View questions about the CARES Act and the MPF Traditional Program:

1. How can FHLB Des Moines justify having a forbearance program that does not comply with the CARES Act for the MPF Traditional Program? If you stay with the current guidance will member institutions be "held harmless" for any legal action against us for violating the law? While we fully appreciate all the moving parts to the program, please provide the legal guidance you are making the basis of your decision for violating the CARES Act.

FHLB Des Moines is working very closely with the Mortgage Partnership Finance® (MPF®) MPF Provider/Chicago and the various MPF Banks on this issue.

As many of you know, the MPF Program provides for the sale of many different loan types into the various MPF products. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) does not specifically apply to all of the loans sold into the MPF Program. Where the CARES Act does apply, the MPF Program Announcements have clearly stated that MPF originating and servicing Participating Financial Institutions (PFIs) must comply with all applicable laws and guides relevant to the loans sold and serviced.

MPF Traditional (i.e. risk-sharing) conventional loans, in particular, are not covered under the CARES Act. We are currently assessing the “gaps” between relief provisions offered under the MPF Traditional Guides and those provided under the CARES Act. This effort will help us understand the implications and impact of additional relief provisions under the MPF Traditional Program. 

“Mortgage Partnership Finance” and “MPF” are registered trademarks of the Federal Home Loan Bank of Chicago.