Comprehensive Review of the Federal Home Loan Bank System

October 26, 2022

As financial leaders directly serving diverse communities, the African American Alliance of Community Development Financial Institutions (CDFI) CEOs (the Alliance) is a membership- driven intermediary organization of 67 Black-led CDFIs, which aims to build the capacity of member organizations, expand access to capital for member organizations, and build power in Black communities by challenging and influencing financial sectors to operate more equitably. Our members reach historically underserved communities in all 50 states by providing financial services in the small business, affordable housing, and commercial real estate development sectors. Currently, 10 Alliance members are Federal Home Loan Bank (FHLB) members, and this letter highlights the challenges and operational issues hose members face as they navigate the FHLB System. Additionally, we provide recommendations for increasing program access and usefulness for our members and other non-depository CDFIs across the country.