Letter to the Federal Housing Finance Agency on its Advisory Bulletin regarding Federal Home Loan Banks’ Credit Risk Management

ICBA and other groups sent a letter to the FHFA on its recent Advisory Bulletin to the FHLBanks regarding credit risk management expectations for member institutions. ICBA expressed concerns about the lack of clarity in the guidance and the lack of statutory authority to issue this guidance to FHLBanks. ICBA emphasized that community banks rely on FHLBank advances for liquidity, and ICBA and the other groups oppose any regulatory action that undermines community bank access to the system.