Community Impact Advance Pilot Program FAQ
Find answers to commonly asked questions about the Community Impact Advance.
Pilot Program Details
The Community Impact Advance Pilot Program (Pilot Program) is an advance product that allows members to borrow at 50 to 200 basis points (bps) below regular advance interest rates for providing direct support through new grants, loans, or investments for affordable housing and economic development, and to community partners in Illinois and Wisconsin.
July 16, 2024 – June 30, 2027
FHLBank Chicago is committed to delivering innovative regional support to our members and their communities. Our goal for the Community Impact Advance is to directly support specific affordable housing and community development needs identified in our Targeted Community Lending Plan.
- Interest rate subsidy is the amount of money that FHLBank Chicago forgoes in interest payments to essentially buy down the Community Impact Advance rate by up to 200 bps.
- Each member has a $1 million interest rate subsidy limit. For affiliated members, the limit applies to all affiliates jointly.
- Members should use the Community Impact Advance subsidy calculator on at the bottom of the Community Impact Advance page prior to reservation.
- Members will be required to provide the advance structure (maturity term, advance amount, and rate discount) in an application to reserve interest rate subsidy. Once these details are provided, the interest rate subsidy amount will be calculated on the application screen.
Only an authorized advance transaction user should submit and execute a Community Impact Advance.
An interest rate subsidy that is not used within the 90 calendar-day period following its submission will expire. The reserved subsidy will be returned to the individual member’s limit and overall Pilot Program limit. No exceptions or extensions are permitted for submitted reservations.
The Community Impact Advance is approved for three years, subject to availability of funding. It is challenging to predict or forecast market movements and therefore predict when funding under this Pilot Program may be utilized. FHLBank Chicago’s goal through the Community Impact Advance is to support members in filling unmet community needs in Illinois and Wisconsin.
Advance Structure
Only A121 fixed rate, fixed term advances can be executed under the Community Impact Advance. Advances must be between one- and 10-year term. Refer to the “Program Requirements” document on eBanking for more information.
The interest rate discount is only available in 25 bps increments from 50 to 200 bps (25, 50, 75, 100, 125, 150, 175, or 200).
Members can execute multiple advances of any size, more than $10,000, as long as per-member and Community Impact Advance Pilot Program limits are not exceeded. The size of the advance depends on the interest rate discount, the advance term, and the advance amount selected by the member.
Members are allowed to change any terms of the advance within the reservation application, subject to available per-member and Community Impact Advance Pilot Program limits. However, once Impact Data is submitted by the member to FHLBank Chicago, no changes to advance terms will be allowed.
Members will be required to execute the advance with the same terms as requested in their reservation application when calling in to the Member Transaction Desk at 855.345.2244, option 1, or mtd@fhlbc.com.
No. Underlying eligible activities do not need to be match funded. This means the advance term may differ from underlying activities, and one advance can support more than one underlying activity. However, the advance amount cannot exceed the total amount of the underlying activities.
A reservation for interest rate subsidy can only apply to one advance and one Impact Category. If a member wants to use the Community Impact Advance Pilot Program for multiple advance structures, the member must submit multiple reservations. If a member wants to use the Community Impact Advance for more than one Impact Category, the member must submit multiple reservations.
No. Community Impact Advances are not allowed to have a different settlement date from the date at which the member calls in to execute the advance. However, advances can be executed on a day at the member’s choice within the reservation period, but only after impact data has been submitted to FHLBank Chicago.
No, the advance maturity does not need to match the maturity of the underlying loan.
No, the advance is not required to be prepaid if the underlying loan prepays. FHLBank Chicago encourages that your institution uses any existing advance funding to support new community investment activities instead.
Community Impact Advances have a minimum term of one year. However, FHLBank Chicago offers Community Advances that can be less than one year term. Please see our Community Advances page for more information.
Standard prepayment fees apply to all Community Impact Advances. If underlying loans prepay, there is no requirement to prepay the advance, though you are encouraged to repurpose the funds for other community investment activities. If you have questions on any applicable prepayment fees, please contact your sales director.
Eligibility
Qualifying activities may be direct grants, loans, or investments in one of three Impact Categories: Affordable Housing, Economic Development, and Community Partners. Underlying activities are limited to Illinois and Wisconsin and subject to area median income (AMI) restrictions. High-level eligibility requirements can be found on our Community Impact Advance page, and more specific eligibility requirements are outlined in the “Program Requirements” document in eBanking.
Refer to the “Program Requirements” document in eBanking. For questions, reach out to your sales director or the Member Transaction Desk at 855.345.2244, option 1, or mtd@fhlbc.com.
No. In addition to AMI requirements, all activities are limited to only Illinois and Wisconsin.
No, the purpose of the Community Impact Advance is to incentivize new investments in communities in Illinois and Wisconsin. Activities must be awarded, issued, closed, or settled after July 1, 2024, and before an advance is transacted.
AMI limits for the Community Impact Advance are in the “Community Impact Advance Income Limits Workbook” at the bottom of our Community Impact Advance page.
Mixed use developments may qualify based on location and should be evaluated under affordable housing. The location of the development must be in a census tract <=100% AMI. Mixed use developments may not qualify based on borrower income at this time.
No, the purpose of the Community Impact Advance is to create new investments in communities in Illinois and Wisconsin. Refinances and renewals of loans would not be considered new activities under the Community Impact Advance.
Yes, a new loan to an existing customer would be eligible, if it satisfies all other eligibility requirements. New activities are not limited to only new customers.
FHLBank Chicago is not restricting the terms of underlying loans or investments supporting a Community Impact Advance. However, a goal of the Community Impact Advance is to amplify our support of affordable housing and economic development in Illinois and Wisconsin by lowering funding costs for members and their customers and partners.
Purchasing bonds can qualify if a new, direct investment of your institution in one of the Impact Categories. All eligibility requirements of the Community Impact Advance must be met. Bonds under the Economic Development Impact Category should be supporting specific, economic development projects or creating and retaining jobs in low-to-moderate income census tracts.
Possible bond classes that may qualify include housing development bonds, single-property multifamily bonds in low-income areas (Fannie DUS or Freddie PCs for example), or municipal bonds.
No, the only nonprofits that qualify under the Community Partners Impact Category are 501(c)(3)-designated nonprofits.
For the activity to qualify under the Community Impact Advance, the lending must be to a small business that meets the Small Business Administration’s small business size standards set forth in 13 CFR Part 121.
A participation loan is not disqualified from supporting a Community Impact Advance as long as it meets all other eligibility requirements.
FHLBank Chicago will not provide guidance on whether a specific member activity is eligible. Please refer to the “Program Requirements” and “User Guide” documents in eBanking for determination of eligibility.
Procedure
The application for a Community Impact Advance is available under an eBanking banner on the home page. Use the “Community Impact Advance User Guide” within the application system for step-by-step directions.
Impact Data reporting is dependent upon the Impact Category the qualifying activities fall under. For Affordable Housing activities, property locations and number of households or rental units are required. However, for Economic Development activities, locations of businesses and projects and number of jobs created or preserved are required. View detailed Impact Data reporting requirements on the “Community Impact Advance User Guide” on eBanking.
Someone with advance transaction authority at your institution must call the Member Transaction Desk 855.345.2244, option 1, and refer to the application number provided at the time the subsidy reservation was approved. Remember that Impact Data must be reported to FHLBank Chicago before an advance may be executed, and someone with advance transaction authority must submit the application for final approval.
You will no longer be able to make changes to your reservation or Impact Data after submission to FHLBank Chicago. After the advance is executed, members are not expected to maintain and update Impact Data as the activities should already be closed, settled, issued, or awarded.
By submitting Impact Data and receiving full approval of your application, you are now ready to transact an advance. Funds will be available following the advance execution. Please contact the Member Transaction Desk at 855.345.2244, option1, for additional information.
There are no ongoing reporting requirements for members. Impact Data should be accurate and complete at the time of submission.
Other Questions
Contact your sales director or the Member Transaction Desk at at 855.345.2244, option 1, or mtd@fhlbc.com.
Please refer to the appropriate CRA regulations to make this determination. Certain activities that support a Community Impact Advance may qualify for CRA credit dependent upon the activity type, the assessment area of your institution, and other factors that determine CRA credit.
For properties located in Illinois or Wisconsin, DPP-eligible loans may qualify for the Community Impact Advance. Affordable housing lending can qualify for borrowers with income at or below 150% AMI, which includes DPP-eligible loans, as per requirements under the DPP program such loans are restricted to 80% AMI. Members should refer to the Community Impact Advance income limits specific to this Pilot Program to ensure eligibility before submitting an application.