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Letters to Regulators

Reporting Burden for the FHLB Affordable Housing Program

June 3, 2004

Office of Information and Regulatory Affairs
Office of Management and Budget
Attn: Desk Officer for the Federal Housing Finance Board
Washington, DC 20503

To Whom It May Concern:

The Independent Community Bankers of America (ICBA)1 appreciates the opportunity to comment on the reporting burden for the Federal Home Loan Bank (FHLB) Affordable Housing Program (AHP).

Background

In order to participate in the AHP, FHLB members must spend time providing information to the FHLB for the following activities: AHP applications, AHP modifications requests, monitoring agreements, recapture agreements, Homeownership Assistance Program applications, and verifications of statutory and regulatory compliance at the time of subsidy disbursement. This information helps the FHLB to determine whether an AHP applicant satisfies the statutory and regulatory requirements to receive subsidized advances or direct subsidies under the AHP. The Finance Board estimates that the time burden involved in these activities are:

  1. AHP applications — approximately 25 hours
  2. AHP modification requests — approximately 3 hours
  3. AHP monitoring agreements — 4.5 hours
  4. AHP recapture agreements — 1 hour
  5. Homeownership Assistance Program applications — 2 hours
  6. Verification of compliance submissions — 1 hour
  7. FHLB Advisory Council Report and Recommendations on AHP Implementation Plans — 0 hours

Discussion

Many community banks do not participate in the AHP program. Most cite the cumbersome application process and reporting burden as the major obstacle to participating. Community bankers believe the program is a good one, but see the benefits being outweighed by the burdens connected to participation. Most have a limited staff so committing the resources is difficult.

Community bankers who do use the AHP generally agree that it takes about an hour to provide information for recapture agreements. However, other reporting requirements may take up to 30% longer than the Finance Board estimates. Community bankers who are able to partner with experienced outside groups on AHP projects may spend less reporting time. Bankers believe that the FHLB could provide additional assistance on how to complete the forms.

Thank you for the opportunity to comment. If you need additional information or have any questions, please contact me by phone at 202-659-8111 or by e-mail at katie.bragan@icba.org.

Sincerely,

Katherine Bragan
Associate Director of Lending and Accounting Policy

1 ICBA represents the largest constituency of community banks in the nation and is dedicated exclusively to protecting the interests of the community banking industry. We aggregate the power of our members to provide a voice for community banking interests in Washington, resources to enhance community bank education and marketability, and profitability options to help community banks compete in an ever-changing marketplace.




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