On Aug. 31, 2022, the Federal Housing Finance Agency (FHFA) announced that it would conduct a comprehensive review of the Federal Home Loan Bank (FHLB) system. This article addresses two legal issues relevant to the review:

• FHFA’s statutory authority to reduce the number of Federal Home Loan Banks, and
• The application of the FHLBank statutory “super lien”

FHFA’s authority to reduce the number of federal home loan banks

The Federal Home Loan Bank Act establishes a maximum number of 12 Federal Home Loan Bank districts and an expectation that there should be no fewer than eight districts. There are nuances to a reduction details ⇒

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