NAFCU writes to FHFA on FHLBs


NAFCU Senior Regulatory Affairs Counsel Aminah Moore wrote to the Federal Housing Finance Agency (FHFA) Friday in response to the agency’s comprehensive review of the Federal Home Loan Bank (FHLB) System as it approaches its centennial. Overall, Moore urged the FHFA to avoid disrupting the FHLB System as a result of this review and recommended any expansion of FHLB membership should exclude non-depository institutions, such as underregulated fintechs, because they are not subject to capital requirements or regulated by a prudential regulator.

NAFCU previously wrote to the FHFA in response to its request for input on FHLB membership. The association wrote that any membership expansion should only include entities that are subject to a regulatory scheme, and that the agency should “prohibit the use of conduits as they inject significant serious risk to the system and cannot demonstrate a nexus to the FHLB’s public policy mission.”

In addition, Moore called on the FHFA to waive the prohibition in its tangible capital rule in the short term and align its tangible capital rule with the capital definition of federal financial regulators in the longer term.

“Many of NAFCU’s member credit unions rely on the FHLBs for liquidity purposes to fully serve their membership’s mortgage and community development needs,” wrote Moore. “As of the end of 2022’s second quarter, the System had 1,574 credit union members, an increase of more than 30 percent over the past 10 years.” She went on to note that credit unions now account for nearly 25 percent of the System’s total membership base.


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