Government funding runs on a fiscal year that ends on Sept. 30. Ideally, Congress would have passed all twelve appropriations bills long before the deadline, but “regular order” has become rare and large omnibus funding bills the norm. An election year makes regular order even more elusive as small majorities, and a divided government have both parties counting on more leverage following the election.

This year Congress was forced to once again pass a continuing resolution (CR) to temporarily fund the government. The extension to Dec. 20 will make for uncertain holiday plans and assures that retiring and defeated members of Congress will get a final opportunity to add their priority legislation to a huge bill just before the end of their terms. The passed CR funds government at current levels but also included an additional $231 million for the Secret Service to carry out protective operations, including activities related to the 2024 presidential election and other special security events. 

Congress has now left Washington until after the election, but there’s still lots of activity. Presidential transition teams for both candidates are working to be ready to fill nearly 4000 presidential appointments, 1200 of which require Senate confirmation. They are also working to develop a policy agenda that can quickly show the impact of the new administration. Meanwhile, agencies continue rulemaking in hopes that the election doesn’t force them to alter course.

Ranking Member Tim Scott Introduces Housing Legislation

Senate Banking Committee Ranking Member Tim Scott (R-SC) introduced the Renewing Opportunity in the American Dream (ROAD) to Housing Act.

The legislation includes:

• Reforms to housing counseling and financial literacy programs. Requires housing counseling assistance through the Department of Housing and Urban Development (HUD) to be distributed in a geographically diverse manner that appropriately considers organizations serving rural and urban areas and requires assistance to be prioritized for organizations serving areas with the highest foreclosure rates.
• Rental assistance demonstration program. Eliminates the cap on the number of public housing units that may be converted under the Rental Assistance Demonstration (RAD) to allow for other forms of federal assistance and provide opportunity for private investment that is currently unavailable for public housing.
• Loan originator compensation. Directs the Bureau of Consumer Financial Protection (CFPB) to update Regulation Z and increase flexibilities for loan originator compensation to encourage origination of small dollar mortgages under $70,000.
• Authorization of Moving to Work Program (MTW). Fully authorizes the MTW Program and requires evaluation of housing reforms undertaken by MTW participants to identify replicable program models to improve cost-efficiency and outcomes for families in HUD-assisted housing.
• Definition of manufactured home. Updates the definition of manufactured home, which is limited to structures that are built on a permanent chassis, to include other modular or prefabricated housing by striking the limitation.
• Opportunity Zone priority. Requires HUD to prioritize awarding of competitive grants relating to the construction or preservation of housing to recipients located in or that primarily serve communities designated as Opportunity Zones.

September update from the Council of FHLBanks, a trade association for the FHLBank System is available here.

In 2024, the FHLBanks will award AHP funds assessed in 2023 to support homeownership and affordable rental housing projects across the 11 FHLBank districts. In addition, in 2023, the FHLBanks committed to provide an additional 50 percent of prior year earnings to fund voluntary AHP awards and other voluntary programs, which is anticipated to result in $1 billion in grants and subsidized loan awards in 2024.

Click here to view FHLBank Affordable Housing Program and Voluntary Programs Update.

Request for Information on the Discount Window:



The Board of Governors of the Federal Reserve System (Board) seeks public input

on questions related to the operational aspects of Federal Reserve Bank (Reserve Bank)

extensions of discount window and intraday credit.

Comments are due by Dec. 9, 2024.

Information requested includes:

Discount Window Operations:

1. For the following discount window operational processes, what operational frictions or inefficiencies exist? Are there any specific actions that could be taken by the Federal Reserve to address those issues?

a.    Submitting legal documents to a Reserve Bank.

b.    Pledging or withdrawing securities as collateral.

c.    Pledging or withdrawing loans as collateral.

d.    Requesting discount window advances and receiving proceeds.

e.    Repaying discount window advances before their full maturity.

f.     Using the Discount Window Direct online portal.

2. Are there operational frictions or inefficiencies in the processes mentioned above that are particularly acute or pressing for FHLB members? What specific improvements could be made with respect to depository institutions that are members of an FHLB?

3. Are there operational frictions or inefficiencies in the processes mentioned above that are particularly acute or pressing for smaller depository institutions or depository institutions that use correspondents to interact with the Federal Reserve? What specific improvements could be made with respect to these institutions?

General Questions:

• Are there other changes that the Federal Reserve could make to improve the operational efficiency of the discount window and intraday credit?
• What operational aspects of accessing Federal Reserve discount window and intraday credit programs are most costly or burdensome for depository institutions, both in terms of direct expenses and staff hours?

FDIC Board of Directors Approves Final Statement of Policy on Bank Merger Transactions



The Federal Deposit Insurance Corporation (FDIC) Board of Directors approved a final Statement of Policy on Bank Merger Transactions (Final SOP). The Final SOP addresses the scope of transactions subject to FDIC approval, the FDIC’s process for evaluating merger applications, and the principles that guide the FDIC’s consideration of the applicable statutory factors as set forth in the Bank Merger Act.

With respect to the statutory factors, the Final SOP:

• Confirms that the FDIC’s evaluation of a merger’s competitive effects may take into account concentrations beyond deposits, including small business or residential loan originations;
• Clarifies that the proposed merger should result in less financial risk than the risk posed by the institutions on a standalone basis;
• Elaborates on the FDIC’s expectation that a merger will enable the resulting institution to better meet the convenience and needs of the community to be served; 
• Applies additional scrutiny to the evaluation of financial stability for transactions resulting in an institution with $100 billion or more in total assets; and
• Communicates the FDIC’s expectation to hold public hearings for mergers resulting in an institution with over $50 billion in total assets.

HUD Final Rule to Expand Offerings at Housing Counseling Agencies:

The Modernizing the Delivery of Housing Counseling Services final rule now allows HUD-approved housing counseling agencies to use alternative communication methods, including meeting virtually and by phone, to engage and educate homebuyers and renters seeking support with their housing needs.

The rule aims to increase accessibility for people who have difficulty obtaining in-person services due to linguistic, physical, geographic or other barriers such as transportation and childcare costs. Expanding these options is also a more cost-effective and efficient way for housing counseling agencies to meet with their clients, as they no longer need to maintain multiple facilities for in-person engagements. Participating agencies that are unable to provide virtual and/or remote meeting flexibilities or in-person counseling to clients who need them are required to refer those in need of services to other agencies.