Comment Detail

Comment

This is the input of the Neighborhood Finance Corporation’s Leadership regarding the FHFA six key areas of interest:
1. The FHLBanks’ general mission and purpose in a changing marketplace;

Neighborhood Finance Corporation (NFC) is a CDFI. One key issue for CDFIs is access to affordable capital. It is our desire that any changes to the FHLB system address the growing role of CDFIs and their ability to bring affordable capital to historically disinvested communities.

2. FHLBank organization, operational efficiency, and effectiveness;

As a member of the FHLB of Des Moines, Neighborhood Finance Corporation utilizes the Home$tart down payment program. We appreciate the staff that works on this program and the access to much needed down payment resources. We recommend a down payment resource be part of any changes, and would also appreciate the opportunity to discuss efficiencies and program design enhancements that would make this program even more beneficial to our community. For example, when there are home renovations and the Home$tart funds are not paying for the renovation and the first mortgage loan product does not allow cash back to the borrower (i.e. Fannie Mae’s HomeStyle Renovation), that the Home$tart funds are released prior to completion of the renovations.

3. FHLBanks’ role in promoting affordable, sustainable, equitable, and resilient housing and community investment;
The Affordable Housing Program (AHP) is a valuable resource to bring affordable, sustainable, equitable, and resilient housing to low-income populations and areas. NFC believes there is benefit in this program remaining competitive, and therefore funding those programs that leverage other resources and serve those most in need. NFC also believes that the scoring should be reviewed regularly and that the reporting requirements can be less burdensome.

4. Addressing the unique needs of rural and financially vulnerable communities;

NFC does not have any specific comment other than these are important communities to serve.

5. Member products, services, and collateral requirements; and

As a CDFI, NFC would appreciate a review of the collateral requirements. For many non-depository CDFIs, the primary source of on balance sheet loans that can be used for collateral are second mortgages. Possibly there could be a specific ‘carve out’ of programs to serve CDFIs through products, services and the collateral requirements.

6. Membership eligibility and requirements.

NFC does not have any specific comment other than the suggestion that there is a special consideration for CDFIs.