Credit Union Exam Solutions Presents With Flying Colors

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Ryan Donovan, CEO of the Council of Federal Home Loan Banks, joins Mark Treichel to walk through what came out of the first Federal Home Loan Bank oversight hearing in 15 years — and what credit unions should take from it.

The Federal Home Loan Bank System is not a well-known system, as Ryan puts it, so the testimony started with education: 11 banks serving 6,300 members — credit unions, banks, insurance companies, and community development financial institutions (CDFIs) — providing liquidity so those members can serve their own members, customers, and communities.

On credit unions specifically, membership growth continues. A substantial portion of credit union assets is already inside the System; by member count, there is still room to grow among smaller institutions.

Ryan explains the regulatory ask that matters most for liquidity managers: when regulators look at the liquidity coverage ratio and similar measures, Home Loan Bank advances should be treated as core liquidity, reflecting the System’s reliability across its history. Those conversations have begun with the FDIC and will extend to the other member regulators, including the incoming chairman of the National Credit Union Administration (NCUA).

He also draws the distinction credit unions sometimes blur: the Federal Reserve has limited lending authority — overnight lending, with limits on consecutive days and on days borrowed within a set period — while the Home Loan Bank is a daily liquidity provider, with its nexus to housing sitting in the collateral members bring, whether mortgages they originated or bought or mortgage-backed securities they hold.

On interoperability — one of the two hard-to-pronounce words of the hearing, alongside countercyclical — Ryan describes the work that came out of the March 2023 lessons learned: encouraging members to establish and periodically test discount window lines, improving Fed and Home Loan Bank communication so the right people can reach each other at 6:00 on a Friday, negotiating master subordination agreements so collateral can move faster in a crisis, and proposing that the Fed accept a Home Loan Bank letter of credit on behalf of a member in stress to bridge from Friday’s close to Monday’s open. Mark connects this directly to staff turnover, including the roughly 27% of NCUA staff lost to buyouts, and what that does to a call tree.

On housing, the banks are required by law to set aside 10% of the previous year’s net earnings for the Affordable Housing Program (AHP). For the last two years they have contributed 50% more than required, putting more than $1 billion a year toward affordable housing. Ryan is candid about AHP’s burden — 13 FHFA regulations and six advisory bulletins — and notes that FHFA under Director Pulte is overhauling it. He contrasts AHP dollars committed with voluntary program dollars already out the door, and warns against any change to the 10% statutory floor that would crowd out voluntary programs.

The conversation closes on CDFI membership, low income housing tax credit (LIHTC) collateral that is reliable but hard to value, the subsidized programs Chicago, Boston, and Cincinnati run, H.R. 7647 and the community financial institution definition, and why insurance companies belong in the System at all.