11th District Cost of Funds Index

The 11th District COFI was a monthly savings-institution funding-cost index used by adjustable-rate mortgages before publication ended in January 2022.

The 11th District Cost of Funds Index (COFI) was a monthly benchmark measuring the weighted-average funding cost of eligible savings institutions in Arizona, California, and Nevada. It was published by the Federal Home Loan Bank of San Francisco and used mainly as a reference index for adjustable-rate mortgages.

COFI is discontinued. The final monthly 11th District COFI, covering December 2021, was published in January 2022. A remaining COFI-linked mortgage now depends on its contractual fallback, servicing rules, and any applicable replacement-index framework.

Key Takeaways

  • COFI measured institutions’ interest cost on savings, advances, and other borrowings, not current mortgage offers or Treasury yields.
  • The 11th Federal Home Loan Bank District covers Arizona, California, and Nevada.
  • The index generally moved more slowly than market rates because institutions’ funding portfolios repriced over time.
  • A COFI-linked adjustable-rate mortgage normally added a fixed contractual margin to the applicable index value.
  • Rate and payment caps could prevent the new payment from moving one-for-one with the fully indexed rate.
  • Publication ended after the number of eligible reporting institutions declined substantially.
  • The last monthly value was for December 2021 and was published in January 2022.
  • Replacement treatment is contract-specific; not every COFI loan moved to the same index or spread.

What COFI Measured

Savings institutions fund assets such as mortgages using several liability sources. Historical COFI inputs included:

  • savings and transaction deposits
  • time deposits
  • Federal Home Loan Bank advances
  • other eligible borrowings

The index compared interest expense on those funds with the amount of funds outstanding. It therefore represented an average cost of liabilities for the reporting institutions.

COFI did not directly measure:

  • the rate on new mortgages
  • the cost of one newly issued certificate of deposit
  • a risk-free government rate
  • a central-bank policy rate
  • the credit risk of an individual borrower

How COFI Was Calculated

A simplified annualized relationship is:

$$ \text{COFI} \approx \frac{ \text{Annualized Interest Expense on Eligible Funds} }{ \text{Average Eligible Funds Outstanding} } $$

The official calculation aggregated eligible institutions before computing the ratio. It was not a simple average of each institution’s rate and not a sum of “interest expense times weight” as some simplified descriptions suggest.

The methodology used monthly accounting data and annualization rules. Historical reproduction therefore requires the applicable FHLBank methodology, reporting population, and observation month.

Why COFI Was a Lagging Index

An institution’s funding base included deposits and borrowings that repriced at different times. When market rates rose, older low-rate liabilities could remain in the portfolio until renewal or maturity. When market rates fell, older high-rate liabilities could also remain.

As a result, COFI often adjusted more gradually than a market rate based on current transactions or securities. That lag could smooth monthly changes, but it did not guarantee lower lifetime borrowing costs.

A slow-moving index can be favorable or unfavorable depending on the rate cycle:

Market-rate directionTypical COFI behaviorPossible borrower effect
Rates risingCOFI may rise with a delayInitial protection, followed by later increases
Rates fallingCOFI may fall with a delayBorrower may wait longer for lower indexed rates
Rates volatileFunding-cost averaging can smooth movementPayment path differs from faster market indices

Worked Example: Historical COFI ARM Reset

Assume a legacy adjustable-rate mortgage specified:

  • applicable COFI: 0.50%
  • contractual margin: 2.75%
  • no binding floor or periodic cap for this reset

The fully indexed rate would be:

$$ 0.50\% + 2.75\% = 3.25\% $$

If a periodic cap limited the increase from the prior rate, or a lifetime cap or floor applied, the note rate could differ from 3.25%. A payment cap could also limit the payment change without limiting interest accrual, potentially creating deferred interest under the contract.

This example is historical. A post-cessation reset must use the replacement process required by the loan documents and applicable servicing framework.

COFI Cessation

When monthly COFI was developed in 1981, more than 200 savings institutions contributed data. Industry consolidation, mergers, and charter changes reduced the eligible reporting population over time.

The Federal Home Loan Bank of San Francisco announced that it would discontinue its cost-of-funds indices because too few eligible institutions remained to support continued publication. The last monthly 11th District COFI publication occurred in January 2022 for the December 2021 observation.

The end of publication does not erase the original mortgage contract. It activates whatever replacement or unavailability language governs the loan.

What Replaced COFI

There was no single universal outcome for every loan.

Depending on the mortgage note, investor, and servicing framework, a COFI-linked loan could use:

  • an Enterprise 11th District COFI Replacement Index
  • a Treasury-based index identified in the note
  • another fallback selected under the contract
  • a replacement index plus an adjustment intended to reduce value transfer

Fannie Mae and Freddie Mac developed Enterprise replacement arrangements for affected populations, while some notes expressly directed a different fallback. The original document and current servicer notice are the starting evidence.

COFI vs. Other Mortgage Indices

Index typeMain inputTypical response to market changes
Historical 11th District COFISavings-institution funding expenseGenerally gradual and lagged
Treasury constant-maturity rateGovernment-security market quotations and curveMore responsive to current Treasury conditions
SOFR-based indexSecured overnight Treasury repo data or compounded formTransaction-based, with convention-dependent smoothing
Prime rateBank-published lending base rateChanges discretely when banks revise prime

“Less volatile” does not mean “always cheaper.” The margin, caps, floor, adjustment frequency, and index level determine the borrower outcome.

How to Review a Legacy COFI Mortgage

  1. Locate the note’s exact index definition and publication source.
  2. Confirm the margin, adjustment dates, lookback, and rounding rule.
  3. Identify initial, periodic, and lifetime rate caps.
  4. Separate rate caps from payment caps.
  5. Read the index-unavailability and replacement clause.
  6. Review any servicer conversion or replacement notice.
  7. Verify whether a spread adjustment accompanies the new index.
  8. Recalculate the reset using the specified observation date.
  9. Preserve historical COFI values and servicing records.
  10. Escalate unexplained discrepancies through the servicer’s dispute process.

Common Mistakes and Limitations

  • Describing COFI as still published monthly.
  • Treating COFI as a current mortgage offer rate.
  • Calculating it as a simple average of institution rates.
  • Assuming a slow-moving index is always favorable to borrowers.
  • Ignoring the loan margin, caps, floor, and rounding.
  • Treating a payment cap as an interest-rate cap.
  • Assuming every COFI mortgage received the same replacement.
  • Using the last published COFI indefinitely without checking the fallback clause.
  • Confusing 11th District COFI with a generic cost-of-funds measure.

Authoritative Sources

  • Reference Index: Contractual benchmark used with a margin to reset a floating rate.
  • Adjustable-Rate Mortgage: Mortgage whose rate can reset under index, margin, and cap provisions.
  • SOFR: Active U.S. dollar overnight benchmark used in some floating-rate frameworks.
  • LIBOR: Another discontinued benchmark that required contract-specific transition.
  • Interest Rate Cap: Limit on specified rate increases or floating-rate exposure.

FAQs

Is the 11th District COFI still published?

No. The final monthly index, for December 2021, was published in January 2022.

What index replaced COFI?

It depends on the mortgage documents and servicing framework. Some loans use an Enterprise replacement index, while others specify a Treasury-based or different contractual fallback.

Why did COFI usually move slowly?

It averaged funding expenses across deposits and borrowings that repriced at different times, so changes in current market rates flowed through gradually.

This article provides general mortgage and benchmark education, not individualized borrowing, legal, servicing, or refinancing advice. The mortgage note and current servicer records control a specific reset.