Re: Federal Home Loan Bank Mission RFI (https://www.fhfa.gov/sites/default/files/2024-05/FHLBank-Mission-RFI-2024.pdf)
Dear Director Thompson,
The American Bankers Association and the undersigned state bankers’ associations are pleased to offer comments on the Request for Input published by the Federal Housing Finance Agency (FHFA) regarding the Federal Home Loan Banks' Core Mission Activities and Mission Achievement.
We continue to welcome the thoughtful and inclusive process that FHFA has followed since announcing the Comprehensive Review of the Federal Home Loan Banks. The multiple opportunities for stakeholders to engage should promote understanding among interested parties about the strengths of the FHLB System and encourage feedback on potential areas for improvement and innovation. In particular, we believe that this request for input (RFI), as well as the recently published RFI regarding the Affordable Housing Program (AHP) will help to guide FHFA to the right approaches toward rulemaking and other policy changes.
As noted by FHFA, the RFI is an outgrowth of the Comprehensive Review of the Federal Home Loan Banks conducted in 2023. The RFI reviews the statutory background and regulatory provisions in FHFA’s Core Mission Activities (CMA) regulation related to the mission of the FHLBanks, and it requests input on updates to the mission statement, methods for measuring and evaluating mission achievement, and financial incentives for members with a strong and demonstrable connection to the mission of the FHLBank System.
While we do not take issue with FHFA’s authority to review and update regulations (either those promulgated by the FHFA or a predecessor agency), we caution that any regulatory agency, including FHFA, must remain within boundaries set by statute. A troubling aspect of the FHFA’s comprehensive review of the FHLBs was the premise, asserted frequently, that it was the first comprehensive review of the FHLBs since the founding of the System in 1932. That assertion ignores the fact that there have been numerous legislative and regulatory changes to the System over its 92 years of operation.
Download the joint comment letter to read the full text.
