Comment Letters
Comment letters written by the Coalition and the organizational members about FHLB reform.
January 31, 2025
Coalition Urges Stronger Oversight and Governance Reforms for FHLBs to Align with Public Mission
The coalition calls for expanding the expertise of public interest board directors, to include fair housing, tribal housing, and community development. They also urge FHFA to rebalance board composition by increasing the number of public interest independent directors and moving toward a 50/50 split between independent and member directors to better align the FHLB system with its public mission. A major focus of the letter is excessive executive compensation, with the coalition urging FHFA to impose limits on the pay of FHLB presidents, who earned an average of $2.9 million in 2023—far exceeding comparable public-sector and GSE roles.
October 31, 2024
Over 60 National and Local Organizations Sign On to Letter Urging Congressional Action to Expand FHLBanks' AHP Contributions
This letter calls on Congress to enact legislation that would require that FHLBs devote at least 30 percent of their net income every year to support housing and community development, including no less than 20 percent on AHP contributions.
August 19, 2024
CFR Submits Letter on AHP Application Process to FHFA
This letter, based on a survey of 25 housing organizations, highlights several challenges including the complexity of the application process, the competitiveness of funding, and burdensome reporting requirements.
July 15, 2024
CFR Submits Response to FHFA RFI on FHLB Mission
The Coalition for FHLBank Reform, with the support of 50 additional local and national advocacy groups, submitted a letter in response to the the Federal Housing Finance Agency’s Request for Information on the FHLBank mission and the metrics for mission achievement.
July 15, 2024
Comments on the Federal Home Loan Bank mission
Kathryn Judge (CFR Advisory Board Member) and Aaron Klein published a comment letter with The Brookings Institute in response to the FHFA's RFI on mission.
July 15, 2024
NCRC Comment on FHLB Mission
National Community Reinvestment Coalition (CFR organizational member) submitted a letter in response to the FHFA's RFI on FHLB mission.
July 15, 2024
CFA, UFCW, and Others Submit Letter to FHFA Regarding Insurance Companies and FHLBanks
Organizational members of the Coalition and other housing advocacy groups submitted a letter to the FHFA in response to the RFI on mission. This letter focuses on the membership of insurance companies in the FHLB System and proposes an membership-incentive model to encourage more mission related activity from the insurance members.
July 15, 2024
UFCW Comment on FHLB Mission
United Food and Commercial Workers International Union (CFR organizational member) submitted a letter in response to the FHFA's RFI on FHLB mission. This letter focuses on how insurance companies are profiting from their membership in the FHLB System while workers struggle with the effects of the affordable housing crisis.