Future Acceptance of eNotes as Collateral within the Federal Home Loan Bank System
The 11 Federal Home Loan Banks (FHLBanks) are developing a solution that will pave the way for our members to pledge eNotes as eligible collateral. As member-owned cooperatives, we recognize and understand the value and benefits that eNotes provide, both to our nearly 6,900 member institutions and to the customers they serve.
The FHLBanks have created Electronic Promissory Notes (eNotes) Model Collateral Acceptance Requirements and Guidelines, a common set of core requirements for accepting eNotes as collateral. These guidelines are based on federal law pertaining to electronic signature transactions, and set forth standards relating to eSignatures, eNote documentation, eClosings, eRegistry requirements, eNote vault requirements, and servicing system requirements. Each FHLBank will need to approve the Electronic Promissory Notes Model Collateral Acceptance Requirements and Guidelines in accordance with their internal approval process.
The FHLBanks have made significant progress in arriving at a systemwide solution for storage of eNotes, and are in the process of finalizing this important milestone. Once this process is complete, the FHLBanks will be able to set a timetable for providing collateral value. However, since each individual FHLBank has its own systems, processes, and policies regarding collateral, implementation timelines will vary.
At FHLBank Indianapolis we anticipate that we will begin to accept eNotes as collateral by the end of 2020.
For more information about eNotes, please see the below materials, including a webinar, video, and eNotes readiness checklist.
- What is an eNote? - This short video at the bottom of the page describes what is and is not an eNote.
- Overview Videos – These videos answer basic questions regarding an eClosing, eRegistry, and eVault.
- FHLBank Webinar – A deeper dive video that provides an overview of eNotes and explains how they will impact the FHLBank system.
- eNotes Checklist – A checklist that summarizes the steps your institution needs to take before they can pledge eNotes as collateral.
- eNotes Requirements – This document outlines the requirements your institution needs to meet before pledging eNotes.
FHLBank Indianapolis recognizes that its membership is segmented, and different organizations are at different stages regarding the origination and/or acquisition of eNotes. This ranges from members currently having the capability to originate/acquire an eNote, to those actively pursuing eNote technology, to those that are in the early stages of gathering information regarding eNotes, and to members that currently are not interested in originating eNotes.
FHLBank Indianapolis currently accepts loan collateral with documents containing wet-signature, scanned, or eSigned signatures with the exception of the promissory note, which requires a wet-signature.
While FHLBank Indianapolis continues to work towards the acceptance of eNotes as collateral, the purpose of this page is to provide members with educational materials, collateral requirements, and a pledging checklist. These materials are provided to assist members no matter what stage they are in with regards to the origination and/or acquisition of eNotes.