ROCIS_CSR Supporting Statement_2022 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.” 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 FHFA to promulgate
regulations establishing standards of community investment or service that Bank member
institutions must meet in order to maintain access to long-term Bank advances. 1,2 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 statutory and regulatory community support standards. 5
Members are strongly encouraged to complete and submit Form 060 online, but may submit a
12 U.S.C. 1430(g)(1).
For purposes of the community support requirements, a long-term advance is an advance with a term of maturity
greater than one year. 12 CFR 1290.1 (definition of “long-term advance”).
3
See 12 U.S.C. 2901 et seq.
4
12 U.S.C. 1430(g)(2).
5
See 12 CFR 1290.2. Non-depository community development financial institutions and institutions that have been
Bank members for less than one year as of March 31 of the year the Form 060 is due are not required to submit
Form 060.
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version via email or fax if they cannot complete the submission online. In Part I of Form 060, a
member that is subject to the CRA must record its most recent CRA rating and the year of that
rating. Part II of Form 060 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.
Part 1290 also establishes the circumstances under which FHFA will restrict a member’s
access to long-term Bank advances and to the Bank Affordable Housing Programs (AHP),
Community Investment Programs (CIP), and Community Investment Cash Advance (CICA)
programs for failure to meet the community support requirements. 6 Part 1290 permits Bank
members whose access to long-term advances has been restricted to apply directly to FHFA to
remove the restriction. 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 members 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.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
If FHFA did not collect the information at least biennially, its ability to effectively evaluate Bank
members’ community support review, as is required by the Bank Act, would be impacted.
6
7

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

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7. Circumstances Requiring Special Information Collection
No special circumstances require FHFA to conduct the information collection in a manner
inconsistent with the guidelines provided for 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 August 19, 2022. 8
The 60-day comment period closed on October 18, 2022. FHFA received one comment letter
that was not responsive to any of the questions in the notice and contained no comments relating
to the community support requirements or any issues arising under the PRA.
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 1,884 hours. The estimated annualized cost
associated with this burden estimate is $183,124.80, 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 1,875 hours. The estimated annualized cost associated with this burden estimate is
$182,250.
Most Bank members are required to submit a completed Community Support Statement
biennially, with exemptions for 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.
8

See 87 FR 51095 (Aug. 19, 2022).

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There are currently about 6,600 Bank members. 68 of these are non-depository CDFIs. 9
Moreover, there has been a net decrease in System membership over the last three years of 124
members in 2019, 37 members in 2020, and 121 members in 2021. This averages to a loss of 94
members per year. Based upon that average, FHFA estimates a net loss of 282 members over the
coming three years.
After subtracting the exempt members (68) and the estimated loss in members (282) from the
current membership of 6,600, FHFA estimates that 6,250 members will be required to submit the
biennial statement over each of the next several cycles. This corresponds to an annual average of
3,125 respondents.
Senior executive completes and submits Form 060:
•
•
•
•
•
2)

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

0.6 hours
3,125
1,875
$97.20 10
$182,250

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 9 hours. The estimated
annualized cost associated with this burden estimate is $874.80.
FHFA based its estimates for the annual burdens arising from the preparation, review, and
submission of these requests upon an annual average of 12 respondents. Currently 32 members
are on restriction for failure to submit 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:

0.75 hours
12
9
$97.20
$874.80

13. Estimated Total Annualized Cost Burden to Respondents

Federal Housing Finance Agency, Membership Database (November 2022).
See Real Earnings News Release, Bureau of Labor Statistics (Nov. 10, 2022), available at Real Earnings News
Release - 2022 M10 Results (bls.gov) . The Bureau of Labor Statistics found that “[r]eal average hourly earnings
decreased 2.8 percent, seasonally adjusted, from October 2021 to October 2022.” Id.
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FHFA has not identified any costs to respondents other than the costs discussed in detail under
Item 12 above.
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 534 hours. The estimated annualized
cost associated with this burden estimate is $60,876, 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 531 hours. The estimated annualized cost associated with this burden
estimate is $60,534. These estimates are based on the following calculations:
Senior policy analyst responds to questions from Bank staff concerning community
support requirements, and reviews and processes Community Support 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:

0.17 hours
3,125
531
$114
$60,534

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 3 hours. The estimated annualized cost associated with this burden estimate is
$342. 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
12
3
$114
$342

15. Reasons for Change in Burden
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FHFA has decreased its estimate of the total annualized hour burden imposed upon respondents
by this information collection from 1,950 hours in its 2020 submission to 1,884 hours in this
submission. This decrease is due to the projected reduction in System membership over the next
three years.
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 18.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
This information collection does not employ statistical methods.

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