Community Support Statements

Approximately every two years, each Federal Home Loan Bank of Chicago (FHLB Chicago) member must complete a Community Support Statement (CSS) for the Federal Housing Finance Board (Finance Board). Each quarter, the Finance Board informs the FHLB Chicago which members have been selected to complete the CSS. This list is also published in the Federal Register. As required by the Community Support Regulations, the FHLB Chicago provides written notice to each of its members selected for CSS review. Included in the notification is a CSS form with instructions (.doc) and the date that the completed form is due back to the Finance Board. The deadline for submission of a CSS to the Finance Board is generally 45 calendar days after the date of publication of the notice in the Federal Register. Non-profits and other housing advocates in the FHLB Chicago's district are also notified by the FHLB Chicago, in case they wish to comment on a member's record.


Federal Home Loan Bank Members Selected for Community Support Review this Quarter (.pdf)

The Finance Board will provide written notice to the member and the FHLB Chicago of its determination regarding the CSS. If the Finance Board determines that further information is necessary to process the CSS they will request it directly from the member.

If a member does not submit a CSS or fails to meet the CSS requirements of the Finance Board (listed below), the Finance Board requires that the FHLB Chicago restrict the member's access to FHLB Chicago's services and products. Once access is restricted, the member cannot borrow advances for longer than one year or access any of the Community Investment programs, including the Affordable Housing Program (AHP), Downpayment Plus® Program (DPP®) or Community Investment Cash Advance (CICA) advances or letters of credit. The restriction can be lifted by submission of a CSS that meets the Finance Board requirements.



Finance Board Requirements

To stay eligible for all FHLB Chicago services, the Finance Board will take into account the following:

• If a member is subject to Community Reinvestment Act (CRA) requirements then it needs to earn a CRA evaluation of outstanding or satisfactory from its regulator. A member with a CRA rating of "Needs to Improve" shall be subject to a probationary period until its regulator completes its next CRA evaluation and issues a rating. A member that receives a CRA rating of "substantial non-compliance" or that failed to improve on the next evaluation after being on probation, will be restricted in advance usage and access to Community Investment programs.

• Members must meet a first-time homebuyer standard. The standard may be satisfied by the following:

• If the member's most recent CRA rating is "Outstanding" and there are no public comments or other evidence to the contrary, the homebuyer standard is met and all of Part II of the CSS form can be omitted.

• If the member can demonstrate in Part II that it has established a record of lending to first-time homebuyers, the standard is met.

• If the member has a program to lend or support lending to first-time homebuyers, the standard is met. Program examples include special flexible underwriting standards, participation in a government lending program targeting first-time homebuyers, participating in a loan consortia for first-time homebuyers or loans that serve predominately low or moderate income borrowers.

• If the member has a program to assist other organizations that help first-time homebuyers receive a mortgage, the standard is met. Program assistance examples include homeownership counseling services, outreach or technical assistance for first-time homebuyers, investing in mortgage backed securities that include a pool of loans to low and moderate income borrowers, etc.

Almost every institution can qualify under one of these four methods.

If the Finance Board deems that a member has not satisfied the first-time homebuyer performance standard, the member will be placed on probation for one year. If the problem is not corrected, the Finance Board will restrict the member's access to long-term advances, the Affordable Housing Program (AHP), Downpayment Plus® Program (DPP®) and Community Investment Cash Advance (CICA) advances and letters of credit. Members will also be placed on restricted status if they fail to submit a completed Community Support Statement.



How to Complete the Form

Follow the instructions below to complete the CSS form. Community Investment staff is available to provide technical assistance.

1. All selected members must fill out the name/address/contact information at the top and complete the signature block, Part III.

2. Indicate your CRA rating in Part I. If you are not subject to CRA requirements, simply put "not applicable" in this section.

3. If your CRA rating is "Outstanding" you may skip Part II. All others should complete Part II, Section A or B, or possibly both.

  • Part II-A asks for mortgage data for first-time buyers. If you collect this data, please fill in section A. If you don't collect this data leave section A blank and go to section B.

  • Part II - B gives a list of typical programs to help first-time homebuyers and asks you to check off those you provide. No quantitative data is needed. Please contact Community Investment staff for assistance if you do not recognize an activity that applies to you.

4. Some members may feel that Part II does not adequately reflect their assistance to first-time homebuyers. If so, they may choose to write a short description of what they offer, or factors that limit their offerings. The description should be no more than one page and should be attached to the CSS form.

If you have any questions, please contact Community Investment staff. The completed statement should be mailed to the Finance Board at the address listed below or e-mailed to fitzgeralde@fhfb.gov by the deadline given to you in the notification letter.

Federal Housing Finance Board

Office of Supervision
Community Investment & Affordable Housing
1625 Eye Street, N.W.
Washington, D.C. 20006


HOME | SITE MAP | CAREERS | COPYRIGHT | LEGAL | ANTI-PREDATORY LENDING POLICY | PRIVACY POLICY | CONTACT US