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CUNA Releases Detailed Analysis of FHFA’s FHLBank Report

The Credit Union National Association (CUNA) has released a detailed analysis of the Federal Housing Finance Agency’s (FHFA) report on the Federal Home Loan Bank (FHLBank) system to get credit unions thinking about how they use the FHLBank system and potential impacts of the FHFA’s report.

This comes after the California and Nevada Credit Union Leagues released its own analysis (Leagues’ Bulletin: FHLB Analysis on Home Loan Bank System). The Leagues’ regulatory compliance bulletin on the FHFA’s report can be found here. Credit union leaders are encouraged to read it, as it summarizes key takeaways of the FHFA’s report and its legislative and regulatory recommendations.

CUNA’s Analysis
CUNA’s summary pairs FHFA’s objectives identified in the report with FHFA’s corresponding recommendation.

“It should be noted that the recommendations in the report will require future action and that the report, by itself, does not implement any changes in the FHLBank System,” the summary notes. “With the release of the Fall 2023 regulatory agenda, we will get a better sense of how quickly FHFA intends to move on some of the recommendations in the report.”

According to the FHFA, the report looks at the future of FHLBanks through four lenses:

  • Mission of the FHLBanks.
  • FHLBanks serving as a stable and reliable source of liquidity.
  • FHLBanks supporting housing and community development.
  • Efficient operation and governance of the FHLBanks.

The objectives and recommendations in CUNA’s analysis are sorted by these principles.

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