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  • Comment Detail

  • Date: 09/12/14
    First Name: Robert
    Last Name: Meyerson
    Organization: Harvest Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I think the proposal to require that FHLB member banks maintain 1% of assets invested in residential real estate is terrific. The bank is known as the Federal HOME LOAN Bank, not the Federal Loan Bank. Its mission is to encourage financial institutions to invest in residential housing. Why should an FI that is not in that line of business have access to the system's funding? They have other options. If they don't, we members don't want them bleeding our facility. Allowing non-residential mortgage FIs into the system is mission creep at its worst: it distorts the system mission beyond recognition. The only real issue here is what the percentage should be. 1% sounds way too low to me and will allow institutions with other priorities to make a minimal investment to qualify for their other purposes.