[1]Mortgage real estate investment trusts (mREITS) that currently receive funding from the Federal Home Loan Banks (FHLBanks) will see their funding phased out after five years from the effective date of the FHFA’s final rule for FHLB membership [2], which was announced on January 12.
The new rule cuts off the possibility of FHLBank membership for non-bank financial institutions such as hedge funds, investment banks, and equity REITs, keeping in line with the FHLBanks’ mandate of serving the housing finance market by extending credit to commercial banks, credit unions, and savings/loan institutions.
FHLB system's traditional mandate is to serve the US housing finance market by extending credit to commercial banks, credit unions, and savings/loan institutions
Those mREITs which received captive insurance subsidies from FHLBanks prior to September 2014, when the FHFA originally published the membership rule, will be eligible to receive funding for another five years from the date the rule becomes effective, which will be 30 days after it is published in the Federal Register. With ample time left to find replacement funding, mREITs are faced with a key decision, according to Fitch Ratings: Go with either low-cost, short-term repo funding with a shorter duration and increased liquidity risk, or long-term borrowings that include increased funding costs and affect profitability.
“From a credit risk perspective, we would view the latter more favorably because of the benefit to asset-liability duration matching,” Fitch stated.
Fitch Ratings believes that an mREIT such as Ladder Capital used the FHLBank system for approximately 42 percent of its funding as of September 30, 2015, will benefit from the five-year phase out provision of FHFA’s final rule. While many REITs have used the FHLBank system for a significant portion of its funding, the total FHLBank advances for the 10 largest mREITS were just 10.6 percent of their overall debt funding. The phasing out of borrowing from the FHLBank system “incrementally weakens the diversification of (mREIT) funding sources,” according to Fitch.
The establishment of captive insurance subsidies gave nonbank financial institutions greater access to FHLBank membership starting in 2012, and 2015 saw a significant ramp-up, according to Fitch. At least 23 insurers (out of 7,255 institutions that were members of the FHLBank system, 346 of which were insurance companies) were captive insurance subsidiaries of mREITs, while FHLBank advances increased from 11.6 percent of par value at year-end 2011 up to 15.6 percent of par value by September 30, 2015, according to Fitch.