| 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
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