ROCIS_CSR Supporting Statement--2020 Renewal

"COMMUNITY SUPPORT REQUIREMENTS"
OMB NUMBER 2590-0005
SUPPORTING STATEMENT

A. JUSTIFICATION
1. Circumstances Necessitating the Collection of Information
The Federal Home Loan Bank System (System) consists of eleven regional Federal Home Loan
Banks (Banks) and the Office of Finance (a joint office of the Banks that issues and services
their debt securities). The Banks are wholesale financial institutions, organized under authority
of the Federal Home Loan Bank Act (Bank Act) to serve the public interest by enhancing the
availability of residential housing finance and community lending credit through their member
institutions and, to a limited extent, through eligible non-member “housing associates.” 1 Each
Bank is structured as a regional cooperative that is owned and controlled by member financial
institutions located within its district, which are also its primary customers.
Section 10(g)(1) of the Bank Act requires the Director of the Federal Housing Finance Agency
(FHFA or the Agency) to promulgate regulations establishing standards of community
investment or service that Bank member institutions must meet in order to maintain access to
long-term advances (i.e., loans made by a Bank to a member). 2 Section 10(g)(2) of the Bank Act
requires that, in establishing these community support requirements for Bank members, FHFA
take into account factors such as the member’s performance under the Community Reinvestment
Act of 1977 (CRA) 3 and record of lending to first-time homebuyers. 4 FHFA’s community
support regulation, which establishes standards and review criteria for determining compliance
with section 10(g) of the Bank Act, is set forth at 12 CFR part 1290.
Part 1290 requires that each Bank member subject to community support review submit to FHFA
biennially a completed Community Support Statement (Form 060), which contains several short
questions the answers to which are used by FHFA to assess the responding member’s
compliance with the community support standards. 5 In part I of the Form, a member that is
1

Certain non-member entities are permitted by statute to engage in limited business activities with a Bank. See 12
U.S.C. § 1430b. FHFA’s regulations refer to these entities as “housing associates.” See 12 CFR part 1264.
2
See 12 U.S.C. 1430(g)(1). By regulation, FHFA has defined “long-term” advances to be those with an original
term to maturity greater than five years. See 12 CFR 1266.1.
3
12 U.S.C. § 2901 et seq.
4
See 12 U.S.C. § 1430(g)(2).
5
See 12 CFR 1290.2(b).

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subject to the CRA must record its most recent CRA rating and the year of that rating. Part II of
the Form addresses a member’s efforts to assist first-time homebuyers. A member may either
record the number and dollar amount of mortgage loans made to first-time homebuyers in the
previous or current calendar year (part II.A), or indicate the types of programs or activities it has
undertaken to assist first-time homebuyers by checking selections from a list (part II.B), or do
both. If a member has received a CRA rating of “Outstanding,” it need not complete part II of
the Form. A copy of the current Form and related instructions appear as an attachment to this
Supporting Statement.
Part 1290 also establishes the circumstances under which FHFA will restrict a member’s access
to long-term Bank advances and to Affordable Housing Program (AHP), Community Investment
Program (CIP) and Community Investment Cash Advance (CICA) programs for failure to meet
the community support requirements. 6 It permits Bank members whose access to long-term
advances has been restricted to apply directly to FHFA to remove the restriction if certain criteria
are met. 7
2. Use of Data
FHFA uses the information collection contained in FHFA Form 060 and part 1290 to determine
whether Bank members satisfy the statutory and regulatory community support requirements and
to ensure that, as required by statute and regulation, only Bank members that meet those
requirements maintain continued access to long-term Bank advances and to AHP, CIP, and
CICA programs.
3. Use of Information Technology
Bank members are strongly encouraged to complete and submit Form 060 online, but may
submit a version via email or fax if they cannot complete the submission online.
4. Efforts to Identify Duplication
This information collection avoids duplication by utilizing CRA ratings as a method of
determining fulfillment of the community support requirements by those members that are
subject to the CRA.
5. Impact on Small Entities
This information collection does not have a significant economic impact on a substantial number
of small entities. The regulation implements statutory requirements and is applicable to all Bank
members regardless of their size.

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7

See 12 CFR 1290.5(b), (e).
See 12 CFR 1290.5(d).

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6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
If FHFA did not collect the information at least biennially, it would be unable to determine
effectively whether Bank members satisfy the community support standards they are required by
statute to meet in order to maintain access to long-term Bank advances and to AHP, CIP, and
CICA programs.
7. Circumstances Requiring Special Information Collection
No special circumstances require FHFA to conduct the information collection in a manner
inconsistent with the guidelines provided in this Item 7.
8. Solicitation of Comments on Information Collection
In accordance with the requirements of 5 CFR 1320.8(d), FHFA published a request for public
comments regarding this information collection in the Federal Register on January 22, 2020. 8
The 60-day comment period closed on March 23, 2020. FHFA received no comments.
9. Provision of Payments to Respondents
No payment or gift will be provided to any respondent.
10. Assurance of Confidentiality
FHFA has not provided, and is not required to provide, any assurance of confidentiality with
respect to the information to be collected.
11. Questions of Sensitive Nature
There are no questions of a sensitive nature in the information collection.
12. Estimated Burden of Information Collection on Respondents
FHFA is seeking OMB clearance for two information collections under this control number: (1)
Community Support Statements (Form 060); and (2) Requests to Remove a Restriction on
Access to Long-Term Advances. The total estimated annualized hour burden imposed upon
respondents by these two information collections is 1,950 hours. The estimated annualized cost
associated with this burden estimate is $195,000, which includes salaries, benefits, and overhead
costs. These estimates are based on the following calculations:
1) Community Support Statements (Form 060)
The estimated annualized hour burden associated with the preparation, review, and submission of
Form 060 is 1,920 hours. The estimated annualized cost associated with this burden estimate is
$192,000.
8

See 85 FR 3680 (Jan. 22, 2020).

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Most Bank members are required to submit a completed Community Support Statement
biennially, with members that are non-depository community development financial institutions
(CDFIs) or that have been members for less than one year as of March 31st of the year
submission is required exempted from the submission requirement. There are currently about
6,700 Bank members. Considering that about 60 of those are non-depository CDFIs and that the
System has experienced a consistent net loss of about 100 to 200 Bank members annually over a
period of years, FHFA estimates that an average of about 6,400 members will be required to
submit the biennial statement over each of the next several cycles, which corresponds to an
annual average of 3,200 respondents. FHFA calculated the burden and cost estimates as follows:
Senior executive completes and submits Form 060:
•
•
•
•
•

Time per Form:
Total Forms:
Total hours:
Hourly rate:
Total cost:

0.6 hours
3,200
1,920
$100 (includes salary, benefits and overhead)
$192,000

2) Request to Remove a Restriction on Access to Long-Term Advances
The estimated annualized hour burden associated with the preparation, review, and submission of
requests to remove a restriction on access to long-term advances is 30 hours. The estimated
annualized cost associated with this burden estimate is $3,000.
FHFA based its estimates for the annual burdens arising from the preparation, review, and
submission of these requests upon an annual average of 50 respondents, based on the fact that
there are currently 100 members on restriction for failure to file a biennial Community Support
Statement.
Senior executive prepares and submits a request to remove a restriction on access to longterm advances:
•
•
•
•
•

Time per request:
Total requests:
Total hours:
Hourly rate:
Total cost:

0.6 hours
50
30
$100(includes salary, benefits and overhead)
$3,000

13. Estimated Total Annualized Cost Burden to Respondents
FHFA has not identified any costs to respondents other than the costs discussed in detail under
Item 12 above.

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14. Estimated Cost to the Federal Government
The estimated annual hour burden to FHFA associated with the two information collections for
which it is seeking clearance under this control number is 163 hours. The estimated annualized
cost associated with this burden estimate is $16,072, which includes salaries, benefits, and
overhead costs. These estimates are based on the following calculations:
1)

Community Support Statements

The estimated annualized hour burden to FHFA in connection with assisting members with the
completion of their Community Support Statements and with the review and processing of the
completed forms is 150 hours. The estimated annualized cost associated with this burden
estimate is $14,700. These estimates are based on the following calculations:
Senior policy analyst responds to questions from Bank staff and Bank members concerning
community support requirements, and reviews and processes Statements for which part II has
been completed (regarding a member’s efforts to assist first-time homebuyers) or for which
incorrect CRA ratings have been entered:
•
•
•
•
•
2)

Time per Form:
Total Forms:
Total hours:
Hourly rate:
Total cost:

0.1 hours
1,500
150
$98 (includes salary, benefits and overhead)
$14,700

Request to Remove a Restriction on Access to Long-Term Advances

The estimated annualized hour burden to FHFA in connection with reviewing and processing
member requests to remove restrictions on access to long-term advances and to AHP, CIP, and
CICA programs is 13 hours. The estimated annualized cost associated with this burden estimate
is $380. These estimates are based on the following calculations:
Senior policy analyst reviews and processes each request to remove a restriction on access to
long-term advances and notifies Bank staff of the result.
•
•
•
•
•

Time per request:
Total requests:
Total hours:
Hourly rate:
Total cost:

0.25 hours
50
13
$98 (includes salary, benefits and overhead)
$1372

15. Reasons for Change in Burden
FHFA has decreased its estimate as to the total annualized hour burden imposed upon
respondents by this information collection from 2,287 hours in its 2017 submission to 1,950
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hours in this submission. This reduced estimate is due primarily to a reduction in the total
estimated number of Bank members going forward, as compared to the 2017 estimate, and a
corresponding reduction in the estimated average number of Community Support Statements
submitted annually from 3,500 to 3,200. A reduction in the burden estimate for the preparation
of individual Community Support Statements from .65 hours in 2017 to the current .60 hours—
due to the increased prevalence of electronic submissions—also accounts for some of the
decrease in the overall burden estimate.
16. Plans for Tabulation, Statistical Analysis and Publication
FHFA will not publish the results of this information collection.
17. If Seeking Approval to Not Display the Expiration Date for OMB Approval of the
Information Collection, Explain the Reasons Why Display Would Be Inappropriate
FHFA plans to display the expiration date for OMB approval.
18. Explain Each Exception to the Topics of the Certification Statement Identified in
“Certification for Paperwork Reduction Act Submission.”
There are no exceptions to the certification statement identified in this Item.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
The information collection does not employ statistical methods.

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