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Title page 1

Contents 4

Highlights 2

Letter 7

Background 10

The FHLBank System and Advances 10

Bank Population 12

Role of Federal Financial Regulators and Federal Reserve Banks 13

Recent Periods of Financial Stress 15

Most Banks Have Maintained Relatively Consistent FHLBank Borrowing Since 2015 16

A Majority of Banks Have Regularly Borrowed FHLBank Advances Since 2015 16

Large Banks Were Responsible for Most FHLBank Borrowing Since 2015 21

Banks' Ratio of FHLBank Borrowing to Total Assets Generally Has Stayed Within a Consistent Range Since 2015 22

Selected Banks Reported That FHLBank Advances Have Advantages over Other Funding Sources 24

For Most Banks, Higher FHLBank Borrowing Was Associated with Positive Outcomes from 2015 Through 2024 26

Small Banks with Higher FHLBank Borrowing Lent More on Average Than Those with Lower FHLBank Borrowing 26

Small Banks with Higher FHLBank Borrowing Were Generally Less Likely to Have Serious Safety and Soundness Issues 30

Potential Changes to FHLBank Lending Raise Key Trade-Offs for Policymakers 34

Commonly Cited Concerns About FHLBank Lending Relate to Perceived Structural Incentives for Risk-Taking 34

Certain Changes to FHLBank Lending Suggested in Literature Have Trade-Offs, and Some Duplicate Existing Authorities 37

Other Considerations Could Help Inform Policy Deliberations on FHLBank Lending 46

FHLBanks and Federal Reserve Banks Have Ongoing Efforts to Improve Coordination 48

FHLBanks, FHFA, and Banking Regulators Meet Regularly to Discuss Policy and Other Issues 48

Efforts to Improve Routine and Emergency Coordination Between FHLBanks and Federal Reserve Banks Are Ongoing 49

Agency Comments 54

Appendix I: Objectives, Scope, and Methodology 56

Appendix II: Description of GAO's Econometric Models of Associations Between FHLBank Borrowing and Banks' Outcomes 66

Appendix III: Discussion Group Participants 80

Appendix IV: GAO Contact and Staff Acknowledgments 82

Bibliography 83

Tables 4

Table 1. Median Ratio of FHLBank Borrowing to Total Assets, by Bank Size, First Quarter 2015-Second Quarter 2025 23

Table 2. Variables Used and Estimated Associations Between Total Outstanding FHLBank Borrowing and Total Lending by FHLBank Members, 2015-2024 70

Table 3. Estimated Associations Between FHLBank Borrowing and Lending by FHLBank Members, by Borrowing Measure and Loan Type, 2015-2024 71

Table 4. Variables Used and Resulting Odds Ratios from Regression Analysis of Appearance on the Problem Bank List, 2015-Third Quarter 2024 74

Table 5. Variables Used and Resulting Odds Ratios from Regression Analysis of Appearance on the Problem Bank List, by FHLBank... 75

Table 6. Variables Used and Resulting Odds Ratios from Regression Analysis of Bank Failure or Liquidation, 2015-Third Quarter 2024 76

Table 7. Variables Used and Resulting Odds Ratios from Regression Analysis of Bank Failure or Liquidation, by FHLBank Membership... 78

Figures 5

Figure 1. Number of Banks, by Asset Size, and Total Banking System Assets, First Quarter 2015-Second Quarter 2025 13

Figure 2. Total Outstanding Federal Home Loan Bank Borrowing, by Bank Size, First Quarter 2015-Second Quarter 2025 18

Figure 3. Banks' Share of Total Outstanding FHLBank Borrowing, by Bank Size, First Quarter 2015-Second Quarter 2025 21

Figure 4. Total Outstanding Federal Home Loan Bank Borrowing, by Bank Size, First Quarter 2015-Second Quarter 2025 22

Figure 5. Banks' Overall Lending Outcomes by FHLBank Borrowing Measure, 2015-2024 27

Figure 6. Banks' Real Estate Lending Outcomes by FHLBank Borrowing Measure, 2015-2024 28

Figure 7. Banks' Consumer Lending Outcomes by FHLBank Borrowing Measure, 2015-2024 29

Figure 8. Banks' Likelihood of Appearing on FDIC's Problem Bank List by FHLBank Borrowing Measure, 2015-Third Quarter 2024 31

Figure 9. Banks' Likelihood of Failure or Liquidation by FHLBank Borrowing Measure, 2015-Third Quarter 2024 32

Figure 10. Overlap Between Member Banks of FHLBanks and Federal Reserve Banks, as of March 31, 2025 51

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