The Federal Housing Finance Agency overstepped its authority when it proposed excluding captive insurers from obtaining membership in the Federal Home Loan Bank System, according to captive insurance companies. Real estate investment trusts – including Redwood Trust and Two Harbors Investment – have used captive insurance companies to gain access to FHLBank financing. “The proposed membership regulations would needlessly exclude an entire category of statutorily permitted members that can further the FHLBank System’s mission as the mortgage finance market continually evolves,” Redwood Trust said in a comment letter to the FHFA. The FHFA issued...