Law for Sustainability
Opening screen of FHFA Listening Session, October 3, 2022. 164 views as of October 13.
The eleven Federal Home Loan Banks - established by Congress in 1932 – “have total assets that exceed $1 trillion. They were conceived to support housing finance, but they no longer play that role.” So wrote Cornelius Hurley of the Boston University School of Law[1] in “Imagining Taxpayer Response to FHFA Reform” in American Banker , October 7, 2022. Why should environmental citizens care? The home is our immediate environment, our housing has huge environmental impacts that can be greatly reduced, and the system is not equitable.
Hurley pointed out:
“The Home Loan banks issue debt obligations in the hundreds of billions of dollars. They are the second largest issuer of debt after the U.S. Treasury Department. Their debt is subsidized by all taxpayers….
…because of the government guaranty, the Home Loan Banks offer below-market rates. Second, the Home Loan banks incur zero credit risk in lending to the banks because, even in the rare event of a bank failure, the Home Loan bank has a priority over the FDIC (and the taxpayer) in that bank’s receivership. The upshot is that it is cheaper for the banks to borrow from their Home Loan banks than from their own depositors.”
I wonder if there are people on the inside who might agree with him, because the FHFA has launched a national public conversation about how the system should be reformed. Not being attuned to financial policy I have come to this late, but there is still one more week to comment. [2]
The announcement of FHFA’s “Comprehensive Review” states it “supports affordable, equitable, and sustainable access to mortgage credit”, for home and community investment. But if depositors and taxpayers are subsidizing this pool of credit for all other banking operations, what happens to the original purpose of addressing housing issues? What happens to aspirations for a housing system that influences the evolution of healthy homes and sustainable community development?
Hurley pointed out:
“The Home Loan banks issue debt obligations in the hundreds of billions of dollars. They are the second largest issuer of debt after the U.S. Treasury Department. Their debt is subsidized by all taxpayers….
…because of the government guaranty, the Home Loan Banks offer below-market rates. Second, the Home Loan banks incur zero credit risk in lending to the banks because, even in the rare event of a bank failure, the Home Loan bank has a priority over the FDIC (and the taxpayer) in that bank’s receivership. The upshot is that it is cheaper for the banks to borrow from their Home Loan banks than from their own depositors.”
I wonder if there are people on the inside who might agree with him, because the FHFA has launched a national public conversation about how the system should be reformed. Not being attuned to financial policy I have come to this late, but there is still one more week to comment. [2]
The announcement of FHFA’s “Comprehensive Review” states it “supports affordable, equitable, and sustainable access to mortgage credit”, for home and community investment. But if depositors and taxpayers are subsidizing this pool of credit for all other banking operations, what happens to the original purpose of addressing housing issues? What happens to aspirations for a housing system that influences the evolution of healthy homes and sustainable community development?