The Consumer Federation of America, together with the Coalition for Federal Home Loan Bank Reform (CFR) and other housing advocacy organization, submitted a comment letter to the Federal Housing Finance Agency (FHFA) outlining key recommendations to strengthen the governance and accountability of the Federal Home Loan Banks (FHLBs). The coalition calls for expanding the expertise of public interest board directors, to include fair housing, tribal housing, and community development. Moreover, for regular independent and member directors, they recommend adding more expertise on affordable housing lending, CDFI lending, and climate finance on the boards.

They also urge FHFA to rebalance board composition by increasing the number of public interest independent directors and moving toward a 50/50 split between independent and member directors to better align the FHLB system with its public mission.

A major focus of the letter is excessive executive compensation, with the coalition urging FHFA to impose limits on the pay of FHLB presidents, who earned an average of $2.9 million in 2023—far exceeding comparable public-sector and GSE roles. They recommend that executive compensation be tied to mission-driven outcomes, such as the number of new housing programs launched, increased Community Investment Cash Advance (CICA) and Community Investment Program (CIP) usage, and greater support for mission-focused lenders like housing finance agencies (HFAs), small community banks, and CDFIs. The coalition emphasizes that without these governance reforms, the estimated $7.3 billion in annual federal subsidies risk being misallocated toward corporate profits rather than advancing fair and affordable housing and community development. They commend FHFA for addressing these governance issues and urge additional reforms to ensure that FHLBs fulfill their public mission effectively and efficiently.