Unclear drafting in the September plan by the Administration to restructure the housing GSEs suggested that FHLB membership might be expanded no matter the tough tone throughout the rest of the plan cutting the GSEs down to a far smaller size. With FHFA’s new RFI on FHLB membership, it’s clear that any latitude for MREITs and other FHLB wannabes was not to be. The RFI is very clear: nontraditional members will need to make a very strong showing of housing-finance commitment to join a Home Loan Bank and even current insured-depository members may need to reconfigure advance use.
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