Federal Home Loan Banks Have Mixed Risk Profiles Relative to Non-Member Banks, New Study Shows

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Tim Yeager

FAYETTEVILLE, Ark. – In the first study to examine the impact of Federal Home Loan Bank membership and funding on commercial bank risk, a University of Arkansas researcher found evidence to suggest that member banks have somewhat higher risk profiles than non-member banks.

“Although our findings suggest that the cumulative impact of FHLB membership and advances on bank risk is modest, we caution that our sample period was one of robust economic growth, and that serious moral-hazard problems could arise if bank leverage ratios revert to historical norms,” said Tim Yeager, associate professor of finance in the Sam M. Walton College of Business. “The increasing reliance on these advances is a potential safety and soundness concern because access to them can undermine market discipline, and the FDIC (Federal Deposit Insurance Corp.) cannot raise premiums sufficiently to deter risk-taking.”

Yeager wanted to know if FHLB membership and advances could lead to greater risk-taking by banks. Congress established the FHLB system in 1932 to advance funds against mortgage collateral. As such, the system pre-dates Fannie Mae and Freddie Mac as the first government-sponsored enterprise for housing. FHLB banks have provided a source of long-term stable funding for home mortgages.

Initially, membership was limited to thrifts, which are financial institutions that focus on taking deposits and originating home mortgages. But recent passage of federal laws, including the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 and the Federal Home Loan Bank Modernization Act of 1999 have opened the system to commercial banks and credit unions. Since the early 1990s, commercial banks have turned to FHLB advances to plug the gap between loans and deposits. The controversial issue, as Yeager mentioned, is that this practice could lead to safety and soundness problems by relaxing constraints on risk-taking in the same way that brokered deposits helped savings and loan institutions ramp up risk in the 1980s.

Yeager found that liquidity risk and leverage risk rose modestly for FHLB members compared to non-members. Liquidity risk represents threats to a financial institution’s ability to convert assets into cash or quickly cover current financial liabilities with current assets. Leverage risk rises as the firms take on more debt for a given amount of equity because large financial losses could leave the bank insolvent.

The study revealed that interest rate risk – a drop in bank earnings or equity due to the variability of interest rates – declined somewhat for banks that accepted advances as a benefit of FHLB membership. Credit risk – the risk of loss due to a debtor’s non-payment of a loan or other line of credit – and overall bank failure were largely unaffected by FHLB membership.

“Although the evidence fails to produce a ‘smoking gun,’ the worrisome incentives embedded in the FHLB advances should give policymakers pause,” Yeager said. “We argue that bank supervisors should remain vigilant, and only careful monitoring by state and federal supervisors can prevent distressed banks from responding to the moral-hazard incentives associated with FHLB funding and underpriced deposit insurance.”

Yeager suggests that legislators and banking regulators consider imposing usage restrictions on advances similar to those used on brokered deposits, which would curtail access to advances as bank risk increases and capital ratios decline. Secondly, the FDIC and other regulators may attempt to remedy the situation by imposing a capital charge on banks with large amounts of collateralized obligations. The FDIC recently announced that it will take FHLB advances into account when setting deposit insurance premiums in 2009.

Overall, Yeager said, the findings on FHLB activity and risk should help bank managers and supervisors distinguish between prudent and imprudent use of advances.

The study was published in Journal of Banking and Finance.

Prior to his appointment in the Walton College, Yeager was an economist at the Federal Reserve Bank of St. Louis.