I have been presented a question whether my bank would potentially receive CRA credit by acting as an intermediary between a mortgage lender and the FHLB. My bank would use its access to FHLB Affordable Housing Program funds and allow the mortgage lender to use these funds inside our assessment area to lend to a qualified LMI borrower. The thought is since my bank is using the funds in our name we would obtain some form of credit. I have tried to research this, and the closest FAQ found was concerning providing technical assistance .12(t)-3. That said, I am not exactly sure this would qualify as technical assistance. Our MLO discussed this with the FHLB and was told we should receive some CRA credit as they were aware other banks doing something similar received credit; however, the FHLB could not offer how such credit was determined nor if it was as CD lending or service.

Anyone familiar with such an arrangement, and if so, can you point me to an FAQ to assist with documenting for exam purposes.

If your financial institution, as the member of the FHLB, is acting as a sponsor of a AHP funded initiative, your primary federal regulator should afford some kind of positive consideration under the CRA. You can see, though, how different federal regulators may address this fact circumstance differently. It's a [censored] shoot.

We have been provided CRA Service consideration for the time spent on the application, deployment and oversight of the program and CDL consideration for our loan(s) that support the project(s). Even if you are not the lender, you should still be able to get CRA Service consideration for facilitating the FHLB funding.