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Financial Services Law Insights and Observations

FHFA Proposes Rule to Replace Federal Home Loan Banks' Use of Credit Ratings

Dodd-Frank FHFA

Lending

On May 23, the FHFA proposed a rule to require the Federal Home Loan Banks (FHLBs) to base determinations about the appropriateness of specific investments or activities on their own internal documented analyses of credit and other risks. Currently the FHLBs use credit ratings provided by certain national credit rating organizations. Dodd-Frank Act section 939A requires the FHFA and other federal regulators to review regulations that require use of such credit rating firms. The FHFA proposal seeks comment on alternative analyses for use by the FHLBs in assessing investments, standby letters of credit, and liabilities. Comments on the proposal are due by July 22, 2013.