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Announcement: Moody's: FHLBanks facing GAAP pressures on OTTI losses in
2009
Global Credit Research - 08 Jan 2009
New York, January 08, 2009 -- The Federal Home Loan Banks (FHLBanks) are currently facing the potential for
substantial accounting impairments on their $76.2 billion private-label MBS securities portfolio, Moody's Investors
Service says in a recent report. Under a worst-case scenario, only four of 12 FHLBanks' capital would remain
above regulatory minimums, but the rating agency states that this situation is unlikely. Nevertheless, the report
suggests that the amount of loss "could be material to the banks' capital bases."
The FHLBanks were created to provide member institutions with a stable source of funding, mainly by supplying
cash advances in exchange for collateral. Since the beginning of the credit crisis, the FHLBanks' role has become
increasingly important, Moody's notes, because they have been a vital source of reliable liquidity to their members
and, thus, to the US banking system.
Based on then-current market prices in 3Q08, the banks' total private-label MBS portfolio was valued at $62.7
billion, thus representing a $13.5 billion unrealized loss. In the short term, US GAAP accounting rules may require
the FHLBanks to account for securities in their portfolio as 'other than temporary impairments,'or OTTI , says
Senior Vice President Brian Harris, the author of the report.
"If these unrealized losses are deemed OTTI," he states, "the FHLBanks' capital levels would be significantly
affected -- an issue that is likely to become far more evident during the next two quarters."
"The impact could have important ramifications -- both in terms of more limited, more expensive access to the
capital markets and of heightened regulatory supervision due to the breach of regulatory capital minimums," the
analyst points out.
Should the regulator believe that the OTTI losses of any individual FHLBank will crystallize into realized losses, its
actions could be severe, including conservatorship or a forced merger into a healthy FHLBank. "On balance," Mr.
Harris concludes, "the regulatory response to OTTI will probably focus on capital preservation because we believe
that the ultimate economic losses will be less than OTTI, possibly by a material amount."
Moody's ratings assume a very high degree of government support. "Therefore," the analyst explains, "declines in
capital and the potential regulatory and financial affects could result in reductions of the FHLBanks' Baseline Credit
Assessment (BCA -- the stand-alone ratings of the entities), but the FHLBanks' Aaa senior debt rating and Prime1 short-term debt rating are likely to remain unchanged."
The analyst concludes that the importance of the FHLBanks' lending activities is so significant that the regulators
would be unlikely to reduce individual banks' lending activities even if they were to incur substantial OTTI charges.
The report is titled "Rating Implications on the Federal Home Loan Banks from Other-than-Temporary
Impairments."
***
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New York
Brian L. Harris

Senior Vice President
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653
New York
Robert Young
Managing Director
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

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