There are three “government-sponsored enterprises,” commonly called GSEs, that play a big role in US housing finance: the Federal Home Loan Banks, Fannie Mae, and Freddie Mac.

Perhaps the key similarity across all three is that when they borrow money, the financial markets perceive that the federal government is standing behind the loan–and so they can borrow at a lower interest rate. However, the ways in which the GSEs are organized and interact with housing markets is rather different. Most notably, Fannie Mae and Freddie Mac were converted to private companies, with shareholders, which then went broke when housing prices declined in the lead-up to the Great Recession, and have been run by the federal government under a bankruptcy conservatorship since then. However, the Federal Home Loan Banks came through the financial crisis of 2008-09 without requiring any financial support.

For those occasions when it is useful to understand the Federal Home Loan Banks, and how it differs from the other housing-related institutions, the Congressional Budget Office offers some guidance in “The Role of Federal Home Loan Banks in the Financial System (March 2024). From the “At a Glance” overview to the report:

In 1932, lawmakers created a system of Federal Home Loan Banks (FHLBs) as a government-sponsored enterprise (GSE) to support mortgage lending by the banks’ member institutions. The 11 regional FHLBs raise funds by issuing debt and then lend those funds in the form of advances (collateralized loans) to their members—commercial banks, credit unions, insurance companies, and community development financial institutions.

In addition to supporting mortgage lending, FHLBs provide a key source of liquidity, during periods of financial stress, to members that are depository institutions. During such periods, advances can go to institutions with little mortgage lending. Some of those institutions have subsequently failed, but the FHLBs did not bear any of the losses.

FHLBs receive subsidies from two sources because of their GSE status:

• • The perception that the federal government backs their debt, often referred to as an implied guarantee, which enhances the perceived credit quality of that debt and thereby reduces FHLBs’ borrowing costs; and

  • Regulatory and income tax exemptions that reduce their operating costs.

Federal subsidies to FHLBs are not explicitly appropriated by the Congress in legislation, nor do they appear in the federal budget as outlays. The Congressional Budget Office estimates that in fiscal year 2024, the net government subsidy to the FHLB system will amount to $6.9 billion (the central estimate, with a plausible range of about $5.3 billion to $8.5 billion). That subsidy is net of the FHLBs’ required payments, totaling 10 percent of their net income, to member institutions for affordable housing programs. CBO estimates that in fiscal year 2024, such payments will amount to $350 million.

What is the ownership structure of the FHLB system?

The FHLB system is organized as a cooperative; the individual banks are owned by their members, and FHLBs do not issue publicly traded stock (in contrast to Fannie
Mae and Freddie Mac). One implication is that the system is run for the benefit of its members. The 11 FHLBs are jointly and severally liable for the system’s debt; if any one of them fails, the remaining banks become responsible for its debt.

In dollar terms, what’s the shape of the FHLB system?

As of December 31, 2022, the FHLBs reported assets of $1,247 billion, liabilities of $1,179 billion, and capital (the difference between assets and liabilities) of
$68 billion. Assets included $819 billion in advances, $204 billion of investments, and a $56 billion mortgage portfolio. Liabilities included $1,161 billion of debt.
For calendar year 2022, FHLBs reported net income of $3.2 billion and paid members $1.4 billion in cash and stock dividends. FHLBs’ affordable housing payments that year amounted to $0.4 billion.

What makes the FHLB system so safe, so that it sailed through even the 2008-09 Great Recession?

FHLBs require borrowing members to pledge specific collateral against advances, thus giving the FHLBs priority in receivership over other creditors, including the FDIC [Federal Deposit Insurance Corporation]. Such lending therefore limits the assets that the FDIC has access to when resolving a failed commercial bank. Moreover, if a commercial bank that is a member institution fails, FHLBs’ advances are paid before the FDIC is paid because the FHLB has a priority claim on collateral. The FDIC is thus exposed to more losses, whereas FHLBs are fully protected. … However, FHLBs face interest rate risk, which is the risk that changes in rates will affect the value of bonds and other securities. FHLBs attempt to limit that risk by matching the maturities of their assets and liabilities and through other types of hedging. Interest rate risk stemming from mortgage portfolios has contributed to losses by some banks in the past.

How is the FHLB system different from Fannie Mae and Freddie Mac?

[A] large secondary (or resale) mortgage market has developed in which Fannie Mae and Freddie Mac, two other housing GSEs that are now in federal conservatorship, play dominant roles … Fannie Mae and Freddie Mac purchase mortgages from lenders (including members of the regional FHLBs) and package the loans into mortgage-backed securities that they guarantee and then sell to investors … Today, the primary business of FHLBs is still making advances to their members.

Why is the FHLB system referred to as the “lender of next-to-last resort”?

During financial crises and other periods of market stress, FHLBs also provide liquidity to member institutions, including those in financial distress. Providing liquidity is one way to protect the financial system from liquidity-driven bank failures. In normal times, however, FHLBs aim to increase the availability of, and lower the rates of, residential mortgages by serving as a source of subsidized funds for financial institutions originating those mortgages. … FHLBs are a “lender of next-to-last resort.” (Banks turn to them before accessing the Federal Reserve’s discount window because borrowing from the window signals that a bank is under stress.)

If we were reinventing the housing finance system today, it seems unlikely to me that we would create the Federal Home Loan Bank system. It's been a long time since 1932. Today, the financing for more than half of all home mortgages doesn’t originate from banks, but instead from “nonbank” financial institutions. But that said, the FHLB system doesn’t cost the government anything directly, it’s part of the network of housing-related finance, and it provides a layer of extra protection as the lender of next-to-last resort for banks under stress. Given that the institution already exists, it feels as if unwinding the $1 trillion-plus in assets would be a substantial task, with limited benefits.