April 9, 2024

Woman and man standing next to each other outdoors in front of their home while holding hands and smiling.

Frequently Asked Questions for Members

Homeownership is the primary way in which most people build wealth and opportunity in this country. However, there is a significant racial homeownership gap between people of color and whites due to well-documented historical and inherent discriminatory policies and practices. In recognition of these obstacles and inequities, FHLBank Boston has created a program classified as a Special Purpose Credit Program (SPCP) to support people of color purchase a home. To learn more about the program, please refer to the Lift Up Homeownership Procedures and Frequently Asked Questions listed below.

​What is the Lift Up Homeownership program?

The Lift Up Homeownership program provides enhanced down-payment and closing-cost assistance to first-time homebuyers earning no more than 120% of the area median income, as defined by the U.S. Department of Housing and Urban Development (HUD). The program is designed specifically for people of color defined as Black, American Indian/Alaska Native, Hispanic, Asian, and Native Hawaiian/Pacific Islanders. Through Lift Up Homeownership, grants are made to eligible borrowers when they close on mortgages with participating member financial institutions. Lift Up Homeownership is one of three homeownership assistance programs offered by FHLBank Boston. 

What is a Special Purpose Credit Program?

Special Purpose Credit Programs (SPCPs) are allowed under the Equal Credit Opportunity Act (ECOA) and implementing Regulation B of the Consumer Financial Protection Bureau. These laws allow lenders to establish programs that address special social needs and increase access to the credit markets based on a written plan. The written plan must include the class of people the program is designed to benefit, set forth procedures and standards, and establish the period the program will run for or be evaluated. Considering recent guidance from HUD stating that ECOA-compliant SPCPs generally do not violate the Fair Housing Act (FHA), this SPCP will allow FHLBank Boston’s members to legally provide targeted assistance to people of color without violating ECOA, the FHA, or other overlapping antidiscrimination laws.    ​

Can asking questions about race or ethnicity be considered discriminatory in making lending decisions?

Although ECOA generally prohibits lenders from requesting or considering information about race or ethnicity, there is an explicit exception when the information is needed to determine eligibility for a properly established and administered SPCP. The exception only covers information needed for that purpose. A member may ask a borrower if they are a member of a protected class to the extent necessary to determine eligibility for Lift Up Homeownership program. This means it is appropriate to ask a borrower if they are a person of color. 

How do FHLBank Boston members confirm if their regulator accepts or approves of this program?

Regulators do not approve or disapprove SPCPs. However, the recent interagency statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation B encourages lenders with questions about any aspect of ECOA and Regulation B’s special purpose credit provisions to consult with their appropriate regulatory agency. FHLBank Boston encourages members to consult and/or notify their regulator on their participation in this SPCP. Engaging regulators in discussion about plans to participate in this SPCP minimizes risks and allows institutions to address their regulators’ perspectives. FHLBank Boston met with applicable regulators, including banking regulators, and took their feedback into consideration in designing this program. 

​Does a member need to conduct its own assessment or legal analysis to determine if they are covered under the program? 

FHLBank Boston completed its written plan in compliance with ECOA and Regulation B. A member should make its own determination of what it must do before participating in the program. FHLBank Boston has prepared its written plan cognizant of members’ needs and hopes members will find the analysis in the written plan sufficient for them to rely on to participate in the Lift Up Homeownership program. Members should feel free to conduct their own analysis. FHLBank Boston will provide a copy of its written plan and its Lift Up Homeownership program agreement upon approval of a member’s application.

​How does FHLBank Boston define and certify a homebuyer as a person of color?

FHLBank Boston defines a person of color for participation in the Lift Up Homeownership program as Black, American Indian/Alaska Native, Hispanic, Asian, and Native Hawaiian/Pacific Islander. Homebuyers will be required to self-certify their race or ethnicity by completing a self-certification form provided by FHLBank Boston. Individuals who do not self-identify their ethnicity or race will not be eligible to participate in this program.  

Does every member of a household have to fit FHLBank Boston’s definition of people or color?

No. The entire household does not have to be persons or color. However, at least one adult who self-certifies as a borrower on the first mortgage loan application must be a person of color as defined in FHLBank Boston’s written plan. 

​What if a person is of mixed race? 

The borrower or co-borrower only needs to self-certify as Black, American Indian,  Alaska Native, Hispanic, Asian, or Native Hawaiian/Pacific Islander.  

Does the homebuyer have to be a first-time homebuyer? 

Yes. The homebuyer must be a first-time homebuyer. FHLBank Boston defines a first-time homebuyer according to regulation 24 CRF 92.2. In addition, at least one adult borrower must complete first-time homebuyer education/counseling from an organization approved by FHLBank Boston. Please refer to FHLBank Boston's list of approved agencies.

What is the maximum grant amount a homebuyer can receive through the Lift Up Homeownership program? 

An income-eligible homebuyer identifying as a person for color, as defined in FHLBank Boston’s written plan, can receive up to a $50,000 grant.  

Can the homebuyer down-payment contribution be a gift or gift of equity?

No. This contribution must be $1,000 of the homebuyer's own funds and not a gift or gift of equity. This contribution must be evidenced on the executed purchase and sales agreement or addendum. The homebuyer may receive an additional gift of gift of equity in the transaction. However, these sources of funds will not be considered the homebuyer's own contribution. 

What types of properties are eligible to be purchased under the Lift Up Homeownership program?

Eligible properties are owner-occupied, primary residences purchased in New England and include one- to four-family homes, townhouses, condominiums, cooperative housing units, and manufactured housing deeded as real estate. 

​Can the Lift Up Homeownership program grant be used to buy down a homebuyer’s interest rate?

Yes. The Lift Up Homeownership program grant can be used to buy down a homebuyer’s interest rate by purchasing discount points (capped at 2%).

Is the Lift Up Homeownership program grant forgivable?  

Yes. The Lift Up Homeownership grant is forgivable after five years from the closing date, subject to complying with the program’s affordability provisions. Homebuyers will be required to sign a subordinate mortgage and note securing the affordability provisions. In the event of a sale, transfer, assignment of deed, or refinancing prior to the end of the five-year period, FHLBank Boston will conduct a repayment calculation based on net proceeds and the homebuyer’s capital investment in the property, to determine if funds are due to FHLBank Boston. In the event of a refinancing, FHLBank Boston will permit the Lift Up Homeownership grant to be subordinated at its sole discretion. Please work directly with all grant recipients before contacting FHLBank Boston’s housing and community investment team.

Does the Lift Up Homeownership program operate like the FHLBank Boston’s Equity Builder Program (EBP) and Housing Our Workforce (HOW) homeownership assistance programs?

Yes. The Lift Up Homeownership program procedurally operates similarly to the EBP and HOW, including determining income eligibility, enrolling eligible homebuyers, requesting disbursement of grant funds, and monitoring. The Lift Up Homeownership program differs in that it is a Special Purpose Credit Program, governed by separate procedures, disclosures, and retention documents. Please refer to the program Procedures  and homeownership assistance programs income calculation guidelines.

​Can a homebuyer layer the Lift Up Homeownership program grant with either EBP, HOW, or FHLBank Boston’s Affordable Housing Program?

No. The Lift Up Homeownership grant cannot be layered or combined with FHLBank Boston’s EBP, HOW, or Affordable Housing Program. If a homebuyer meets the Lift Up Homeownership requirements, they can layer the grant with local, state, federal, and other down-payment assistance programs outside of FHLBank Boston.