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CBAI Urges Improvements to the FHLB’s Affordable-Housing Program

In a June 12, 2018 letter to the Federal Housing Finance Agency (FHFA), the Community Bankers Association of Illinois (CBAI) provided its observations and recommendations regarding proposed amendments (Proposal) to the Affordable Housing Program (AHP). CBAI emphasized that the importance of AHP should not be understated. For more than 25 years, the FHLB-Chicago’s AHP has provided nearly $300 million to help more than 57,000 low and moderate-income individuals and families to obtain, develop or preserve safe, decent and affordable housing.

Unfortunately, the FHFA’s Proposal recommends a top-down approach that promotes a number of national housing priorities that may not align with the housing priorities and needs within the various FHLB districts. In addition, the Proposal makes the AHP more complex, less flexible and less transparent.

CBAI urged the FHLB to withdraw the proposal and resubmit after consultation with stakeholders or allow each FHLB to retain its current AHP structure and requirements. If the FHFA decides to move forward with this Proposal, any final rule should provide maximum ease and flexibility to best meet the housing needs of FHLB districts and not threaten the relevancy of the AHP and lessen the value of FHLB membership. Read Comment Letter.