The 11 Federal Home Loan Banks (FHLBanks) submitted a letter to the Federal Housing Finance Agency’s (FHFA) request for input related to FHLBank membership.

In their letter to Deputy Director Andre D. Galeano, the banks noted that “any expansion of membership should be done with the safety and soundness of the System as the paramount principle.”

In 2008, Congress explicitly recognized the FHLBanks’ mission of providing liquidity to members without limiting that purpose to housing finance, highlighting a dual mission of providing liquidity to members and supporting affordable housing and community development. The FHLBanks’ ability to fulfill that statutory mandate to provide liquidity to members was demonstrated in the 2008-2009 financial crisis and again in the current coronavirus crisis.

As part of the response to the RFI, the Federal Home Loan Banks proposed principles that should be considered when addressing any changes in membership eligibility.