Our Position

The Federal Home Loan Bank System


  • The Federal Home Loan Banks (FHLBs) must remain a strong, stable, reliable source of funding for community banks.
  • ICBA opposes any legislation or administrative action that would permit any new types of non-depository entities, which are not prudentially regulated, to access any FHLBank program or service, either directly or indirectly.
  • ICBA strongly opposes any ongoing mortgage asset test for member institutions to access the FHLB system.
  • The regional structure and cooperative nature of the FHLB system must be maintained, and any structural changes to the FHLB system must originate and be supported by the member owners of the system.
  • Advances should remain the FHLBanks’ primary focus and members should not be required to track or segregate advances for “mission related purposes”.
  • FHFA should align the capital requirements for member bank FHLB advances with the prudential regulators to avoid disruption and possible liquidity problems for otherwise well capitalized community banks.


The vast majority of community banks are FHLB members. They are active advance users or rely on the availability of advances as an alternative source of liquidity. ICBA will work to ensure that as the administration and Congress consider changes to the housing finance system, the FHLBs remain a healthy, stable, reliable source of funding, liquidity and other products to serve the needs of all member-owners.

Staff Contacts

Tim Roy

VP, Housing Finance Policy



Ron Haynie

SVP, Mortgage Finance Policy