JUL.13.2006 1:SlPM CHINQTOWN CDC 415 9 2 9 1 4 9 9 N0.652 P.l
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Federal Housing 1;inance Board
1625 Eye Street, NW
Washington, DC 20006
W; Federal Housing Finance Bosud; Proposed Rdc: Escess Stodi Resmaions and Retained Earnings
Requirements for Federal Home Loan Banks; RIN Number 30G3-AB30; Docker Number 2006-03
We are very concmed about the F e d e d Housing Finance Board's proposed rulc on ~xcess stock and
retained -e requirmcnts. We have used the Affordable Housixag Programs (AHl') of the Federal
Home Loan Bylks O;Wanks) to help make many of our projects affordable to very low income people.
San Prancisco faces a severe housing affordabiliry gap and we would be hard pressed to make such projecrs
as the sa-vice enriched 105 unit Intcmatiod Horel Senior Housing project or the81 unit Broadway Family
Aparrmenrs a reality.
We arc especially concerned that rhc Finance Board does not seem to have devoted sufficienr rime KO
evaluating thc impact of the proposed rule on the AHP and oSer voluntary contributions, which rely on
FHLBank earnings for t e r funding. The proposed rule does nor include any sudz analysis, despire the
likelihood that the rule would cause a reduction in Bank earnings and, therefore, funds available for the AHP.
The overall impact of the proposed rule could be particularly adverse in this period of increasing mortgage
rates and reduced f e d d fundmg for housing. It would be unf~srunate rhe enactment of tlds proposed rule
caused families to be shuc our of thc housing market due to their inability r affad higher mcurgage rates,
I utge you to wirhdraw hproposed rule. In impact could be extremely datlwging to the effarrs of out
organization and similar organiiations nationwide rhac are working to provide affordable housing
oppartunides to families in need, lkanlr you for y o u consideration of these cornrncnts.
Director of Housing Development
1525 Grmt Avenue - San Francisco,California 94133-3323
41 5.984.1450 F.U 415.362.7992 - CRS 800,735,2929