CUNA Regulatory Comment Call


March 8, 2005

Proposed Rule on Reporting Requirements for the Federal Home Loan Banks
(Not a Major Rule)

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Associate General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you would like a copy of the proposal, or you may access it here.

BACKGROUND

The Federal Home Loan Bank System consists of twelve FHLBs operating under the supervision of the Finance Board. The FHLBs are government-sponsored entities (GSEs) that are federally chartered but privately owned entities created by Congress to support the financing of housing and community lending by their members. The members are primarily financial institutions, such as credit unions. Because of their GSE status, the FHLBs are able to borrow in the capital markets at favorable rates, which are then passed on to their members and then to consumers in the form of secured loans, advances, and other financial services at rates that members generally cannot obtain elsewhere. The Federal Home Loan Bank Act provides the Finance Board with the authority to require examinations and reports of condition from the FHLBs in the form that the Finance Board prescribes.

DESCRIPTION OF THE PROPOSAL

The Finance Board proposes to issue many of its existing reporting requirements in the newly created DRM, including certain reporting requirements that are currently located in the Finance Board rules. The DRM will include instructions addressing data definitions, as well as requirements concerning data elements, reporting format, reporting method (such as paper or electronic), record retention, timeliness, reporting frequency, and certification. The DRM will be an enforceable order issued pursuant to the Finance Board’s investigatory powers, and future changes to these requirements will be made by amending the DRM. The reporting requirements concerning capital stock for voting purposes, director elections, and capital requirements will not be affected by this proposal.

In addition to creating the DRM, the proposal will also amend the Finance Board rules regarding the FHLBs’ reporting obligations to require each FHLB to:

QUESTIONS TO CONSIDER REGARDING THE FINANCE BOARD’S PROPOSAL

Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com