Community Support Statements
Every two years, each FHLB Des Moines member must complete a Community Support Statement (CSS) for the Federal Housing Finance Agency (FHFA). To stay eligible for all services, including long-term advances, members must meet two standards:
1. If a member is subject to Community Reinvestment Act (CRA) requirements, as are banks and thrifts, they need to earn a CRA evaluation of outstanding or satisfactory from their regulator. If a member's most recent federal CRA rating is "Needs to Improve," FHFA will place that member on probation until it receives the rating from its next CRA examination. During the probationary period, it will retain access to long-term advances. If the member does not receive an improved CRA rating at its next CRA evaluation, its access to long-term advances will be restricted.
If a member's most recent federal CRA rating is "Substantial Non-compliance," FHFA immediately will take action to restrict that member's access to long-term advances. The restriction will remain in effect until the member's CRA rating improves.
2. All FHLB Des Moines members (i.e. banks, thrifts, credit unions and insurance companies) MUST meet a first-time homebuyer standard (see the Community Support Statement Instructions). This would include institutions not subject to the requirements of the CRA.
Every two years, the Bank sends a notice with an updated CSS form, CSS form instructions and a due date. The FHLB Des Moines Advisory Council, nonprofits and other housing advocates in the relevant district market areas are also notified in case they wish to comment on the institution’s performance record.
If a member fails to complete and return the CSS in a timely manner, the FHFA regulates that FHLB Des Moines restrict a member’s access to services. It is important that FHLB Des Moines members submit a completed Community Support Statement to the FHFA before the deadline to avoid being put on restriction.
Additional Resources
Members Subject to Community Support Review
Community Support Statement Submission Portal
If you have any questions, please contact the Member Service Team at 800-544-3452 ext. 2200 or via email at CommunitySupportProgram@fhlbdm.com.