The AHTCC has submitted comments recommending that the Federal Housing Finance Agency (FHFA) and the Federal Home Loan Banks (FHLBanks) take affirmative steps to encourage all member institutions – including and especially insurance companies – to invest in, lend to, and/or provide other ancillary support to multifamily affordable housing, particularly through Housing Credit investments. The submission was in response to a recent Request for Input (RFI) regarding the regulations governing the core mission activities and mission achievement of the FHLBanks. The comments focus on incentivizing greater support in the FHLBanks System for affordable housing financing – particularly as insurance companies make up a sizeable portion of its membership, and rising insurance costs continue to pose a formidable challenge for affordable housing production and preservation.
FHFA is undertaking a comprehensive review of its regulations to better align the FHLBanks with their core mission of supporting housing and community development. While the nation faces a growing volume of unmet housing and community development needs, the composition of the FHLBank System’s membership has shifted away from institutions with a strong focus on mortgage lending, and the scope of eligible collateral has expanded to include non-housing-focused assets.
In November 2023, the FHFA released the FHLBank System at 100: Focusing on the Future (System at 100) Report, which encapsulates a year-long review of the FHLBank System and offers several recommended actions. A key finding from this review highlights the necessity for the FHLBanks to bolster their support for housing and community development. Clarifying the mission of the FHLBanks is crucial to enhancing this support and executing the recommendations outlined in the Report.
The current RFI seeks public input on potential updates to the mission statement, methods for measuring and evaluating mission achievement, and financial incentives for members demonstrating a robust connection to the mission of the FHLBank System. The AHTCC’s comments underscore the importance of revising the FHLBanks’ mission to better address challenges to affordable housing finance across the nation, such as rising development and operating costs. 
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