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Financial Services Law Insights and Observations

CBO report outlines strengths and risks of the FHLBank system

Federal Issues FHLB Accounting

Federal Issues

Recently, the Congressional Budget Office (CBO) released a report on the Federal Home Loan Banks’ (FHLBanks) role in the financial system, outlining their strengths and risks in the larger financial system. The CBO noted that FHLBanks are insulated from failure because their main activity, granting advances to members, was “overcollateralized and benefits from the banks’ super-lien position.” On accounting this year, the CBO estimated that in FY 2024, FHLBanks will receive $7.3 billion in subsidies, driven by new debts and reductions in debt-service costs. The CBO also estimated that in FY 2024, FHLBanks will issue $800 billion of debt and make advances of $560 billion. The CBO listed three potential risks FHLBanks could pose to the broader financial system: first was a risk to taxpayers in the event the FHLBank system failed and required government support; second was the risk that any FHLBank stress could spill over into other financial areas; and third was the risk of losses to the FDIC Deposit Insurance Fund from FHLBanks’ collateralized lending and their “super-lien positions.” However, the CBO’s report noted that FHLBanks pose less of a risk than Fannie Mae, Freddie Mac, or other commercial banks. Further, there have never been any credit losses on an FHLBank advance. Despite these strengths, CBO noted that FHLBanks could still fail in an economic crisis.