachusetts Municipal Association includes recommendations and resources to help guide a community to update its bylaws relative to Accessory Dwelling Units (ADUs). Accessory dwelling units are a second dwelling unit on a single-family residential lot and can be a significant piece of a municipality’s solution to help older adults Age in Community.

If you have questions or want more information, contact me:

James Fuccione, MPA
Senior Director
Mass. Healthy Aging Collaborative


We look forward to engaging more CDCs to help people of all ages thrive in Massachusetts.

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Final Rule Amends Affordable Housing Program, Incorporates MACDC’s Concerns

January 8th, 2019 by Don Bianchi

The Federal Housing Finance Agency (FHFA) published a Final Rule amending its regulations for the Federal Home Loan Banks’ (FHLBanks) Affordable Housing Program (AHP), which incorporated many of the comments submitted by MACDC and other affordable housing advocates in response to a Proposed Rule amending the regulations. 


In March 2018, FHFA published proposed amendments to AHP.  As described by the FHFA, the proposed amendments would give the Federal Home Loan Banks more flexibility in allocating their AHP funds, in establishing special competitive funds that target affordable housing needs in their districts, and in designing their own project selection scoring criteria.  It would also make other significant changes to the AHP Program. 


After reviewing the proposed rule, and consulting with members and allies, MACDC submitted its comments to FHFA. MACDC commented on a number of provisions, focusing on issues related to transparency, proposed targeting, and long-term affordability.  We were, therefore, pleased when FHFA issued the Final Rule, which addressed the concerns expressed by MACDC. 


FHFA held a webinar on the key components of the Final Rule in December.  The slides from the webinar provide a summary of the changes incorporated in the Final Rule. (FHFA Slides on Final AHP Rule)  The Final Rule, published in November, makes changes to the AHP; the most significant changes are described below. 


AHP Funding Categories: 

It moves from two categories (a Competitive Application Program and a Homeownership Set Aside Program) to three categories (A General Fund, Targeted Funds, and a Homeownership Set Aside).  The Final Rule incorporates some statutory and regulatory priorities for the General Fund, including Underserved Communities and Populations, Creating Economic Opportunity, and Community Stability including Affordable Housing Preservation.  Up to 40% of a FHLBank’s annual AHP funds can be allocated to up to three Targeted Funds, at the discretion of the FHLBank. 


Changes to Homeownership Set Aside Program: 

While the maximum set aside remains at the greater of 35% of the FHLBank’s annual total AHP contribution or $4.5 million, the maximum grant award is increased from $15,000 to $22,000 per household, subject to automatic annual adjustments.  In another change, one third of the Homeownership Set Aside Program funding allocation must be directed to first-time homebuyers, or households for owner-occupied rehabilitation (rehab), or combination of both. 


Changes to Monitoring Requirements for LIHTC Projects and Projects with Government Funds: 

The Final Rule removes the requirement for the FHLBanks to review back-up household income and rent documentation at initial monitoring for AHP projects which also receive Low Income Housing Tax Credits.  The Rule also removes the requirement for the FHLBanks to reviewback-up household income and rent documentation during initial and long-term monitoring for AHP projects that also receive funds from certain government housing programs. 


Homeownership Retention Agreements: 

The Final Rule eliminates retention agreements for homeowners receiving AHP subsidy solely for rehab.  For homeowners receiving AHP subsidy for purchase, and for purchase in conjunction with rehab, the Rule establishes a de minimis exception to subsidy repayment where the amount subject to repayment is $2,500 or less. 


Implementation Dates: 

For owner-occupied retention agreement requirements, the compliance date is January 1, 2020.  For all other provisions, the compliance date is January 1, 2021.  A FHLBank may choose to implement any set of related provision in the Final Rule at an earlier date. 


Of significant importance, several other changes proposed by FHFA were not included in the Final Rule, in response to comments submitted by MACDC and others.  The most significant of these problematic changes proposed would have required the FHLBanks to re-rank project scoring to meet FHFA Outcome Requirements, which could have resulted in a FHLBank replacing a higher scoring application with a lower-scoring application, disrupting AHP’s predictability and transparency.  Another proposed change would have imposed two well-intentioned, but problematic targeting requirements, which may not be achievable in some markets.  A third proposed change would have been a blanket removal of the five-year retention agreements from all assistance to owner occupants, including assistance for purchase, leaving open the possibility for speculative gain.  MACDC is grateful for FHFA’s responsiveness to these concerns in its Final Rule, and to our allies for joining MACDC in sharing concerns about the Proposed Rule. 


MACDC is aware of the critical nature of AHP funds to the feasibility of many affordable housing projects in Massachusetts.  We believe the Final Rule will result in changes that allow the FHLBanks to better tailor the AHP to the needs of the communities they serve, while preserving the scoring transparency that has long been an essential feature of the program. 

Commenting Closed


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