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| Community Support Statements |
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Approximately every two years, each Chicago Federal Home
Loan Bank (Chicago FHLB) member must complete a Community Support
Statement (CSS) for the Federal Housing Finance Board (Finance
Board). Each quarter, the Finance Board informs the Chicago
FHLB 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 Chicago FHLB provides written notice
to each of its members selected for CSS review. Included in
the notification is a CSS
form with instructions 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 Chicago FHLB's
district are also notified by the Chicago FHLB, in case they
wish to comment on a member's record.
The Finance Board will provide written notice to the member and
the Chicago FHLB 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 Chicago FHLB restrict a member's access to
Chicago FHLB'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 AHP,
the DPP™ Program or CICA advances or letters of credit. The restriction can
be lifted by submission of a CSS that meets the Finance Board
requirements.
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| Finance Board Requirements |
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To stay eligible for all Chicago FHLB 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 Boards deems a member's first-time homebuyers performance
unsatisfactory 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, AHP, the DPP Program and Community Investment advances and letters
of credit. Members will also be placed on restricted status if
they fail to submit a completed Community Support Statement.
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| How to Complete the Form |
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Follow the instructions below to complete the CSS form. Community Investment
staff is available to provide technical assistance.
- All selected members must fill out the name/address/contact
information at the top and complete the signature block, Part III.
- Put your CRA rating in Part I. If you are not subject to CRA
requirements, simply put "not applicable" in this section. 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.
- 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.
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Federal Housing Finance Board |
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Office of Supervision |
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Community Investment & Affordable Housing |
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1625 Eye Street, N.W. |
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Washington, D.C. 20006 |
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