The Council of Federal Home Loan Banks has submitted comments to the Federal Housing Finance Agency (FHFA) on its draft Strategic Plan: Fiscal Years 2026-2030, expressing support for the agency’s efforts under Director Bill Pulte’s leadership to modernize oversight and reduce unnecessary regulatory burdens on the Federal Home Loan Banks (FHLBanks).
The Council’s letter commends FHFA’s recent steps to rescind outdated guidance and advisory bulletins that were not subject to public notice and comment and proposes incorporating the goal of reducing unnecessary regulatory burdens across the FHLBank System’s supervisory framework. The Council also urges FHFA to ensure that rules and supervisory guidance allow the FHLBanks to fully meet their foundational liquidity mission, which supports housing finance, community development, and affordable housing.
The Council’s comments highlight how certain regulations and advisory bulletins have limited the 11 FHLBanks’ ability to provide liquidity to their members and encourages FHFA to continue refining these frameworks to align with safety and soundness objectives while empowering the System to do more to address housing challenges nationwide. The letter also requests revisions to the regulatory structure governing the FHLBanks’ Affordable Housing Program (AHP), and refers to an August 2024 comment letter containing specific recommendations for addressing greater utilization of AHP funding to address critical housing needs.
“Director Pulte has proposed a strategic plan that charts a bold path to sustain the FHLBank System’s long-term stability and impact,” said Ryan Donovan, president and CEO of the Council of Federal Home Loan Banks. “We will be a constructive partner to ensure the FHLBanks keep delivering reliable liquidity in a safe and sound manner to help keep mortgage credit affordable.”
The Council also reaffirmed the FHLBanks’ commitment to collaborate with FHFA to strengthen the Affordable Housing Program and leverage both statutory and voluntary initiatives to expand housing supply and affordability in all 11 FHLBank districts.
“To more effectively leverage the Affordable Housing Program (AHP) in addressing critical housing shortages in the FHLBanks’ respective districts, the FHLBanks request revising the AHP regulatory framework and stand ready to collaborate with the FHFA’s Division of Housing and Mission Goals on this important initiative,”: said Donovan in the letter. “We encourage the FHFA to revisit the recommendations submitted in the FHLBanks’ August 14, 2024, comment letter responding to the FHFA’s Request for Input on the FHLB AHP Competitive Application Process as well as the FHLBanks’ June 1, 2018, comment letter to the Proposed Rulemaking for the AHP Amendment (RIN 2590-AA83).”
