FHFA and FHLBank Coordination with Regulators Improved After the Spring 2023 Bank Failures, but Several FHLBanks Faced Challenges Obtaining Timely Supervisory Information

View Report

Date Issued

Thursday, September 18, 2025

Submitting OIG

Federal Housing Finance Agency OIG

Agencies Reviewed/Investigated

Federal Housing Finance Agency

Report Number

EVL-2025-005

Report Type

Inspection / Evaluation

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 6 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
EVL-2025-005-1	No	$0	$0
FHFA's DBR should assess the extent to which FHLBanks are relying on redacted ROEs when reviewing membership applications or performing ongoing monitoring.
EVL-2025-005-2	No	$0	$0
FHFA's DBR should clarify and reinforce DBR’s expectation to the FHLBanks that they should request and receive from federal and state regulators ROEs that are not substantively redacted, and that other relevant supervisory reports should be collected when necessary.
EVL-2025-005-3	No	$0	$0
FHFA's DBR should conduct outreach to federal financial regulators to reinforce the need for compliance with 12 U.S.C. § 1442(a)(1), which requires their production of reports, records, and information relating to the condition of any member of any FHLBank upon request by an FHLBank. As part of this outreach, make clear that such materials extend beyond ROEs, and that materials produced in response to an FHLBank requests should be provided without substantive redactions.
EVL-2025-005-4	No	$0	$0
FHFA's DBR should assess the extent to which restrictions on access to state-issued ROEs may hinder the FHLBanks in making fully informed decisions when evaluating applications for membership and when making determinations to limit or deny member requests for advances in accordance with applicable FHFA regulations.
EVL-2025-005-5	No	$0	$0
FHFA's DBR should, if applicable, continue to pursue outreach with the Conference of State Bank Supervisors and state regulators to assist FHLBanks in accessing state-issued ROEs.
EVL-2025-005-6	No	$0	$0
FHFA's DBR should complete its assessment of the extent of weaknesses in the FHLBanks’ enforcement of members’ material adverse change notification requirements, and provide guidance to FHLBanks on best practices, such as issuing periodic reminders of notification requirements, to help ensure members’ compliance with the FHLBanks’ contractual requirements.