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Staff Analysis
FHLB System at 100 Report
November 08, 2023
On November 7, 2023, the Federal Housing Finance Agency released the FHLBank System at 100 Report: Focusing on the Future report that is the culmination of the agency’s more than yearlong comprehensive review of the Federal Home Loan Bank System.
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Comment Letter
Letter to CFPB on Residential Property Assessed Clean Energy Financing
July 26, 2023
While the goals of these programs are laudatory, the financing arrangements employed by many PACE programs, as they are currently authorized by state and local governments, present significant consumer protection concerns for borrowers as well as safety and soundness concerns for both primary and secondary mortgage market participants.
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Letter to Congress & Regulators
Letter to FHFA on FHLB at 100 Request for Comments
October 27, 2022
Comments on the Federal Housing Finance Agency's comprehensive review of the Federal Home Loan Banks.
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Comment Letter
Proposal to Change Affordable Housing Goals for Fannie Mae, Freddie Mac
October 17, 2022
In a rapidly changing economic environment where rising interest rates and an acute shortage of affordable housing threatens to become chronic, a benchmark that is more reflective of changing conditions is both welcome and warranted.
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Staff Analysis
FDIC Draft Principles on Climate-related Financial Risk Management
May 18, 2022
ABA comment letter writing guide on the FDIC's draft principles on climate-related financial risk management.
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Comment Letter
Letter to FHFA on re-proposal of eligibility requirements for Fannie Mae and Freddie Mac non-depository single-family seller/servicers
April 25, 2022
ABA supports this effort to strengthen the safety and soundness of the housing finance system and in particular, to address concerns related to the capital and liquidity requirements for non-depository seller/servicers.
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Position Paper
Climate Change and Banking
February 09, 2022
In light of efforts by investors and by policy-makers at Federal, state, and local levels to respond to climate change, ABA and its members understand that climate-related financial risk - and broader environmental policy goals - have implications for banks, their counterparties and the communities that banks serve.
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Staff Analysis
FHFA GSE Affordable Housing Goals
September 21, 2021
On August 25th, the Federal Housing Finance Agency (FHFA) published a proposal and request for comments on the housing goals for Fannie Mae and Freddie Mac (the Enterprises) for 2022 through 2024. The Federal Housing Enterprises Financial Safety and Soundness Act of 1992 (the Safety and Soundness Act) requires FHFA to establish annual housing goals for mortgages purchased by the Enterprises.
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Comment Letter
Letter to FHFA on Climate and Natural Disaster Risk Request for Input
April 19, 2021
Like many organizations and industries, the American Bankers Association has increased our focus on climate related risks. ABA recently joined the U.S. Climate Finance Working Group, a coalition of financial trade associations, in developing a set of principles to guide discussions and engagement on how the financial system and our regulators should address climate change issues.
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Comment Letter
Letter to FHFA on Enterprise Housing Goals
February 26, 2021
We note at the outset that the ANPR poses questions that suggest a potential reduction in the housing goals credit awarded to the GSEs - and perhaps the eligibility for purchase of some categories of loans altogether, based upon a number of rationales. ABA continues to believe that the overall footprint of the market served by the GSEs should be reduced in an orderly, well considered fashion to avoid market disruptions.
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Backgrounder
Flood Insurance Issue Update
February 22, 2021
The National Flood Insurance Program (NFIP) has been reauthorized through September 30, 2021. As of February 2021, the prospects for long term NFIP reauthorization are unclear. The House Financial Services Committee, led by Rep. Maxine Waters, unanimously passed a reform and five year reauthorization in mid 2019, but the Senate did not take up the reform legislation.
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Backgrounder
Environmental, Social and Governance (ESG) Issue Update
February 22, 2021
Environmental, Social and Governance (ESG - also often referred to as 'sustainability') issues are an increasing area of focus for banks of all sizes, driven by attention from regulators, investors, customers and employees.
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Comment Letter
Letter to FHFA on Prior Approval of New GSE Products, Activities
January 07, 2021
ABA welcomes the FHFA's effort to bring greater transparency and objectivity to the approval process for new products offered by the GSEs. Ensuring that the GSEs' activities remain focused on the secondary market and do not stray into competition with primary market participants is a key responsibility of the FHFA.
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Comment Letter
Comments to Treasury on CDFI Certification
November 05, 2020
ABA supports the Treasury/CDFI's efforts to revise and update the CDFI certification to ensure that it is meaningful and that participants adhere to the mission and goals of the CDFI program. We urge the Treasury to evaluate bank and credit union applicants for CDFI certification on the same terms, and not rely upon National Credit Union Administration designations.
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Comment Letter
ABA Comment to FHFA on the re-proposed capital rules for Fannie Mae and Freddie Mac
August 31, 2020
ABA provides a critique of the FHFA's re-proposed capital rules for Fannie Mae and Freddie Mac through a lens of how the proposal would impact loan originator's ability to sell loans to the GSEs in a reformed, post conservatorship environment.
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Staff Analysis
FHFA’s Re-proposal of Enterprise Capital Risk Proposal
June 30, 2020
On June 30, 2020, the Federal Housing Finance Agency (FHFA) published in the Federal Register a proposed rulemaking (NPRM) soliciting public comments on a re-proposal of rules establishing a new regulatory capital structure for the government sponsored enterprises (GSEs) Fannie Mae and Freddie Mac.
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Comment Letter
ABA Letter to FHFA on FHLB Membership
June 23, 2020
ABA reiterates positions taken in a 2015 comment letter that membership eligibility for the FHLBs is set by Congress and that FHFA's proper role is to ensure the safe, sound and mission compliant use of the System by eligible members.
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Comment Letter
ABA Letter to FHFA on the Property Assessed Clean Energy (PACE) Program
March 16, 2020
ABA letter to FHFA on the RFI re: Property Assessed Clean Energy (PACE) Program
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Comment Letter
Letter to OCC on the Proposal on New Round of EGRPRA-Recommended Rule Changes
March 09, 2020
ABA Comment to OCC on the proposal on new round of EGRPRA-recommended rule changes.
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Staff Analysis
Disparate Impact Proposed Rule
September 30, 2019
ABA's summary and guidance on HUD's proposed update to its disparate impact rule.