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Please note that this transcript reflects corrections to inaccuracies in the realtime closed captioning in the roundtable video. 

Eric Howard: Welcome to FHFA's fourth Roundtable Discussion. To those of you watching us 

live, we are in Oklahoma City. Our discussion today will explore the Federal 

Home Loan Banks’ role or potential role in supporting Native American 

communities. My name is Eric Howard, and I am a principal policy analyst in the 

Federal Home Loan Banks’ Affordable Housing branch. And I am joined by 

Joshua Stallings, the deputy director of FHFA's Division of Federal Home Loan 

Bank Regulation. I am also a proud member of the Choctaw Tribe. I was born 

and raised in Wetumka, Oklahoma, which is a small community founded and 

named by members of the Muscogee Creek Tribe after their ancestral home in 

Alabama. Wetumka is also the headquarters for two federally recognized Tribes, 

the Alabama-Quassarte Tribal Town, and the Kialegee Tribal Town. My family 

has been in Oklahoma for generations, and we have traced our ancestry back to 

Thomas Howard, who received a roll number through the Dawes Commission in 

1907. Growing up in Oklahoma, I've seen firsthand the important roles the 

Tribes play in the lives of their people and in the state. Their efforts to preserve 

their languages, cultures, and traditions are very important, as is their emphasis 

on improving the health, education, and overall welfare of their people and 

their families, and this is also a great source of pride. Another source of great 

pride and in line with what we are here today to discuss are the programs the 

Tribes have implemented to provide housing for low-income households, the 

elderly, and veterans. I know from personal experience the significant impact 

these housing programs have had on the lives of my neighbors, my friends, and 

family. And I still remember to this day the sense of pride and accomplishment 

my aunt felt when she was able to qualify for and receive a single-family home 

through the Choctaw Nation. And this allowed her to raise her family in a safe, 

clean, and modern home. With that, I would like to say, Yokoke or thank you to 

our esteemed roundtable participants, our guests joining us here in-person and 

all of you watching on the livestream. We have been very pleased with the high 

level of stakeholder interest. Joshua will be your moderator today, and I'll turn it 

over to him for some opening remarks. 

Joshua Stallings: All right, thank you for the introduction, Eric. And let me say thank you again to 

our esteemed roundtable participants and those watching on the live stream. As 

Eric noted, this is our fourth roundtable discussion. We had our inaugural 

roundtable just a month ago, it was just a month ago in Washington, DC. We've 

already done four of these and we've got a few more to go before we're done 

here this year where we explored the question of mission and the purpose of 

the Federal Home Loan Bank System. For all of those that are interested, the 

videos and transcripts of that inaugural roundtable can be found on our 

website. We have also been to Chicago and to the Mississippi Delta, where we 

had conversations about vulnerable communities, both in the urban and rural 

environment. These roundtables are the second phase of the Federal Home 
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Loan Bank System at 100: Focusing on the Future initiative. With the Federal 

Home Loan Banks just turning 90 years old and approaching their centennial, 

our director, Director Thompson, felt that now was a good time, it was now as 

good a time as any to conduct a comprehensive review of the Federal Home 

Loan Bank System. We kicked this off with a comprehensive, well, we kicked off 

this comprehensive review with what turned into a three-day, three-part listing 

session due to the high interest. And that was all just the first phase before we 

got into these roundtables. So as I was already saying, we already had, we're on 

the fourth roundtable that we're gonna complete this year with three more to 

come, and we're expecting to do even more as we get into next year. So at

today's roundtable discussion, we'll focus particularly on the topic of the Federal 

Home Loan Bank support for Native American communities. This is actually the 

first of a two-part roundtable as we will continue on the same topic next week 

in Washington, D.C. specific to CDFIs that are doing their work with the Native 

American community. As the director has mentioned many times, safety and 

soundness and equitable access to credit are not mutually exclusive. We, of 

course, will continue to focus on our safety and soundness mission. We are also 

committed to ensuring our regulated entities provide needed liquidity across 

the nation for historically underserved markets and populations such as Tribal 

communities and communities of color. We welcome bold ideas, some of which 

may require legislative action to implement. We also welcome 

recommendations that can be implemented in the near term. The Federal Home 

Loan Bank System has been a critical source of liquidity since its inception 90 

years ago. This is particularly true during times of market stress and particularly 

for smaller members that often haven't had access to other sources of funding. 

Even with that being true, we would like to explore where and how the banks 

can expand their scope and thinking to be creative and to think more broadly 

about how they may help with affordability concerns that are being felt in all 

communities today. In this and future roundtable discussions, we are going to 

be asking some big questions on the Banks’ role or potential role in addressing 

housing finance, community and economic development, affordability, the 

unique needs of rural and financially vulnerable communities and other related 

issues which will inform our actions, and we have been especially encouraged to 

hear from such a varied group of stakeholders. And I should say that we hope to 

extend the reach of this effort as well. That is in fact a big part of this initiative, 

to expand the reach to those that are not familiar with the Federal Home Loan 

Bank system. As the director has repeatedly stated, our stakeholders and 

potential stakeholders are an important part of our review process. While our 

roundtable discussions are with a small group of folks, we are live streaming the 

discussions, so that we can reach stakeholders and extend the reach to as many 

potential stakeholders as possible. In regard to Tribal communities and 

concerns, it is especially important to hear input from Tribal community 

members, especially those who may not be as familiar with the Federal Home 

Loan Banks. To that end, we believe it is critical to get out of Washington, DC, 
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which we have done, right? Here we are. To give us an opportunity to meet 

with local constituents and hear about local issues and topics in addition to 

concerns that may be shared on a more national basis. We look forward to the 

discussion today and the feedback we will receive as we continue the initiative. 

With that, let me thank the roundtable participants again and let us review 

some of the guidelines for the discussion. 

Eric Howard: Okay, so Joshua will be the moderator for our discussion today, and we'll be 

directing questions to our roundtable participants. We expect and hope that we 

will have an open and engaging discussion. No recommendation or views should 

be considered off the table, and we encourage you to offer differing views 

about some important questions that we will be covering this afternoon. We 

also want this to be orderly, and as such, we will ask that everyone turn their 

name placard to the side, so that Joshua will know to call on you. He will call on 

each of you in turn. We ask that everyone engage knowing that we will likely 

not agree on all points and in a respectful manner. To ensure that everyone has 

a turn to speak and we cover every discussion topic, if someone is going long, 

Joshua or I will interject to keep the conversation going. We will also have a 

break, probably 30 minutes based on the amount of time we have, it may be 20. 

And this break will be roughly halfway through today's event. So, we also have a 

disclaimer that we need to make you aware of, and this is something that I'm 

going to read verbatim. We have organized this roundtable to obtain your input 

on the mission of the Federal Home Loan Banks, including input on several 

specific questions that were sent to you prior to the meeting. During today's 

session, FHFA will not discuss the status or timing of any potential rulemaking. If 

FHFA does decide to engage in a rulemaking on any matters discussed today, 

this meeting would not take the place of a public comment process. The rule 

making document would establish the public comment process and you would 

need to submit your comments, if any, in accordance with the submission 

instructions in that document. FHFA may summarize the feedback gathered at 

today's session in a future rulemaking document if we determine that a 

summary would be useful to explain the basis of a rulemaking. Anything said in 

this meeting, and that also includes reactions, nodding, eye-rolling should not 

be construed as binding on or a final decision by the director of FHFA or FHFA 

staff. Any questions we may have are focused on understanding your views and 

do not indicate a policy or legal position. Participants in today's roundtable may 

have a financial interest, whether direct or indirect on outcomes that may affect 

the Federal Home Loan Banks and their businesses. Today's roundtable will be 

live streamed on FHFA's website and video recorded. FHFA may also prepare a 

transcript of today's session, which would include the names of all speakers and 

the organizations they represent if any. The recording and any transcripts 

prepared will be posted on FHFA's website and YouTube channel along with any 

materials being presented today or otherwise submitted in conjunction with the 

roundtable. 
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Joshua Stallings: Okay. And, yeah, they had to edit that with the eye rolling specifically for me. 

I'm a little expressive. You'll see me doing some things, ignore all of that as 

you're talking. So for the benefit of those that are on the live stream, the 

roundtable participants have been given a set of prompts that we will reference

during the course of this afternoon's discussion. We had a chance to meet 

during lunch before the roundtable discussion today, but again, for the benefit 

of those watching, let's begin with introductions. So, let me ask that you 

introduce yourself and state your affiliation with the Federal Home Loan Bank 

System, if you have one, whether that be in your current capacity or a former 

capacity. Let's start with Holly and work our way around clockwise. - Is this on? -

I think they're all on. 

Holly Johnson: Okay. Good afternoon. My name is Holly Johnson. I am a citizen of the 

Chickasaw Nation. I am a CPA, I am also an independent director of the Federal 

Home Loan Bank of Topeka. I have served the Chickasaw Nation in various 

capacities for 25 plus years, having retired as Secretary of Treasury in December 

of 19. I now serve my Tribe as an independent contractor working on special 

initiatives and special projects. I am nearing into my second term as a 

independent director for the Federal Loan Bank of Topeka, so I guess that makes 

seven years of service. I am the incoming audit committee chair and serve on 

the Risk Oversight Committee, as well as having served on Operations and 

Human Resources and Inclusion Committee. And I think I'm here today, not so 

much as an expert in Indian housing or a member bank perspective like my 

colleagues here today, but more as someone having a unique perspective of 

knowing the Federal Home Loan Bank System as well as Tribal government in 

general, so thank you for allowing me to participate. 

Shay Stanfill: Great. Well, first of all, thank you all for coming to Oklahoma and hosting this 

conversation, so welcome to Oklahoma and thank you. My name is Shay Stanfill. 

I'm the director of Housing Management at the Housing Authority of the 

Cherokee Nation. I live in Tahlequah, which is the seat of the Cherokee Nation, 

and I have served Cherokee citizens for longer than I like to admit, now over 20 

years. I've been with the Housing Authority for two years. I'm loosely affiliated 

with the Federal Home Loan Bank through an association with the Oklahoma 

Native Assets Coalition. I'm an Advisory Committee member of that 

organization, and we have recently become a grantee of the Federal Home Loan 

Bank System. 

Jason Brower: My name is Jason Brower. I'm with the First State Bank in Anadarko, Oklahoma. 

I am here just to kind of throw my input and to give you guys an idea of how a 

local community bank has benefited or seen the benefit of down payment 

assistance programs with our Tribal members in Caddo County, Oklahoma. 

Valerie Powell: I'm Valerie Powell. I'm with the Choctaw Nation Housing Authority and I'm 

currently serving as the senior director, and I've been there 25 years and served 

several capacities. I've also served formally on the Federal Home Loan Bank 
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Affordable Advisory Council. Before that I was in the banking industry for 

several years, so thank you. Thank you for coming. 

Robert Fightmaster: I'm Robert Fightmaster. I am the president of mortgage lending for First 

National Bank and Trust, a wholly owned entity of Citizen Potawatomi Nation. 

I'm also the current president of the Oklahoma Mortgage Bankers Association. 

My banking relationship with Federal Home Loan Bank goes back 10 to 12 years. 

We've sold into the program for a long time. We've been able to help 150 or so 

people get in the down payment assistance program over the years through the 

set aside and also through the program with ONAC. So we're big fans of the 

system and we use it on a pretty much daily basis. Good partners. 

Sharon Wise: Hello, my name is Sharon Wise. I'm with Native American Housing Services. 

We're a 501(c)(3). Thank you so much for inviting us to be here today. I'm a 

Choctaw Tribal member, but our organization is Native, but it is not under any 

Tribe or as such. I started Native American Housing Services in 1999 and I left 22 

years of mortgage banking to do so. So, we've worked with several Tribes in 

several areas. We've been the recipient of, I don't know exactly, two to three 

AHP grants in conjunction with tax credit projects that we're partnered on. And 

probably in 2000 or 2001 we wrote an AHP for the Apache Tribe of Oklahoma 

for down payment assistance and it was one of the first ones. So, I've been 

around a long time. Maybe that's why you invited me here. But it's a pleasure 

to be here. Thank you.

Gene Watson: Thank you for inviting me, my name is Gene Watson. I'm the CEO of Chickasaw 

Community Bank in Oklahoma City. Chickasaw Community Bank's a bank that's 

solely owned by the Chickasaw Nation. We were founded 20 years ago by 

Governor Anoatubby, with a vision of providing capital in Indian country where 

capital was hard to find or didn't exist at all. Happy to say that over the last 20 

years that our institution has become a leader in the 184 Native American Home 

Loan product. We currently service over a billion dollars in servicing of that 

product for Native Americans across the country. We have a network of local 

lenders throughout several states that we work with on a correspondent or a 

wholesale basis. We provide the secondary market for that 184 product 

throughout the country. And thank you for inviting us. We're excited to 

participate. The bank's also a member of the Federal Home Loan Banking 

System. And typically, historically, we've leveraged that relationship for liquidity 

on big projects that we've done in the past, so thank you for inviting me. 

Joshua Stallings: So we have people today, people at the table today who touch the housing and 

community development space from different angles. We have bankers, Tribal 

housing authorities and service providers. So if we can, let's start by setting a 

shared foundation. So, what are some important housing issues you see that are 

specific to your Tribe or Tribal area in general? And, Shay, can we start with

you? 
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Shay Stanfill: Sure. So it's not just our market, but I think this is true across most Native 

communities, but affordability is a huge issue. The lack of financial education 

and the utilization of banking relationships amongst our population is lower 

than what we would like to see. If you just look at numbers, sometimes you'll 

see that someone may have an account, they may have a banking relationship, 

but they're still utilizing fringe services, which makes it difficult whenever it 

comes time to qualify for a loan. A lot of Native Americans are entrepreneurs. 

They might not call themselves business owners, they might not call themselves 

entrepreneurs, but they've got side hustles, they've got things they're doing on 

the side to earn income. Sometimes that income goes unreported, which again, 

then is a barrier when you want to go to a mainstream financial institution to 

obtain financing. Just this stock, affordability of housing stock is, it's just not 

there. I was talking to someone yesterday and I hadn't realized it, but Oklahoma 

needs 70,000 units, affordable units for individuals. These people need housing 

that they can afford. That is first and foremost. And then the second layer of 

that is people who are in homes, are in homes that oftentimes need a lot of 

rehabilitation. That is expensive. And while Tribes do receive funding from HUD 

or through the NAHASDA program, the sheer number of people needing 

significant repairs to their homes is just overwhelming. So I would love to see 

some more matched savings programs, individual development account 

programs for those people who, they can't wait on the Tribe to be able to take 

care of those non-emergent items. IDAs are a little tricky because sometimes we 

limit those based on income, and those are the individuals who typically 

struggle to meet day-to-day needs. So, I would say affordable housing stock and 

the rehabilitation of existing homes. 

Joshua Stallings: Robert, do you have anything? 

Robert Fightmaster: Sure. This is a topic that you hear for years. I did a little research trying to find 

some information on some of the things we're talking about at this roundtable. 

And I found a study that talked about the exact things that Shay's saying from 

2015. So this is not a new topic by all means, but I think it's been magnified 

recently over the increased values that we have. Oklahoma somehow got on a 

list of the most affordable places to buy an investment property in the country. 

So if you're trying to buy your first home and you have limited assets, you're not 

only competing with other first time home buyers now here, you're competing 

with investors that include people from Wall Street. So if you are a seller, are 

you going to take the cash offer from an investor or are you going to have an 

FHA appraisal done on a 184 program or traditional FHA, so they can get down 

payment assistance program and worry about is it gonna appraise for enough, 

are there gonna be repair? So there's really not a lot of opportunities for Tribal 

members to buy a house if they're going up against those people. Another thing 

that we have talked about somewhat is when we have these down payment 

assistance programs, they're wonderful. We've helped a lot of people get into 

houses, but the limits on those incomes is like 80% of the median income. If you 
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take that, you can really only qualify for about $180,000 house if you have 

another debt because rates have went up. So you can't, where you gonna find a 

house for $150,000 anymore in the metro in Oklahoma City? You're not. So, 

that's something that we could probably talk about and consider on, is there an 

opportunity to raise those limits on some of these down payment programs to a 

hundred percent of the median income instead of 80% might grant these folks 

an opportunity to afford something. 

Joshua Stallings: Valerie.

Valerie Powell: Yes, I would definitely echo that. Affordability is the big part of it. We've got to 

figure out a way to make the homes more affordable. Whether it is more 

funding for down payment, whether it is help with buy down of interest rates, 

because the costs are just too much for the, especially low-income families. But 

also echoing what Shay said, was the self-employed borrowers is almost 

impossible to get qualified for a home loan. You have to just layer on different 

programs that are available to them to make it happen for them. So, that is a 

huge need to address what can we do for those self-employed borrowers. 

Rehab is a big need. Our homes are in such dire need and we need programs to 

be able to come in. Whether, I'd love to see even a match. I mean, you wanna 

think boldly and what can we do? Tribes are willing to help their Tribal members 

and there's different organizations willing to help if we can match and so that 

greater funds are available. 'Cause it's gonna take a lot more funds than just a 

typical $5,000 or $10,000. It's gonna take more. One thing we've even talked 

about, because some of these homes aren't even able to be fixed, what can we 

do in that circumstance? And that is, tear 'em down and build something else. 

And that could be a modular home or something that can be more affordable. 

Those are just some of those really unmet needs. 

Joshua Stallings: So, Holly. 

Holly Johnson: Well, I don't think I have any specific data on this question. I would just

reference, excuse me, there was a national housing needs assessment that was 

done by HUD, you might have been referencing it, I think it was in 2017. But I 

would just encourage FHFA to find that study and read it because although it is 

five years old, I think the content will still be very relevant. And in addition to 

just the state of housing in this current economy with the rising rates and 

material cost and you know, like they said, it's just the monies that we have are 

not going nearly as far. And the HUD, Indian Housing Block Grant has been 

critical to address Indian housing, but it doesn't go far enough. But I wish we 

could look at that as a source of leverageable capital, so we could, you know, 

like you said, this concept of layered funding, it should be used in conjunction 

with more mainstream housing finance and other grants and programs. And I 

think that our programs at the Federal Home Loan Bank should be more visible 

among those and we should be a strategic partner, and look for ways to be 

helpful in just meeting the immense needs. 
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Joshua Stallings: Jason. 

Jason Brower: Well, I just wanted to kind of, I was listening to Valerie and Robert, they said a 

couple of things that made me think there's some, from a small community 

areas, rural areas, there's a lot of smaller community banks. And I feel like this is 

an area where we could come in handy because that's my of expertise, small 

community banks, but so we're talking about loans that would stay on the books 

that wouldn't be sold off. With that means when we're talking about affordable 

housing, there's just some loans that we can do in our area that's gonna be, let's 

just say under the hundred thousand mark. The down payment assistance 

programs would come in really handy because then community banks could 

take on the risk, keep it on their books, whereas mortgage brokers who are 

selling the loan off, it wouldn't be as profitable for them. So, that's something 

that community banks could help out with. I like the idea of what, I think Shay 

and both Robert said this, the median income. If we could take that and make it 

we're qualifying for loans, that's gonna be a little bit easier for us in the smaller 

areas because if we could just think, I think you'd said it earlier, if we could just 

do 80% of the national or a hundred percent of the median income, because in 

my county the median income is very low compared to Oklahoma City. So 

making some changes on that, even in rural areas would help out a lot for 

getting people into homes. I've seen it where it's been very helpful for the down 

payment assistance programs to come in. That gives them a down payment. The 

community bank can come in and help make the loan and therefore we could 

keep it on the books and not sell it off. 

Robert Fightmaster: Jason, you make the point about income, we talk about this all the time. If 

you're trying to go through the Federal Home Loan Bank or OHFA or any of 

these down payment assistance programs, the standard limit in Oklahoma City's 

been for a family of three is $58,000. You have two teachers, they don't qualify. 

So, how long is it gonna take two teachers to save up $15,000 to buy a house, or 

$5,000 for their closing costs, et cetera. $58,000 isn't much for a family of three. 

It's really not. And that's the issue that you run into a lot, is they just missed it. 

Joshua Stallings: Gene. Or Sharon, it looked like you were about to say something. I'm gonna 

jump to you. 

Sharon Wise: I was just gonna state that OHFA did a market study for the state of Oklahoma. 

You can access it through there for the housing needs. We reference that 

whenever we apply, most of the funding for my organization comes through 

Oklahoma Housing Finance Agency and the federal program is the HOME 

Partnership Investment Program. And we build homes and give down payment 

assistance. I've had, it's a different market now. We've had home buyers close in 

March at three and a half percent, and last month they closed at five and a half 

percent. And we paid additional point or fees to get their rate down to that 

amount, so it's very critical now. And there's a shortage of housing also that's 

been going up along with the rates. So it's just going to cause very, well, the 
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market's gonna be where we don't have as many home buyers and home 

ownership. I know that underwriting and in Oklahoma we don't have 

reservations, so our people compete with the regular population and investors, 

as Robert said, for the properties that they bid on. So I just would like to 

reinforce that it's cost. And the only thing to bring down cost is the down 

payment assistance. And our organization had to increase our down payment 

assistance up to a hundred thousand dollars and it's on a worksheet to get their 

top ratio to 25%. Because 25% with 5% for utilities gets you at a 30% housing. 

And HUD interprets anything over 30% to be a barrier for affordable housing.

Joshua Stallings: Gene. 

Gene Watson: Yeah, I would echo, thanks for calling on me last, by the way. I would echo 

everything that my fellow panelists have said. And I think maybe a little unique 

perspective from us. We do land in 49 states, so I know we're talking about local 

issues, but the same issues are across the country for sure. That entry point for 

that first time home buyer or that low to moderate income, even LMI income, 

borrower, they've been driven outta the market over the last 18 months. We've 

had people that have been pre-qualified on 184 loans in multiple states 

throughout the United States that their offers aren't even accepted. The 

realtors will not put 'em in a car and go show 'em a house because the sellers 

will not accept anything but a cash offer or a conventional financing with 20% 

down, right? And it's a real phenomenon. And so, I don't know if there's 

anything from a legislative standpoint that can be done on that, some type of 

anti steering approach to that. But there's just something fundamentally wrong 

with disenfranchising government borrowers. These are qualified borrowers 

that are pre-approved, they can buy the house, they can afford the house. 

They're trying to make an offer on a house, and they can't even get in a car and 

go look at the house, so there's something fundamentally wrong with that. And 

that's happening all across the nation. Just starting to see it ease up a little bit in 

Oklahoma now. I don't know if the other lenders are as well, but we're starting 

to see our folks that have been pre-approved for a couple years now all of a 

sudden they're able to go look at homes and present offers, so that's a real 

problem. I would also say across the country, we're blessed here in Oklahoma 

with community bankers that understand Indian country and do a wonderful job 

with Robert and Jason and my bank, we've done a wonderful job and this is 

Indian country, right? But in other states there's not, especially the more rural 

states that local lending doesn't exist, okay? And we have developed, over the 

last 20 years, we've really focused on developing a network of those local 

lenders across the United States, especially in some of those more rural areas 

and trying to provide coaching and assistance and to provide that safety net 

from a compliance standpoint for local community banks and credit unions. But 

what we find oftentimes for every one banker or credit union president that's 

willing to take on the, what I call the burden of mortgage lending, right? That 

compliance burden. There's a hundred that say we don't, we can't risk it, we just 
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can't risk it. This process is too much, it's too burdensome. The bar is set too 

high for our, we would like to help, right? But we just can't meet the regulatory 

burden. So, one thing that occurred to me that, that I think is an idea that I 

would like to float is that the PPP plan when the nation was shutting down and 

we decided from a national standpoint we needed to save as many jobs as 

possible. And the funding went out to the banks and the banks were reassured, 

okay, by all the regulators, you have a safe harbor, get this money in the streets. 

It's important to get this money into business owners’ hands and keep people 

working for the next three months, six months, and that program progressed. 

And bankers and credit union presidents, we’re conservative by nature, right? 

And so, we like to do things within a compliant nature. And really that PPP there 

were, the bar was very low to get the money into the streets. And I think the 

lending institutions across the United States did a wonderful job, and they got 

that money in the streets. Was it the right thing to do or not? I don't know that's 

not for-- but the process worked. And lenders by and large stepped up because 

they knew they had the safe harbor, right? That you're not gonna come back 

and there's not gonna be these big hurdles, there's no risk involved with. It was 

literally a risk free loan, and we were able to deploy that capital where it was 

needed in a very quick manner. I think the same approach could happen in 

Indian country for smaller lenders that were maybe under a certain asset level, 

right? If the regulators would consider providing a safe harbor with all of the 

alphabet soup of regulations that you have to adhere to with mortgage lending, 

if they just were provided the safe harbor. There are institutions out there 

already, like my bank and other banks that, and the Federal Home Loan Bank 

that provide a secondary market to do with those loans if they don't have the 

liquidity or the capital to hold 'em on the books like some of the banks here do, 

but would need to sell 'em off. If they could just be provided that safe harbor, I 

think you'd have very willing participants. But the biggest barrier that we have 

to bringing more local lenders into the market is just that fear and the 

regulatory burden. 

Joshua Stallings: Yeah. And so, thank you. And so I know that Sharon, you had mentioned a little 

bit of this, in Oklahoma, the land ownership issues are a little bit different. But 

Gene, with your more national reach, what are you seeing as some issues 

potentially in the land collateral ownership arena that are kind of unique to

you? 

Gene Watson: Sure, you know, Tribal trust lands and leasehold lands. I say it's getting better. It 

is getting better, but it's not good, right? The TSR prospect. So obviously if 

you're a banker, you wanna do a mortgage, you wanna make a loan to 

somebody you can take the collateral, you file your mortgage. And if the 

mortgage goes south, that's your collateral. On Native lands, that's not an 

option, right? So there has to be some type of tri-party agreement with the 184 

and the Title VI Program, the HUD programs. They've gotten an agreement with 

the Office of Native American Programs, the BIA, the local Tribes. And as a 
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lender, I can go in and I can loan. And my guarantor, ONAP, Office of Native 

American Programs says, we're gonna guarantee this loan, you don't have to 

fund the mortgage. If the mortgage goes into foreclosure and gets past due, I 

just file a claim with ONAP, right? And they pay me my claim, I'm paid off and I 

go about. And then government to government between the BIA, Office of 

Native American Programs and the Tribes, they reconcile the foreclosure 

process. Oftentimes the Tribes take 'em back. But these are sovereign nations, 

right? They all have their own different processes and ways about doing that. 

But as a lender, that allows me to step in to do that. But that's one unique 

product, right? That 184 product. And it works well on Tribal lands. I don't think 

any other product works as well on Tribal lands as the 184. But if there were a 

way to do that, there's definitely a need. 

Joshua Stallings: And everybody remember, if you want to speak, just turn it to the side. 

Robert Fightmaster: That's how you do that. 

Joshua Stallings: Don't tempt me. You have something to say? All right. 

Robert Fightmaster: I do. So Gene's got a lot more experience on the 184 front, but that we are, 

Holly talking about the same study, it was published in 2017, the data's off of 

2015. We hosted an economic summit a couple of weeks ago. And there were 

some Tribal members in from some of the northern Tribes and they were talking 

about being able to loan on Tribal land. And so, in this study there were only 

seven Tribal trust loans done in Oklahoma on the 184 program in 2015, but 

there was like 200 in Wisconsin. So one of the things that they were talking 

about when we were at this summit a few weeks back was the appreciation if 

you have a loan on Tribal land that you got through 184 program, the only 

option to sell it is to somebody who's doing a 184 program and it's probably 

gonna keep your property value down. So if we could do these loans on 

conventional, we would open it up for a lot more homeowners to be able to buy 

a property that's in a Tribal trust or that's on a reservation or someplace like 

that, that don't want to do a 184 loan. And I think that would actually grow 

some wealth in Tribal country. So I think that our Tribe is also looking at doing a 

development on Tribal trust. And that's one of the things they've asked me to 

look into is can we find somebody to buy these on the secondary market that's 

not a 184 program. 

Jason Brower: Well, I was thinking when Gene was speaking about some of just the regulatory 

burdens, especially for smaller community banks, you mentioned it. Some 

people just wanna stay away from 'em there. It takes a lot of paperwork. And as 

one mortgage broker told me they didn't like to do loans in our area because if 

the house, you know, you're making a house loan that's a hundred thousand or 

let's just go 80,000, it is easier for a banker to make an $80,000 truck loan than 

it is an $80,000 house loan because there's just so much regulatory burden and 

paperwork that goes along with it, and it makes it so hard, so therefore the fees 

just keep increasing. I was reading on somebody's notes, administrative fees just 
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to do a loan is just keeps going up and up because it takes so long. So, that's a 

really good point. Smaller banks could participate in doing Tribal loans or even 

loans, but for houses, if there wasn't so much burden and stress and risk of 

doing something wrong. And so, I don't know how long it takes to sell one off in 

the secondary market now from start to finish. Is it taking you 45 or 60 days? 

Robert Fightmaster: You know, going through the whole process? Yes, if you go from application 

date to closing. But actually getting 'em purchased, most of them have caught 

up and we’re selling those within a week. 

Jason Brower: And so I mean, but the point is, you know, you can spend that much time 

making a real estate loan or you can spend 20 minutes making a car loan for a 

house. So, taking that and making it a little bit easier helps too 'cause it can help 

get that stuff figured. Y'all made some really good points. I like those. 

Gene Watson: Yeah, we just said what compounds a problem with when you don't have that 

local lender, right? That that borrower can go in and sit down and get eyeball to 

eyeball with. We certainly haven't, we lend in 48 states, we have an application 

online. That person can do a loan with us right here in Oklahoma City and we 

can literally do a loan and talk with them on the phone a couple times and do 

everything else. But not everybody is comfortable doing that, right? And not 

everybody has the wherewithal to walk 'em through that. And there's a certain 

amount of coaching and a certain amount of handholding with some 

communities and some borrowers that needs to happen, and that happens best 

locally. It just works better locally. We've had great success actually with 

different housing authorities throughout the nations where they've actually 

decided we are gonna become the lender because we don't have local lenders. 

We are gonna become the lender. And our bank's been able to go in and help 

facilitate that, and other banks have done that as well. And that just works. But 

local's always better. It is just better. So, it's the only thing I had to add. 

Sharon Wise: I know in 1997, the Federal Home Loan Bank, they now recognize TDHEs to be 

nonmember borrowers, so they could access CHP funds, which would help them 

create their own mortgage pool of loans and put in the NAHASDA funds to 

leverage or any other funds for the risk factor. Has that taken place? I mean, 

we're talking a lot of years gone by. 

Joshua Stallings: I can neither confirm nor deny. Yeah, I'm not really participating in the 

discussion today but I like to take questions. But if you wanna talk more about 

the idea, open to it. 

Sharon Wise: A non-member borrower, you could, if your TDHE became a non-member 

borrower of the Federal Home Loan Bank, which Holly probably knows more 

about this than I do, they could actually borrow funds at different maturity rates 

and interest rates and create their own mortgage pool to loan to their Tribal 

members or whomever they set their policies for. And I know it takes capacity 

and some of the smaller Tribes do not have the capacity, but I think even a 
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partnership under maybe this program with even a member bank to draw down 

CHP funds, community housing program, I believe is what that acronym, that 

they could create the, because you hear, we need a product, that what we have 

now doesn't meet our needs basically. So knowing your needs, create that 

product and it is gonna cost some money for risk because the Federal Home 

Loan Bank doesn't operate risk-free. I mean, they don't wanna be, the Tribe 

would have to put that in, but I think it would be a wonderful way to create 

lending products in your community. 

Valerie Powell: Yes, if I wanted to create something, that was one of my bullet points is that's 

what we would like to at our housing, whether allow housing or housing 

authority or we do have a CDFI. And if that's available, maybe we needed it 

marketed to us or to know that, because I think a lot of the Tribes have that,

one, the capability to facilitate those type of programs. I think we would really 

like to, and I made the notes of allowing some of that risk. Again, you need to 

monitor that and allow that. Allow the regulations and the risk that goes with 

that. You're dealing with the Tribes. We are capable and we already have grants 

that, we're capable to lend those funds and monitor those funds, and regulate 

those funds, so that would be a huge advantage to working with those Tribes.

Joshua Stallings: Shay. 

Shay Stanfill: Well, I'm just gonna echo everything they've just said on that side of the room. 

But I would just say that, yeah, I mean by nature, CDFIs and Native CDFIs are 

more, they're more risk tolerant. We don't have the aversion to risk that a 

community bank, that a federal bank, that a national bank has. And so, the 

Federal Home Loan Bank could provide additional support to CDFIs, specifically 

Native CDFIs who are more risk tolerant, who do have the ability to, as Gene 

said, we eyeball to eyeball with most of these individuals. I know some of them 

operate on national levels, but typically their Native CDFIs are serving people in 

their community and they are more risk averse. There's a cultural understanding 

there with those individuals utilizing their programs. And in that case, you're

talking about more than just purchasing at home. In most cases, you're talking 

about other consumer lending products, other affordable vehicle loans, 

affordable rehabilitation loans, affordable commercial lending, but you're also 

usually getting some handholding. You're usually getting some coaching, some 

technical assistance to those entrepreneurs, to those aspiring entrepreneurs. 

And so, even if the Federal Home Loan Bank specifically can't take on more risk, 

the CDFIs and the Native CDFIs can. 

Eric Howard: Shay, can you follow-up on that? What does that look like? I mean, how, how 

does a bank, how would the bank take that on? I mean, where does that risk 

go? 

Shay Stanfill: Well, the CDFIs and the Native CDFIs take that risk. 
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Eric Howard: Does the bank take more collateral from the CDFI to cover that risk? Or how 

does that risk tolerance work? 

Shay Stanfill: I'm honestly not sure. I don't know the answer to that question. As I said earlier, 

I'm very loosely affiliated with the Federal Home Loan Bank system through 

ONAC. And that association is through a down payment assistance program. But 

I can just tell you that I do have experience in a Native CDFI, I worked with one 

for close to 20 years, the Cherokee Nation Economic Development Trust 

Authority. They have a lot of support from the Cherokee Nation government 

and then obviously the US Department of Treasury, but constantly looking for 

opportunities to provide affordable lending products and operational support 

for those institutions. 

Joshua Stallings: Gene then Holly. 

Gene Watson: I can share with the panel a program that we worked with, with the Cherokee 

Nation at the Housing Authority in a scenario that did work, I don't know if it 

ties to how it would work for the Federal Home Loan Bank, but we were 

awarded, I think a NACA grant if I remember right. But we were able to provide 

down payment assistance to Cherokee Tribal members that were wanting to 

build a new house, right? So the housing authority came up with, I believe, do 

you remember, Shay, five or six different models of houses on that program 

and- -

Shay Stanfill: Different bedroom sizes. 

Gene Watson: Yeah. Right. And based on the need, the borrower, the Tribal citizen donated an 

acre of land. We as a bank, we provided $10,000 down payment assistance, the 

housing authority matched that, so we had $20,000 down. We then, the nation 

contracted with, I believe other Cherokee contractors, but they built the houses, 

right? So, it was quite an economic stimulus. They built the house, we made the 

loan to the housing authority, okay? On a 30-year fixed rate loan. And the 

borrower deeded over the acre of land to the nation. And it was a rent-to-own 

program, right? So at any point during that 30 years, if the borrower wanted to 

assume that loan, pay that loan off, they could do that. The 184 product's a 

qualifying assumable loan. Lots of borrowers have done that. If they built up 

equity and they wanted to take out a second lien or do certain things if they 

wanted to, within their program, they wanted to pass it down to their heirs, 

they were able to do that. But the end of 30 years, when the loan was paid off, 

it was deeded back over to the homeowner. So that was a program to where, 

because of the down payment assistance, it kept the loan amount low enough

that the rent was affordable. And we've literally, that's just one program that 

we, and I tell you that worked overwhelmingly, we're still wrapping up a few of 

those I think. But we built over 800 homes in Cherokee country in the, is it 14 

counties? 

Shay Stanfill: 14 counties. 
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Gene Watson: Built over 800 homes. The bank, we provided $83 million in capital and 

$660,000 in down payment assistance, which was matched by the Tribe. But it 

was a way to leverage those things and really do a really big program. We've 

done similar type projects across the nations with lots of different Tribes and 

lots of different TDHEs, and housing authorities. But the single common 

denominator that makes it work is down payment assistance every time. Every 

time we put this program together at a TDHE or a Tribe or a housing authority 

across the nation, there's always a substantial down payment assistance

qualifier for it. And I would say that, you know, the banks, we play a role in that, 

right? How can we, you know, there are times that, you know, as a lender we, 

you know, we also do a thousand dollar voucher, but when we can participate 

with the down payment assistance along with the Tribe or the housing authority 

or the TDHE, it just works, right? So whatever conclusions you can draw from 

that for the Federal Home Loan Bank, I don't know. But that program worked 

really well, and it's been copied across the nation to great success. 

Shay Stanfill: I would just say, I would completely agree. And we're actually still operating that 

program. We're not getting the $10,000 down payment from CCB right now. But 

that program, it does work. It's a lease-to-own program. It is an affordable 

housing opportunity. And we're still going strong with it. 

Gene Watson: Yeah, that's outstanding. 

Joshua Stallings: Holly, then Robert, and then we'll move on. 

Holly Johnson: Well, and that's very exciting. I think that's what it's gonna take is that 

innovation and partnering and layered funding, and different sources to make 

something work. And that's where I think that the Federal Home Loan Bank 

could be that missing piece of the puzzle sometimes that makes something 

viable, that wasn't before. But I just wanted to lend support to what Shay talked 

about on it, 'cause I do believe that lending to Native CDFIs may represent an 

untapped opportunity. Like you said, many Native CDFIs have strong balance 

sheets and a track record of success with clients that banks have difficulty 

serving. And I think that the FHLBs could learn more about the CDFIs and how 

they manage risk and account for risk. And I think that the CDFIs also need to 

learn more about the system and the way our model works and try to support 

their needs in addition to the traditional products and services that we provide. 

Perhaps we could offer some kind of specific technical assistance for Native

CDFIs. Because I do believe that with an increase in number of the Native CDFIs, 

that represents increasing financial access for Native community residents in 

the short and long term. And I'm just wondering how can we make that, how 

can we make membership and our products and rates more attainable and 

attractive to them? And I do wanna mention, I have heard the comments about 

collateral and what's not working for the CDFIs, and I think it is important to 

point out that the Federal Home Loan Banks will manage risk in direct 

accordance with agency limitations and standards. If it's ultimately the policy 
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view of the agency to relax collateral standards or haircuts, in order to permit 

expanded use of CDFIs, which I know Native and other CDFIs would welcome, 

then the agency will have to take a leading role and clearly define acceptable 

risk and standards or direct Congress to do so. So, I hope that is something that 

can at least be considered. But having acknowledged that reality, the Native

CDFIs with sufficient loan capital could help address the on reservation lending 

market. They have more expertise to work in Native communities, and it may be 

a reasonable step from there for them to develop expertise in the full range of 

Indian land and mortgage options. And then before we leave the reservation 

and trust land topic, I just wanted to say that obviously we all acknowledge 

there are challenges that come with collateralizing trust land and the sovereign 

status of Tribes. Tribes are very aware of this and they will have different views 

on the subject. But what I will say is that Tribal governments understand the 

uncertainty that restricted lands and sovereign status can present and are more 

than willing to come to mutual terms for the benefit of the citizens that they 

serve. Many Tribes have already instituted specific business frameworks to 

minimize risk to lenders. And I talk about Tribal uniform commercial codes and 

such or maybe a different entity, a business entity that's not a sovereign entity. 

But you said bold ideas. And I'm speaking more to our program, but if it 

required a real estate retention agreement of some kind, if they would even still 

be required, are there exceptions that can be made for trust land or could some 

other type of agreement take its place? And also recognizing the value of trust 

assets. We could help facilitate development of trust land through alternative 

means of valuation and collateralization. Tribes have financial resources such as 

third party health care reimbursements, we have NAHASDA monies, we have 

gaming revenues, we have other Tribal income sources that could be used to 

secure loans as well, so thank you. 

Robert Fightmaster: So, we're talking about the CDFI aspect. I learned last week that CDFIs could 

become members of the Federal Home Loan Bank, right? I had no idea. I always 

thought it was just banks and credit unions. And so in talking to some folks, I 

found that out. But there's also the mortgage expertise that you need to be able 

to underwrite your own loans and make sure that they're disclosed properly. So 

it'd be interesting to see in this group if we could come up with a collaboration 

where we could work together for some of our institutions that actually do 

mortgage already, that we could maybe offer those kind of servicing to a CDFI 

who is starting to get into it and maybe isn't ready to commit the resources to 

hiring all these people, so we would certainly be open to those kind of 

discussions. You mentioned the risk. Federal Home Loan Bank System is a 

system of what is your risk tolerance? To make it in simple terms, we guarantee 

part of every loan we do based upon risk factors with the Federal Home Loan 

Bank. If I'm doing a 70% loan to value on an 800 credit score, I may not have to 

guarantee any of that loan. But if I'm doing a 95% on a 620, I may have to 

guarantee more than the bank would and we would probably want to sell that 

to another investor who didn't ask us to guarantee any of that loan. So if a CDFI 
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has more risk, the Federal Home Loan Bank actually would be a really, really 

good option for them if they are okay with a higher risk. 

Joshua Stallings: Okay. So, we're going to move forward to a slightly different topic. So I'd like to 

just, and Holly, I'm gonna come back to you and in your position, I'm not gonna 

ask you to speak for the system, but in your view, could you give us a view of 

what you think the role of the Federal Home Bank System currently is in 

supporting the Native American communities? 

Holly Johnson: Certainly. And I hope everyone had a chance to read about the specific 

programs that I'm referencing 'cause there's acronyms and I'm not even sure I 

would get 'em right, but our AHP, CIP and CICA programs. CICA is a special 

advance program. I know CIP is community investment program. And then the 

AHP is where, we've talked about some of the programs that fall under that. 

They're all very, and I think equally important and have been successful in 

addressing increasing affordable housing needs and community investment. 

Obviously, Tribes and Native Americans are not excluded from those and can 

participate. And the AHP General Fund does address many of the identified 

Native American housing needs, such as homeowner repairs. We've talked 

about down payment assistance, closing cost assistance, rental rehab, rental 

and other housing developments. However, I would say to address the need 

more directly, the FHLBs could target it through the adoption of one or more 

AHP General Fund scoring criterion, or by creating an AHP targeted fund 

specifically for Native American housing on Tribal and non-Tribal lands, such as 

through the Homeownership Set-aside Program, the HSP. Another avenue 

would be one or more voluntary programs, which I believe could be the best 

place for innovation, which we've talked about needing. And then I also think 

it's important, as Gene referenced, working with, you know, these are programs 

that are designed and implemented by the individual banks working with their 

local lenders because they better understand the needs of their Tribal 

communities and can support their traditional values. And then I also think with 

innovation, it will come with trial and error, but we shouldn't be afraid to make 

some mistakes. And I hope there'll be support for the banks and their ability to 

retool and make adjustments, if we're not meeting prescribed targets and goals. 

But back to the question, I think the role of the system is much needed and we 

could play a bigger role. I referenced that housing study, and it's just, even 

though gains are made, it's never enough. And I would like to see us prescribe 

something specifically for Tribes, so they don't have such a hard time competing 

to get these necessary funds. 

Sharon Wise: I have a little bit of CDFI experience from years ago. I helped OFR get their 

certification and such. One way that I can see that the Federal Home Loan Bank 

could be of assistance and with a CDFI that's going to the Treasury for funds. A 

lot of times they ask for matching funds and it can't be federal funds. Well, they 

don't consider in a lot of the federal programs, your funds as federal funds. I 

know under the programs I use through HUD, the Federal Home Loan Bank is 
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not considered matching funds and we can use that for match. So, I think it 

would be something that plays real well with a CDFI because as I remember, and 

Shay you might have to correct me on this because I'm old, and it's been a 

while. A lot of times when you go after funds with the Treasury, whatever your 

match is reflects how you get the funds. If you borrow your match, then your 

Treasury is a loan because your matching funds were a loan. But if you had grant 

funds, then it could be that. But regardless of the Federal Home Loan Bank 

funds are not considered federal in the match and would greatly increase their 

ability to go in for funds. 

Joshua Stallings: So, Gene, are there any factors that you think are preventing the Federal Home 

Banks from playing a larger role? 

Gene Watson: That would prevent? No, I can't think of anything that would prevent it. 

Joshua Stallings: To the point. So, Sharon, are there any administrative bureaucratic challenges 

you think that could be resolved that could help allow the Federal Home Loan 

Banks to play a bigger role? 

Sharon Wise: Well, absolutely. There's always-- taking away barriers is a good thing. And I 

guess, that has to be a discussion between those entities that are seeking funds 

as such. I guess just maybe working on formulating programs or products that 

could share the risk then let the Tribes do that to have the programs. And then 

the CDFIs, if they could have the match funds that they need for their federal 

programs, that would be. And really that isn't taking down a lot of barriers or 

regulation that you have already. 

Gene Watson: I changed my mind. With rising interest rates and rising home costs, I think, 

evaluating the formula for the income qualifier would merit consideration. So, is 

that a barrier? Yes. I think it's a barrier for a lot of people that, these gentlemen 

talked, nearly miss, right? How frustrating is that? It's just a near miss, right? 

Joshua Stallings: Yeah. So, Jason, you have any thoughts related to the Federal Home Bank 

System as it currently stands and the general awareness of what they do?

Jason Brower: So am I supposed to ask that question, like what does the Federal Home Loan 

Bank do? Can the Federal Home, maybe y'all can answer this question, will they, 

when we were talking earlier, you'd mentioned like how the PPP loans went out 

and banks were able to just get the money on the streets, so to speak. So if we 

change some regulatory burdens up, would the Federal Home Loan Bank insure 

some of those loans, like, take some of the heat, say 80% of it, 20, something 

like that? I don't know. I mean, do they do things like that, the Federal Home 

Loan Bank? So as a bank, if you wanted to carry the loan on the books and not 

sell it off, would they take on some of the risk? I don't know. Does anybody 

know? 

Robert Fightmaster: I mean, they don't currently, I mean, they sort of do. I mean, you're doing the 

loan, you're underwriting into Fannie Mae, Freddie standards or you can do 
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manual underwriting and things of that nature. So, they ask you to share in the 

risk, but the Federal Home Loan Bank is taking the bigger part of that risk. Our 

risk when we sell one to the Federal Home Loan Bank is probably limited to 10% 

on one that's kind of marginal. And most of the time they only ask us to share in 

that risk of a three to 5%, so you're kind of flipping it. They take the bigger risk 

when you sell into the program, so that's what they kind of already do. Versus 

you sell it to Fannie and Freddie, the only risk is, is that there's fraud in the file. 

This has some risk if foreclosure in the household for less, you might have to 

write a check, but they've got a program in place that you kind of have reserve 

funds that you can tap into before you actually have to take it out of your bank's 

pocket. So, it's set up for that specific purpose. 

Joshua Stallings: Holly. 

Holly Johnson: Oh, I was just going to also say, with factors that might prevent us from playing 

a larger role. If we are to develop some kind of a targeted fund specific to 

Tribes, that would be like a lack of a well-defined objective and trying to 

streamline the processes to meet it. And in that, we've said let's not create 

another layer of complexity for Tribes. They're already dealing with different 

federal agency requirements, different funding sources, and let's aim to 

eliminate the bureaucratic red tape. And sometimes that causes smaller 

participants to just say it's not worth the trouble. And those are the ones we 

need to help probably the most. Then I think about efficiency specifically for my 

bank, Federal Home Loan Bank of Topeka, we're one of the smallest banks in 

the system with the highest concentration of Tribes. And so, we can't do it all, 

so we're gonna have to be very efficient and set targets and goals that are very 

strategically thought out because we wanna help as many Tribes as we can or 

Tribal citizens. But you know, it's a, you know, if we don't really think it out, we 

just won't meet our goals and objectives. And so, I think about that as a smaller 

bank in the system. 

Joshua Stallings: Robert. 

Robert Fightmaster: So, we talked about down payment assistance programs. You're talking about 

some targeted funds. One of the thoughts that occurred to me when we were 

kind of going through this exercise was, we all kind of remember the old bond 

programs where a county might have interest rates that are 5% when the 

standard rate's 6 or something like that. It'd be interesting to see if we could set 

up some sort of targeted funds where we could kind of attack this affordability 

where we as a bank may not make as much money on doing a loan that we sell 

to the Federal Home Loan Bank. And the Federal Home Loan Bank gets us a 

break also where we could actually say, "Hey, we're gonna, you know, today's 

rates are six and a half, we're gonna do this allotment of $20 million at five and 

a half." That could be a pretty interesting scenario to be able to roll out to 

member banks and CDFIs, et cetera. 
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Gene Watson: The Federal Home Loan Bank could act as basically the custodial lender in that 

scenario. 

Robert Fightmaster: Exactly, right. Yeah. I think that would be really a fairly easy thing to do. When 

they first rolled out the down payment assistance set-aside program to us, I 

think it had been in maybe rural areas only, and then they kind of opened it up 

to any place in the four states that the Federal Home Loan Bank serves. And we 

were all over it. We were one of the first banks that knew about it, so we got to 

do a lot of those. This would really get you back out into some rural 

communities, 'cause that's where a lot of the Tribal members are living. And if 

we're kind of talking about, you know, some of these smaller towns like 

Wetumka and Shawnee, and Anadarko. And that would be a really neat way to 

reinvest in maybe some of these communities that haven't seen dollars be 

targeted toward their communities in a long time. 

Joshua Stallings: So, Valerie, I wanna come back around to awareness of the Federal Home Bank 

System and what it does. So, do you have any thoughts related to the general 

awareness within the housing community and the work that you do of what the 

Federal Home Loan Bank is and what it does? 

Valerie Powell: I truly don't think there's enough awareness in our community of what the 

Federal Home Loan Bank does. That was one of my suggestions, is just being, 

and this is great, this is, I think gonna be very helpful, but being in our 

communities, going to our meetings. We have local meetings throughout the 

country. We have national meetings throughout the country, so I think coming 

to those on a regular basis and keeping up to date with what Indian countries 

are doing and letting us know what you are doing would be tremendous help. 

Joshua Stallings: And, Shay do you have any thoughts on what could potentially be impediments 

for housing associations or the like to engage with the Federal Home bank 

system? 

Shay Stanfill: Well, I would echo what Valerie said, and I would agree that maybe we aren't 

quite informed enough about exactly what the Federal Home Loan Bank System 

is doing already. So, we definitely would welcome just information sharing. Even 

if it's not something that we can take advantage of ,being able to refer other 

organizations or other people to Federal Home Loan Bank systems would be 

very helpful. Most of the time for the Cherokee Nation, we're serving people 

only within our reservation, but we often get requests from individuals outside 

of our area and we are oftentimes Googling, you know, trying to figure out who 

can we refer these individuals to. So just more awareness about what the 

Federal Home Loan Banking system is doing, who's out there, what kind of 

assistance is offered would be great. I don't think this has come up yet today. I 

think I saw it in some of the written responses that were submitted earlier, but I 

would also agree that we would love for the Federal Home Loan Bank system to 

consider the Native American population as a special population. Sorry about 

that. That would be helpful. And then I think Gene touched on this earlier, but 
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the real estate, what is it, the real estate retention agreement cannot, that the 

Federal Home Loan Bank system is currently using, cannot be used on trust or 

restricted land. And maybe Holly mentioned something about can we revise it 

or can we just do away with it? That would be great. Either one of those things. 

Joshua Stallings: Okay. So, Sharon, any thoughts on programs that currently exist within the 

framework of the Federal Home Loan Bank System that are beneficial in the 

Native community? 

Sharon Wise: Well, I mentioned the CHP for community housing program. Then you had 

mentioned the CIP, I think it’s the Community Investment Program for business 

development and such. I think it would help to create a model to present to the 

Tribes, this is how you do it. Because a lot of times you have such massive 

amounts of information, and you have a whole new set of regulations. They 

have NAHASDA now, they have ICDBG regulations, and now they're gonna have 

the Federal Home Loan Bank. If you could put together the model and say, this 

is what you can do and just and this is what you need to do to get to there, and 

they have to take these ideas and present 'em to their housing boards, their 

Tribal leaders. If they could explain it and have that model, I think that would be 

great to have through that. 

Joshua Stallings: And, Valerie, I think that Sharon's kind of picking up on a point of conflicting 

requirements for different programs, so you have any thoughts on that and 

anything that the Federal Home Loan Banks would need to be thinking about in 

developing their programs? 

Valerie Powell: So conflicting with like our NAHASDA and our ICDBG, and things like that?

Joshua Stallings: All of those. 

Valerie Powell: Well, I like what all has been said all day today, is just kind of looking at those 

regulations and maybe trying to, I would say tone those down for our Native 

American communities, knowing that, like Gene had said at one point that, kind 

of making that, those regulations, he said something about safe harbor, we can 

manage that risk better in Indian country. 

Joshua Stallings: Okay. So, Gene, are there any product types that are currently offered by the 

Federal Home Loan Bank system that you think are working well or could be 

improved? 

Gene Watson: Yeah, I hear the housing authorities and the Tribal representatives here talk 

about needing more information about those programs. Bankers need it too, 

right? So I learned about programs today sitting around talking earlier, right? So 

we have largely, Chickasaw Community Bank has largely used the Federal Home 

Loan Bank for liquidity needs, right? We do a big project with a nation, and we 

need a liquidity for a period of time. And we've been able to access that and it's 

been a lifesaver, right? A lifeline at times for us. There are some of these 

projects that we could not do without the Federal Home Loan Bank and that 
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liquidity that's provided. For us it's transitory liquidity. We need it for a period of 

time, but we don't want to take on a bunch of sticky deposits. And especially 

with the cost of deposits going up and cost of funds going up. I think the 

liquidity that you provide to local banks is going to be much more in demand 

over the next 10 years than it has been over the last 10 years. But yeah, I think 

all of the programs that you offer, I know we're gonna go back and we're gonna 

task our team to investigate all those programs. And I guess maybe we fell 

victim to, it wasn't necessarily carved out as a Native program, so we just 

bypassed it. Does that make sense? So when we're looking for all of the 

different programs and grants and things that we can get any type of funding to, 

what we are really looking for is something that will allow us to provide down 

payment assistance, because that's the common denominator to every program 

that we have put together that works. So if we're going to your site and we're 

just googling up something, are you offering anything that provides down 

payment assistance to Native Americans? I suspect you're not gonna show up at 

the top of our Google search, right? Or we would've been in contact about many 

of these things. Although maybe some of your programs that you do offer, we 

could have accomplished those things. So, we've been a little derelict in our 

duty as well. 

Joshua Stallings: Okay. Well, I believe we are at a good time for a break. So let's take 25 minutes 

to let everyone rest up and we'll come back and we will turn to a couple more 

topics. But thank you all for your comments so far and we look forward to the 

continued dialogue. Thanks. 

⚫ ⚫ ⚫

Joshua Stallings: Okay. And welcome back and let's get right back at it. So this next section, I'm 

actually going to turn over to my esteemed co-host of the show today, Eric, to 

take us into the next piece. All right, Eric, go ahead. 

Eric Howard: Great. Thanks, Joshua. So what we're gonna do is take a few minutes and we're 

gonna talk about equity. So we want you to think beyond fair lending legal 

requirements, of course the banks should comply with all fair lending legal 

requirements, but we want you to think beyond that, we'd like to explore equity 

considerations that should be factored in when developing and implementing 

Federal Home Loan Bank programs and products. So, Shay, I'm gonna start with 

you. Can you talk a little bit about how the Federal Home Loan Banks have been 

doing on this front?

Shay Stanfill: Sure. I think I mentioned earlier that we would love to see Native Americans set 

aside as a special population with the Federal Home Loan bank system. The 

Oklahoma Native Assets Coalition is a recipient of a Federal Home Loan Bank 

grant, which we are very appreciative of. We're able to provide some down 
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payment assistance to Native Americans. But the caveat to that is the Oklahoma 

Native Assets Coalition mission is specifically to serve Native Americans. The 

Federal Home Loan Bank, however, requires that we utilize that funding to 

serve all eligible applicants, so it goes against ONAC’s ultimate mission. So, if 

Native Americans were designated as a special population that would alleviate 

that issue, that kind of going against the grain of our mission, not just for ONAC, 

but for any other Native nonprofits or Tribes. 

Eric Howard: Shay, I think I remember reading in your written responses something, and if I'm 

wrong I apologize, but maybe a program or a set-aside program just for Native 

Tribes, Native populations. Is that something that you could expand upon? 

Shay Stanfill: Well, we would absolutely love that. I read that comment in someone else's 

response too, and I don't remember who it was. I'd love to take credit for it 

because I thought it was a great idea, wasn't mine. But no, it would be ideal for 

the Tribes to be able, Tribes or Native nonprofits to be able to compete for 

these funds. When we're competing against these larger banks, we're just not 

competitive sometimes, specifically smaller Tribes, they're not going to be able 

to be competitive, so we would love to be able to see a set aside specifically 

that Tribes are able to compete competitively, actually have a chance at 

obtaining some of those funds. 

Eric Howard: So what should the Federal Home Loan Banks have in place to ensure sufficient 

focus on equity considerations? So, the Federal Home Loan Banks do an annual 

needs assessment, this is called the Targeted Community Lending Plans, and 

these document market dynamics as well as significant affordable housing and 

economic developments in their districts. And they're developed in consultation 

with stakeholders. Could these plans be an opportunity to charge, excuse me, to 

charge the banks to specifically discuss equity considerations for underserved 

populations in their districts? Holly, can I toss that question to you? 

Holly Johnson: Yeah, I think that's a great idea. The AHAC are sort of boots on the ground and 

we take their input very seriously in developing those plans. And there is 

representation of the Native community, but I think it sort of gets lost in all the 

other needs around affordable housing because the needs are so immense, 

right? So I think we need to be a lot more deliberate in that, especially if we 

could devise some kind of a targeted funding program or programs that maybe 

this Targeted Community Development Lending Plan would just be specific to 

Tribes. But that is the way we try to address equity and it's worked pretty well. 

It's an annual process and we encourage representatives from all the various 

stakeholders, but I do know Tribal communities are represented there. 

Eric Howard: So, Valerie, with that being said, and I know that you have experience on the 

AHAC for the bank, so could you offer any suggestions about what more needs 

to be done with respect to the targeted community lending planning process 

and Native populations? 
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Valerie Powell: Well, I think just learning more about what the specific needs are in those 

communities and how those products can be targeted specifically for those 

needs. It's getting the information from the Tribes, preparing those plans. It's 

really just educating themselves on what those needs are and getting more of 

the feedback from more Tribes, not just a few. It really needs to be a greater, 

broader participation from the Tribes for those needs. 

Eric Howard: Can I follow-up with that? So should the Federal Home Loan Banks be required 

to explicitly support or address Tribal home ownership gaps? 

Valerie Powell: Yes. Yes, I think that would be very helpful to specifically address those gaps. 

And what are those gaps and learn those gaps, yes. 

Eric Howard: Okay. So, Gene, I'm gonna throw a question to you. So in addition to Federal 

Home Loan Bank members, who are some key partners for this work and what 

should collaboration and engagement look like? 

Gene Watson: Yeah, so I think some of your programs require a bank to sponsor or support 

different programs within that. I think there does need to be a partnership 

between the Federal Home Loan Banks, the member banks, and Tribal entities. 

Whether they're housing authorities, TDHEs, CDFIs, Tribes themselves. I think 

the Federal Home Loan Bank needs to be deliberate and sensitive to the specific 

and unique needs that reside in Indian country from what's housing. There are 

some specific, and I think there are other members of this panel that can speak 

to that more specifically than I could. And it's unique sometimes within regions, 

sometimes within Tribal members, but there are also some unique needs or 

challenges in Indian country in general. So I think if the Federal Home Loan Bank 

is considering a specialized program and a deliberate program for this sector or 

this group, I think that's wise. I think that would be beneficial. But I think they 

also need to be sensitive to what makes it unique, what are the unique needs 

that might fall outside of the scopes of the programs that you already have. 

Eric Howard: So Gene, you talk a lot, not a lot, but you talked about Indian country, so when I 

hear that, I hear the Topeka Bank. So what about the other banks within the 

system? 

Gene Watson: Sure. I think all the banks within the system should consider this. I mean, I think 

there are 578 federally recognized Tribes, something in or around that number. 

I think those Tribes are active in 36 or 37 states. I think those states, if you look 

at that, would encompass probably all of the banks. Obviously there are gonna 

be concentrations in certain areas. 

Eric Howard: Sure. 

Joshua Stallings: Yeah. So, I guess, can we take a second now, you're talking about some of the 

unique needs and like focusing on some of those unique needs. So does anyone 

have a thought on what that list would entail? Like, if we're looking at this 

through the lens of equity and we wanna make sure that the unique needs are 
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being met, like what would that be with for the Tribal and Native population 

that we need to be considered? Anybody? Sharon. 

Sharon Wise: Well, in different areas it may be seasonal work that they have, you know, 

through farming or something like that. So there needs to be maybe a loan 

product that will be set up on a eight payments a year instead of 12, but it can 

still amortize out in the end. I don't think that's a big risk for a banking institute 

or for a program. Shay had mentioned, with business and not being 

sophisticated in maybe their craft that's turned into a support mechanism. But 

I'm sure that's what the CDFI is there too, to help them document that. But 

maybe to take alternate documentation for incomes and such as that. Like, we 

do need to do more with credit on alternate credit. And also I think there should 

be more, and maybe the Federal Home Loan Bank can help with credit building 

and credit building loans. I know there's a bank in Arkansas that set up a credit 

builder program for their Hispanic workers that work in a lot of the chicken 

houses and all, and they set it up like they have $2,400 and they pay that $200 a 

month. They don't get the money till it's all paid in, but they've established a 

payment history with that bank. Did the bank have any risk? No, not a dollar 

went out of their bank till all of it was paid in, and then it created a credit history 

that was reported by a financial institution. And I think there needs to be more 

programs like that for people that are in rural areas. I mean, they bank with 

their pawn shop. I mean, if they need money, they go pawn something and they 

go get it out. That's still out there, so I think there needs to be programs that 

help enforce or create that habit with that family. 

Joshua Stallings: Holly then Valerie. 

Holly Johnson: Well, I was just gonna say that some of the uniqueness may stem from the 

status of the land. But I think it's important to realize that not-- in this discussion 

about different needs in different regions and parts of the country, is not all 

Native American housing projects are on trust land. Many have state chartered 

housing authorities that are on fee simple lands, so you can't assume, you have 

to kind of take each Tribe where they're at and see what their needs are. 

Obviously economic development is gonna be done on trust land under the 

control of the reservation. But back to what Gene was saying, what we're trying 

to do is impact rural, sometimes very disconnected communities. And so when I 

think about the system, just like it's properly structured to provide access to 

credit institutions of all sizes, types, and geographies, It's also the best well 

suited to best support the unique needs of Tribes and which could be different 

in different parts of the countries and states in which they reside. 

Valerie Powell: Yeah, I think one of the unique needs is definitely the education financial part of 

it. We've always had, we've started out our programs and always had offered 

financial home buyer education, budget, credit counseling just to prepare them 

and get them ready for home ownership. And that's, I think even requiring that, 

even if it's those institutions that already have that ability to do that counseling 
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can do that. But even just having that requirement that we can, it just helps 

prepare them for home ownership. And the credit repair loans, that is 

something that we've started doing as well because they needed that help. They 

were just a little bit overwhelmed with their credit and what they need to clear 

up, and we can come in as our Tribe, our housing authority, our CDFI help them 

clear up that credit and prepare them more for home ownership as well, so that 

is a unique opportunity. 

Robert Fightmaster: So we talk again about CDFI and you're talking about credit building and such. A 

few years back, the CPN and CDFI took on the task of trying to get a lot of their 

citizens away from payday loan companies, so they attacked that with some 

signature loans and they got a lot of their folks away from that terrible turntable 

of always having to go borrow on payday, and you never get out of those, so 

that was one aspect of it. Another thing that we're doing in conjunction with our 

CDFIs, we're doing a hundred percent loans for Native Americans. We're gonna 

do the 80% first and we're gonna do the 20% second through the CDFI. And 

that's gonna be any Native borrower in Oklahoma, it does not have to be CPN. 

So, we have a little unique aspect of having a bank and also having a CDFI that 

can kind of work together. But that's something that other states could certainly 

do the same thing and work with local banks, et cetera. You can sell that first 

mortgage into the Federal Home Loan Bank program 'cause that is considered a 

community second. And so at 80% loan to value, it's a great deal. It's a lot better 

than a minimum down payment because we don't have any PMI. Another thing 

that we were talking about on the break, Sharon and I were talking about her 

program and that all our down payment assistance programs are always talking 

about that minimum amount of an investment that a client needs to get into the 

house. But they don’t really build equity. They're still having a really high 

mortgage payment, it doesn't address some of our housing needs. So, Federal 

Home Loan Bank has their down payment assistance program in there. So, Gene 

talked about the uniqueness of Native lending. Well, let's make these Native 

borrowers unique in the way we look at 'em. Give them a higher grant amount. 

Instead of $7,500, make it 15. We as a bank can only give five of those grants 

out a month. The reason for that is they don't want Bank of America coming in 

and taking out the whole amount in a month with 200 requests, so they limit us 

to five. So, let's not count Native American down payment assistance in that 5% 

cap. That's a nice solution. And then you could also consider maybe no CE 

obligation from the Federal Home Loan Bank if you're doing a loan for a Native 

American. So, there's a couple things that I kind of jotted down as we were 

discussing. 

Joshua Stallings: Okay, thank you. While we have been already talking quite a bit today about 

things that could be done or could be done better, let's turn our attention fully 

to the future of the Federal Home Loan Banks now that we've kind of walked 

ourselves through some of the concerns. So moving on to the future role of the 

Federal Home Loan Banks and their support for Native American communities. 
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Let's first explore where and how the banks can and should be playing a larger 

role. So are there any specific unmet needs that Federal Home Loan Banks are 

not currently supporting, but can or should be? And, Jason, we haven't heard 

from you in a while, you got anything on this one? 

Jason Brower: Well, I don't know if I can speak for some of the programs because I'm still 

learning everything that the Federal Home Loan Bank offers, but I think just 

sitting here today makes me realize that there are opportunities out there. And I 

think educating, I think we touched on that earlier, is educating people to know 

what is out there. That's very helpful. I've learned from Robert today that there 

are down payment programs out there that I was unaware of through the 

Federal Home Loan Bank. So, how can we help? I mean there's some things that 

Sharon touched on that with the credit needs and building credit. And I'm 

looking and I'm thinking, "Community banks fit that." They can in rural areas 

where the populations are smaller, they can do those things. They can help 

those people with those type of loans to build that credit. So, that would 

definitely be a niche. I think that the Federal Home Loan Bank could reach out to 

smaller community banks and say, "Hey, look at these things," and then that 

could help with the home buying experience. Now all of a sudden they have 

credit, but then we're, so we can work on the credit part. We can get that credit 

score up, we can do some of those things. It seems like I'm always coming back 

to the down payment. I just can't get away from that. How do we get that down 

payment in there, that equity to help them out? So, learning about new 

opportunities. So, I'm writing some of this stuff down to figure out how I can 

help out when I get back. How do we get more money? How do we get that out 

there to offer? And so of course Shay had mentioned just the special, how did 

you label that? A special people group? 

Shay Stanfill: Special population. 

Jason Brower: Special population, I'm sorry. Well, that would mean, and the way I hear that is 

that means let's give more weight to rural communities or places that have a 

higher Native population. Let's give them more weight in the grant writing 

process, so that way they can in turn give out down payment assistance. That's 

what we're looking for. How can we get these people into homes? The rent is 

going high. We're seeing that. So in our area, in our county, you can still get into 

a home and pay less for a house payment on a 15-year mortgage than you can 

for some rentals. And somebody had mentioned people from outside are 

coming in, buying up rental properties. Buying up properties and turning them 

into rental properties, so therefore the rent's going up. And it's getting hard for 

people to afford those. So, why not help in another way by giving down 

payments and maybe adjusting the program and the criteria and the weighted 

part, and how can we do that. 

Joshua Stallings: So, Valerie, any thoughts on any specific unmet needs that the Federal Home 

Loan Banks are not currently supporting but could or should? 
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Valerie Powell: Well, I mean, I feel like it's definitely a, larger grant amounts for down payments

is definitely a need. I think rehabilitation is still a great need. Those type of 

programs to do rehab, to do larger amounts of rehab are needed. I think maybe, 

you know, adjusting some of those income levels to those different, the 

nationals versus the medians and things like that would be helpful. 

Joshua Stallings: So let me, can I interject? Can you go back to the rehab point? 'Cause that's 

something we have brought up but hasn't been really talked about a lot. Can 

you talk a little bit more about that? 

Valerie Powell: So, in our area, the homes are, they just, for our low-income families, especially 

for Native American income, Native American families, they're just not able to 

upkeep the homes and they're just deteriorating. Whether it be roofs, whether 

it be just really everything. Even to keep 'em more energy efficient, if there's 

windows and all of that is a need to keep them more energy efficient. We need 

that help to help rehab those homes. And like I've said before, I mean $5,000, 

$10,000 is not enough. It needs to be larger amounts to actually rehab these 

homes to make them more safe, sound, decent, more energy efficient to lower 

total costs altogether. 

Joshua Stallings: So, Gene then Robert. 

Gene Watson: Yeah, I think rehab is a huge issue in Indian country for sure. Especially, if you 

take somebody that's if it's just low housing, low-income housing profile, we get 

'em into a house. They're buying that 70 or $80,000 house. That's typically not a 

newly constructed home unless there's a big down payment that goes with it, 

right? So, oftentimes they qualify but they barely qualify, right? I mean, and you 

get 'em in. Are we really setting people up to succeed at that point, right? So 

four or five years goes by, the air conditioner goes out, do they have $5,000 in 

disposable income? No. Now they're going back to the Tribe looking for special 

programs through the Tribes. And nearly every Tribe has those types of things. 

The banking sector has stepped in, the FHA has stepped in. We offer what's 

called an FHA 125 program loan. It's a second lien, it goes up to $25,000 and it's 

for rehab, right? And so, and we can am[ortize] that out at reasonable note 

rates. We can am[ortnize] that out up to 20 years, so that repayment, that 

payment's fixed rate, it's not adjustable rate. It's not a HELOC or anything, so it's 

a very secure loan. They qualify for it. The underwriting guidelines are standard 

FHA guidelines, right? So, that's a solution. So if the Federal Home Loan Bank, 

but the problem is in today's economy, $25,000 doesn't go very far. You're not 

gonna rehab much on a home, right? And FHA has some programs out there to 

you know, 203K and things like that, but they just miss the mark a lot of the 

times, right? Well, they require certain things. Like, FHA requires that they have 

to use a contractor, they can't do any of the work themselves. Well, that could 

be something that you could be a little flexible on, right? Why can't somebody 

paint their own home? Why can't somebody do some of the rehab? If they're a 

roofer, let 'em roof the house, right? Why do they have to go pay a contractor? 
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And so, there are hurdles and problems with these programs that do exist. And 

so, when I talk about special needs and special opportunities, rehab's a big one. 

If you looked at the underwriting guidelines, the criteria, some of the special 

needs that are in Indian country. I think you could come up with a product that 

would fit the risk profile for the Federal Home Loan Banks and supply a need, 

right? And fill a need. 

Robert Fightmaster: So, Valerie, you mentioned a couple times the different rehab programs. Are 

you saying there's a need for funding to do the rehab or more like a loan that 

they can do the rehab, like what Gene's talking about or both? –

Valerie Powell: Definitely both. Because we still have those individuals that cannot afford a 

loan, they need the grant stability. And we try to step in and help as much as we 

can, but it's, we still need more. 

Sharon Wise: Our organization contracted with the ONAP office. We ran a housing program 

for a Tribe from 2008 to 2015. And we really couldn't spend the money to gain 

new assets because they didn't want that on any of the deeds, so we did rehab. 

So we did probably around 200 rehabs, and our average rehab was just over 

$50,000. And that was 208 to 215. I can't even imagine what it would be today. 

And we used NAHASDA funds for that. So we brought them, we had a policy 

that we rehabbed them to that because it, I know some Tribes try to make their 

money go further, so they capped it like at 30,000. Well, do you get a new roof 

and then your windows leak and you don't have air conditioning, so it's tough. 

The rehab needs to be complete to be effective. 

Joshua Stallings: Shay, you have any thoughts on the expense of rehabbing at this point? 

Shay Stanfill: It's overwhelming. Rehab needs are great, they're extensive. When you talk 

about home ownership rates in Oklahoma, home ownership rates are actually 

not at the bottom of the barrel like you would expect as unfortunately we are in 

some other categories. But I always say we miss the mark when we just look at 

the home ownership rates because we're not looking at the structural 

soundness of those homes. And while the individual may have a roof over their 

head, they may have shelter from the elements, it doesn't mean they're in safe 

and affordable or sustainable housing. Rehab's just a beast. I wish I knew what 

the answer was. Matched savings accounts are, individual development 

accounts are huge. The issue with matched savings accounts is that, I think I 

mentioned this earlier, if you're looking at people in the 80% or below, 

specifically area median income, but even if you're looking at national median 

income, the people that are in that category are just trying to keep the lights on. 

They're just trying to keep the heat on. They're just trying to buy groceries. 

However, there's kind of been an evolution in the asset building field and the 

individual development account field. And over the last several years what 

we've seen is that organizations who do offer individual development accounts 

are not so much looking for regular monthly deposits that are hard to come by, 

but instead maybe being a little more flexible and hopefully this will start 
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gaining ground, but being more flexible and utilizing, letting families utilize like 

tax refunds or any kind of lump sum payments that they get throughout the 

year. Saving those for a set period of time and then matching those. The other 

thing is the match rate has to be, it's gotta be up there. It's gotta be, you know, 

just as we are talking about how expensive rehab can be, a lot of times an IDA 

program, typical match rates are anywhere from three to one to five to one. 

Well, if you're asking someone to save a thousand dollars and you're gonna give 

them $3,000, don't get me wrong, it's free money, it's great, but $4,000 

probably isn't gonna fix your roof. $4,000 probably isn't gonna fix your heat and 

air. It might fix your heat and air. You might get a bandaid, but you're not gonna 

buy the new unit. So, I think just kind of exploring individual development 

accounts with higher match rates with more flexible saving opportunities. Again, 

capitalizing on Earned Income Tax Credits, capitalizing on tax time savings for 

these individuals is key. And then if I can just plug, if we're talking about giving 

away free money, I know pie in the sky again, somebody else mentioned it and 

you said earlier be bold. We just finished piloting a matched emergency savings 

program at the Housing Authority of the Cherokee Nation in the Cherokee 

Nation. We've done one of these before several years ago with a different 

organization, but it makes a huge difference for people. We did a small match 

rate, we asked them to save $100, we matched it at five to one, so that they 

could have $500 because I can't remember right off the top of my head what 

the percentages are. But most people can't afford to cover a $400 emergency 

without borrowing money or using a credit card. And all of us know you're 

probably not even getting new tires for your car. You might get two new tires if 

you've got $400 in your savings account. So, if we can also look at ways of 

encouraging savings when we did follow up on, with some of the individuals 

who participated in this program. Just the security of having $500 in an 

emergency savings account was hugely beneficial to those individuals. We also 

like to see, if you had to use the money, what are you using it for? I know I'm 

getting way off track here, but I would just say it's helping people build an 

emergency savings account. It also would be a little bit of a buffer for home 

emergencies. It's not gonna cover a lot. But it also encourages people, it's kinda 

like a little jumpstart. It encourages people to continue saving. When they have 

to dip into that emergency savings, but there's a little bit left there. Sometimes, 

not all the time, sometimes they will continue depositing. And we will just like 

to say that these kinds of programs don't always take hold. Not everybody is 

going to keep saving after you give them a jumpstart, after they use the 

individual development account. But we like to say we're planting the seed. And 

so, sometimes the seed grows and sometimes it doesn't. But if we're asking for 

free money, I would love to look at opportunities to offer matched emergency 

savings accounts as well. 

Joshua Stallings: So, I know that we're all aware of the supply chain issues that have caused quite 

a bit of the increase in cost. I know we're talking about rehab, that's clearly 
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gonna impact a lot of that. But Sharon, can you speak to, are there any concerns 

related to the availability of people to do the work? 

Sharon Wise: Absolutely. I mean, especially in rural areas, we're fortunate enough that what 

we're building now is close to Oklahoma City. It's just outside so we do have 

contractors and subs. But still out in rural areas, I don't know how they do it to 

get construction on the ground. I mean it's such, I mean, and then you don't 

want to have the cheapest. Because if you have the cheapest, that's the worst 

product you can furnish someone. And I want everybody to focus that. We look 

at sustainable home ownership, we wanna build that house, so they're not 

gonna have bills or replacement or rehabbing just for living there in the next five 

to 10 years. We wanna construct a sound house. So, it has been a struggle for 

us. As a matter of fact, we had homes under construction during the supply 

chain and where a framing package went from $16,000 to $42,000 for our 

builders. And our builders were in contracts with us. So I actually went back 

because I never thought it was, and I'm not putting the Feds on, you know, any 

kind. But I never thought it was a purpose to use federal funds to put a private 

company outta business that they had to stick to my contract, that they would 

go belly up. So we did scratch up more money and met 'em halfway on those 

costs that went up because they were in a firm contract, but it wasn't their fault 

that the lumber went up that high and everything. So in doing that, we kept our 

good builders, that they'll build for us again. And we didn't put 'em outta 

business 'cause I know a lot of 'em did struggle through that. But I think we're 

on the mend now, from what I hear from our builders. I mean, it's still not as 

cheap as it was two years ago, but prices are, they shot up but they're floating 

down a little bit. 

Jason Brower: Well, I was listening to Sharon and I'm thinking when it goes back to something 

you said with the emergency savings. Gene, I think you helped put together a 

project maybe for one of the Tribes with building houses. And with this project, 

and you can correct me if I'm wrong or if I'm off, but I felt like when the Tribe 

would sell a home to a Tribal member, they could, they would make payments 

to it. But then after so long it's like they had, I'm just gonna use an example. So 

say they paid on it for five years and they've got, they would take and set aside 

a certain portion of money. So say they've got $5,000 saved up, they could take 

that and apply it to the loan or they could take it and use it to rehab the house. 

Is that correct? 

Gene Watson: That's correct. 

Jason Brower: That is a fascinating model to me because, and I don't think the regs would 

allow us to escrow on a conventional type loan. So right now we can escrow 

insurance and taxes, but could we also escrow in this other thing? But yet it 

would also help solve the problem of having these emergency funds that you're 

just helping somebody set aside. Whereas my experience has been if a person is 

making payments on a house, they got one payment all set up. But setting aside 
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an extra hundred dollars a month, they won't always do. But if there's some way 

we could escrow that in to help, it would solve a couple of problems, putting 

money back that also, because that is a really neat model, I think that was set up 

to do that for the Tribes. I don't know how y'all, I guess you worked with the 

Tribes to get that accomplished, but it's neat. It's really good. 

Gene Watson: Yeah. We made the loan to the Tribe, the Tribe it was at lease-to-own product, 

right? And so, the Tribe developed their own program, part of the program they 

developed, which I thought was really meaningful. 'Cause these weren't newly 

constructed homes. These were already existing homes at various conditions. 

Now, they made sure that it was a sustainable house, right? But they basically 

built up an escrow, they collected extra above that they set aside for when they 

did assume the loans, it was a five-year assumption. But at the end of that five 

years, each house had its own funds set aside. They would take into 

consideration things like, well, when you take this over, you're gonna have to 

start paying homeowner's insurance. We use AMERIND. This is very inexpensive 

for us, right, shich is a great tool for Tribes to use, right? It is a great cost savings 

on those lease to own programs. The Tribe might pay, I don't know, 25, $40 

through AMERIND for insurance to where an individual might have to pay seven, 

800, 1,200 depending on the house. But yeah, they factored in deferred 

maintenance. They factored in, insurance is going to go up. You're gonna start 

paying insurance, your taxes. You're gonna have to start paying taxes. As a Tribe

they didn't have to pay taxes. And they set up that escrow, they got them built 

and accustomed to making that payment. So when they took it over, they 

handed them an amount of money and sometimes it was 3,000, sometimes it 

was seven or 8,000 depending on what they assess those needs to be, right? 

Okay, here's your emergency fund, you're gonna start taking over the payments 

and your payments haven't changed, so there wasn't a payment shock at the 

end of that five years. But that's just the creativeness and the uniqueness that 

the different Tribes and TDHEs and organizations can do around the country. I 

get to sit in the catbird seat and see all these really cool and neat programs that 

different Tribes come up with. 

Jason Brower: But that model might be something from a Federal Home Loan Bank or even a 

Federal Reserve standpoint with policies is like how could that, something 

similar to that, be used in the banks? I mean, would they allow us to do that? 

That could help in getting houses and so forth. Which would, may take care of 

some of the emergency savings that would go into repairing houses. And so, it 

could help. Just a thought. 

Sharon Wise: Well, when you think about it, and this is sort of out there. But when someone 

buys a home, they're paying everybody else to make sure everybody else is 

gonna be okay. They're paying mortgage insurance, so the lender will be okay. 

They're paying their hazard insurance, so the lender will be okay. They're paying 

title insurance, so the lender will be okay. But there's nothing escrow to take 

care of the home buyer and what they might encounter in the ups and downs of 
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lives. If there could be some kind of escrow put, you know, and I've thought 

about this before, but it's so far out there, that is almost like an insurance 

against job loss beyond your control or emergency rehab, or something like 

that. And with the Tribes so hands-on with their programs and their Tribal 

members, to put something like that in effect, I think would be a good thing. It 

might be something to consider. 

Valerie Powell: Yeah, just to give you from our perspective, that's what we've done. We've 

started a lease purchase program and we build the homes and they lease it 

through first 15 years and at 10 year, we want them to start a hundred dollars, 

$150 in at any time, but at 10 years we require it because they're only paying 

say, $500. We're setting that so that at the end of that 15 years, now here's that 

lump sum that they can now refinance, become theirs. And at that 15 year, we 

know what that payment's gonna be through our lender, and so we kind of 

prepare 'em for that increase in payment for taxes and insurance. So we're

telling them to put in that a hundred, $150 a month extra, but that's their 

money at the end of, that 15 years that they can use now for, maybe there's 

some upgrades they want to do or maybe there's repairs or maybe there's 

furniture, anything like that. They're gonna be able to do that, and it just kind of 

teaches them. But yeah, that's what we've done. 

Jason Brower: I like the model, I like the idea, I like the way that those, that the Tribes are 

doing that. And from a lender standpoint, it's we're just trying to minimize risk. 

And I know that there's gonna be some, that's why you charge interest. But if 

there's ways that we can minimize the risk, then I think it would make it easier 

to get the funds out there. And I think that's where he was going with the PPP 

money is that, you know, lenders and community banks who can get the money 

out fast, they knew that they, or they had reassurance that they were gonna get 

paid back. And so, it was able to flow it. I mean, if we could somehow find a way 

to minimize the risk even more so that what's out there and make it, not just 

minimize it, but also help with the paperwork along the way, but to make it 

easier and less intimidating would be a good thing too. 

Joshua Stallings: So, as we're looking forward, Gene, is there anything in the multi-family space 

that you think that the Federal Home Loan Banks could be doing more to 

support the market? –

Gene Watson: When you ask me, can they do anything more. Like, I have to confess, I don't 

know what you currently do, right? I think from a Tribal standpoint, we as a 

lender do a lot of lending with multi-unit housing. It's a good model. It's good 

affordable housing, it's good safe housing. It doesn't create home ownership, it 

does create affordable housing certainly. I know you're not here to answer 

questions, you're here to ask 'em. So, I would say that that need definitely 

exists. Not everybody's ready to own a home, that's a reality. But everybody 

needs safe, quality housing, right? And so, yeah, I think having a program that 

would have some benefits to it or some advantageous aspect to it for Tribes and 
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banks to work together to do multi-unit, I think that would be welcomed with 

open arms from both sides of that fence, right? From the Tribal entities and 

from the lenders.

Joshua Stallings: So, let me reposition that. Shay, are there any friction points in the multi-family 

space that can make it hard to complete projects? 

Shay Stanfill: Well, I have to echo what Gene said and admit that I don't really know what the 

Federal Home Loan Bank is doing right now. But as far as friction points go, kind 

of what we were talking about earlier in regards to contractors and the 

availability of supplies. I mean that is a huge issue we're facing right now. We're 

actually the Housing Authority of the Cherokee Nation is actually getting ready 

to construct some additional affordable housing units, rental units, multi-family 

units. Based on what we're seeing in response to bids that we're putting out, 

personally I'm a little concerned about, oh my gosh, what kind of bids are we 

gonna get back and how many are we going to get back? But that I know it 

doesn't address what the Federal Home Loan Bank is doing, but that is a 

concern for me too, is not only are we not getting many bids. Sometimes when 

those bids come back, they're way over what we anticipated paying for the 

projects. And at some point we kinda have to weigh what do we pay for the 

project? If this is what the market is demanding, do we just have to go back and 

reevaluate our plans? And that relates to rehab as well. We may anticipate 

something costing $25,000 and we get three bids back for 41, 42 and 42,5. And 

so, then we're kind of in this pickle like, "Oh my gosh, do you just pay it," and 

take your lumps? Or do you say, "This is absolutely ludicrous and can't do it, 

we're gonna rebid." So as far as construction of new multifamily units, that's a 

bit of a concern for me. 

Gene Watson: One aspect or one challenge that we have sometimes with programs that are 

designed for a low-income housing multi-unit is, if every unit is for low-income, 

right, then there's no opportunity to, okay, once we build it, once we get the 

loan, once we build, how are we gonna pay for it? Well, to pay for that on a 

continual basis has to come from someplace, right? So I've seen a project that 

happened in Alaska that I thought was unique, that might be a consideration 

that you should consider, in that it required a percentage of units to be low 

income, I believe that was LMI. But the rest of them could be market rent. One 

criteria also, a percentage of them had to be handicapped accessible. That was 

just the uniqueness of this requirement for this program. And it was a grant and 

we were actually provided the financing for it. But I thought it was really clever 

in that this TDHE was able to subsidize that low-income housing in 20% of their 

units with market rent with 80% of the units. And I thought that was a unique 

approach, but it self-funded, it cash flowed. You could take that to any local 

bank, right? As long as it's cash flowing and make that loan. So, it reduces the 

risk, it creates an opportunity to put more programs together. The unintended 

consequence of that was that nobody knew what percentage or which people 

live behind which door were low income, right? If it were 10 units, two were low 
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income, the other eight were market rent. As a child I used to get off the bus 

and walk into low-income housing. That's where I grew up, provided by the 

government, right? There's a stigma that's attached to that, that was 

unpleasant, and this approach alleviated that. I thought it was really unique and 

clever, and I really appreciated that. So just a consideration, you told us to come 

up with bold ideas. This is an idea that I think has a lot of positives to it with 

multi-unit that really worked well, and they did it in mass in Anchorage. So, we 

did a lot of it like that. 

Joshua Stallings: So, one of the roles of the banks currently plays is filling funding gaps that would 

otherwise be unfulfilled through like the AHP program. So, Sharon, coming back 

to you on this. So, what have been your experiences? Are there any ways this 

role could be strengthened in regard to some of the Tribal issues we've 

discussed? 

Sharon Wise: Well, it's a competitive grant for one thing, and the Tribes do not have any kind 

of advantage. I mean, you have multi-million dollar investors that get a AHP to 

go with their tax credit project. They know all the rules, they have the capacity, 

they have the attorneys, they have everything else, so it's very difficult to get 

awarded. Now, I know the Cherokees got about five AHPs on their tax credit 

projects. It's been almost 20 years ago. So, they've used the AHP that way. The 

Wichita Tribe on their two tax credits had AHP in it. They had about 900,000 on 

two different projects. So the Tribes have utilized, but it's even hard to compete 

for the tax credits anymore because there's probably roughly 60 some odd 

applications and they fund just over 20 usually statewide. So if there was a set 

aside for Tribes, and I know they've done that in New Mexico, I heard. Even on 

tax credits, I mean you can do that. That it wouldn't be as competitive. Or they 

would compete amongst their people, their other Tribes, which have that same 

population they're trying to serve. 

Joshua Stallings: So, Robert, do you have any thoughts on how the Federal Home Loan Banks 

could extend their reach or expand the level of awareness? 

Robert Fightmaster: I think it's difficult for them to always be able to explain all the different 

programs they have. Give you a quick example, kind of popped in my head a few 

minutes ago when we were talking about the rehab programs. We've been 

searching for somebody to buy one time close construction loans from our bank 

for years. And I kept asking the wrong question. I kept asking the Federal Home 

Loan Bank, "Hey, do you guys buy one time close, you buy one time close?" No, 

we buy modified mortgages. Oh, so I can modify my construction loan into a 

permanent? Yes. Most of the people don't know they have that. They said no 

one uses it. I would've been the first person to even try it. They've got some 

stuff out there, but they've got so much probably on their plate. How do you 

find that ability to get that special program out to your bank members, your 

Tribes, et cetera. So, I think there's some, a real wealth of intelligence in Topeka, 

in this group, but how do they get all their products out to these different 
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markets, 'cause those markets are so diverse. Oklahoma City's gonna be a lot 

different than what your needs are in Tahlequah. And that's their challenge and 

that's the hard part. 

Joshua Stallings: So, I think you did a better job of asking my question, so thank you. So, Shay, do 

you have any thoughts on this? On how the Federal Home Loan Banks could 

expand their outreach efforts or how they go about communicating what they 

do? 

Shay Stanfill: Well, Gene touched on this earlier, and it is so true that oftentimes as a Tribe 

we are searching for Native specific opportunities and not even aware that a 

Tribe could apply for some of the programs that you're offering. So I know I 

keep saying it, I feel like this is the third time, but if you wanna know, I really 

hope you do create, you know, I guess establish Native Americans as a special 

population. But, Gene's, right? And that oftentimes we are just searching for 

Native specific opportunities. I feel like that'd make a huge difference. I think 

you would definitely get a lot more applications. A lot more interest from not 

just Tribes and not just housing authorities, but other nonprofits who are 

specifically serving Native Americans. 

Joshua Stallings: Gene. 

Gene Watson: I can't add much to that great response. I would say this, I don't think the way, I 

can tell you how you don't do it, okay? I've heard some talk of- -

Joshua Stallings: Often just as useful. 

Gene Watson: Right. Of consolidating the banks, right? Maybe some consolidation might be 

appropriate, right? If anything, I think that's the wrong approach. I think local's 

better. You've probably heard me say that once or twice. So a consolidation of 

the banks, I think would harm that effort, not help it. For what that's worth. 

Joshua Stallings: So, Holly, what are some trade offs that we should be considering as we're 

thinking about the future state? How should we think about extending the 

reach of the Federal Home Loan Bank System while preserving safety and 

soundness? 

Holly Johnson: Yeah. Well, you hit the nail on the head for me as a director. It is how do we 

meet the full spectrum of needs, knowing also that some of these programs 

we're talking about are just only part of what the Federal Home Loan Banks do 

and the reality that they're broadly managed to examine and examined to zero 

risk. And so I think, we have to recognize what level of risk the banks and the 

agency are willing to accept and in pursuit of what specific purposes. Because 

without careful consideration, we can't disturb the delicate balance of our 

cooperative participation, which is what makes everything feasible. That gives 

us the funds for our programs. And so, I think, it's a good question. Well, I am an 

advocate for Tribes all day long because I know that the needs are immense,

and I feel like we can do more. But I think it needs to, you know, this input today 
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has been invaluable to kind of think about like, how do we strategically best use 

the funds because we can't do it all and what risk are we willing to accept in the 

pursuit? 

Joshua Stallings: So, are you saying that we should go from a no loss posture to a one loss 

posture? I don't know about that. Somebody said they wanted a joke and that 

was the best one I got. All right. Robert, any thoughts from you on this, on 

maintaining that balance? 

Robert Fightmaster: I don't know how you, I don't know what the method is, the methodology 

behind it all. I mean, it's a big animal. It is a monster to try to figure out all the 

things the Federal Home Loan Bank could do, and how do you get that message 

out? I don't know how you could. That's not what I'm here for. 

Joshua Stallings: Fair enough. So to close out today, I want to give everyone an opportunity to 

provide us with what they think is the single most important change you would 

recommend to best position the system as we're moving forward. And if you 

think no changes are needed, also we are willing to hear that, we want to hear 

why. So if we could actually start with Holly and go back around the table again 

if everyone can give us that one most top of the list thing. I know you all got a 

list. It's probably got a few more items on it than that. But like, just gimme that 

one top of the list item. 

Holly Johnson: So, top of the list for Tribal affordable housing and community development. 

Correct? Okay. Well, I'll be interested to see where the agency lands after all 

this input. Does the agency believe that it's more valuable to aim resources at 

hard housing gains or should we focus more on community development 

targets and community building, which may be less tangible? But directly to the 

question. I would say probably affordable owner-occupied housing is a first step 

to improving the quality of life. And that would include all the uses within the 

current HSP because I hope what we're also trying to do is not just put Native 

Americans in acceptable low-income housing. We're trying to put them on a 

path to personal and family asset building. And so in my eyes, home ownership 

would be first and then probably community development. 

Shay Stanfill: Well, Holly didn't take long enough because I was trying to figure out how I can 

make all of my points in one long run-on sentence. 

Joshua Stallings: Just gotta use commas. 

Shay Stanfill: I know I'm sounding like a broken record right now, but I would just say 

designation of Native Americans as a special population would make a huge 

difference in the affordable housing field and in the community and economic 

development arenas. 

Joshua Stallings: Jason, what did you got for us? 
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Jason Brower: You wanna hand me your points? I'll go ahead. Forget the comma. Yeah, from 

just listening, I think we're coming back to just how can we help people with 

more down payment. And so, to get that across, I think what Shay is trying to 

say is whenever you're applying for a grant through the Federal Home Loan 

Bank or to, is can you in your process give more weight, more points or 

whatever to those that are gonna be helping Native American communities? 

And is there a way to somehow give down payment assistance in a like $20,000 

specifically to Anadarko, Oklahoma people? That's where I work. I'm just 

kidding. Yeah, that's my attempt at a joke. 

Joshua Stallings: I was tracking with you. 

Jason Brower: Thank you. Thank you. 

Valerie Powell: Mine would be those larger amounts. We need to look at larger amounts that's 

available to help meet those needs. Whether it be for those down payments or 

the rehabs or the purchase price. We just need those larger amounts looked at. 

Robert Fightmaster: So, this is what I'm here for. So, really the programs are in place. It's just 

tweaking what they have. We don't need to reinvent what the Federal Home 

Loan Bank is or what they do. Just take the programs they have and maybe 

enhance them for Native Americans. Again, larger grants, waive or increasing 

the income limits, making aware that it isn't considered a defined limit for an 

institution to lend. And then secondly, taking a double look at doing loans on 

Tribal trust lands that are conforming and not 184. 

Sharon Wise: Not to offend, okay? But I would hope from your perspective and what you have 

in your idea of accomplishing or meeting your objective with us today and when 

you go on to the other Tribal communities is not that you met your objective 

just talking to a hundred different Tribal representatives and handing out 

brochures or something. I think that it should be, we actually see Indian families 

in housing. That's the objective met. It's not going out, getting input, but putting 

it to work and actually feeling like you've achieved it when it happened, when 

those programs did come out, and we put real families into real housing. 

Joshua Stallings: No offense taken. Gene. 

Gene Watson: Yeah, please hear me when I say that there's a certain injustice that first 

Americans experience the American dream at the lowest levels of any race. So 

come up with special programs designed for Native Americans, first Americans, 

right, to experience home ownership, to experience that American dream. If you 

wanna be part of something meaningful, be part of erasing that injustice. That's 

what I would say. 

Joshua Stallings: Thank you. Eric. 

Eric Howard: Okay. Well, thank you, everyone. In closing, we would like to thank you for your 

thoughts today. One of the things I would just be so remiss if I did not do is 
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thank Christy Finsel, who's the executive director of the Oklahoma Native Assets 

Coalition. Christy was invaluable in setting this up. She knows nearly all of you, I 

believe, and she had recommendations for all of you to participate today. So she 

was going to participate herself, but she had a conflict. And so, I do want to 

thank her. So, some of the things that I would like to say that I heard you say in 

just in summary is the need for more focus on the needs of Native American 

communities, the need for more support for Native American Tribal 

communities, awareness of Federal Home Loan Bank programs that already 

exist, tailored programs such that address rehab needs, matched savings 

accounts, credit building, and just alternative sources of credit. Another thing I 

heard you say is rethink the no loss posture that is predominant throughout the 

Federal Home Loan Bank System. So all of you, thank you. The team here is truly 

exceptional and it's very evident that you care deeply about this initiative. I 

want to encourage everyone to visit our website regularly as we are posting 

updates on our initiative on a weekly basis. And we are planning for a few more 

sessions for the remainder of the year, including, and I believe Joshua 

mentioned this earlier, a session on Native CDFIs in Washington, DC on 

December 8th. This will be followed by another session in Baltimore on 

December 12th on closing the racial home ownership gap and a roundtable in 

Philadelphia on December 15th that's focused on Federal Home Loan Bank 

membership, collateral and safety and soundness. And we will have at least 

several more roundtables early in 2023. So please again, keep your eye on our 

website for updates. And I just want to thank you all for your time today. And 

thank you, those of you who were live streaming our event and participating 

with us that way. So to all of you, safe travels home and thank you very much.

Joshua Stallings: Yeah. Thank you, all. And the only last thing I'll say, 'cause I think that me and 

Eric will be remiss if we didn't mention this, is that there are a number of people 

that put a lot of effort into making these events happen as anyone that has 

done these things know. You're looking at the two of us, but there's probably 

about 20 people that actually made it happen, and we would like to extend a 

wonderful thank you to them for their continued support to get all these done 

so quickly. But once again, thank you to everyone here. We do appreciate all 

your comments and we are indeed listening, so thank you very much.