Comment Detail

Comment

These comments respond to the Federal Housing Finance Agency’s (FHFA) notice of proposed rulemaking RIN 2590-AA39, which would impose new restrictions on Federal Home Loan Bank (FHLBank) membership. As a member of the Affordable Housing Advisory Council for the Federal Home Loan Bank of Seattle, I urge FHFA to extend the comment period on this proposed rule from 60 to 120 days.

The proposed rule would have far-reaching implications for current FHLBank members, prospective FHLBank members, and the communities they serve. It would restrict access to liquidity and funding for housing, job growth, and economic development at a time when policymakers are encouraging financial institutions to increase their lending in order to stimulate the economy. The proposed rule would also force members to manage their balance sheets to specific membership requirements, rather than allowing members to do what is best for their business, communities, and profitability. Further, mandating ongoing compliance with these requirements could cause FHLBank members otherwise in good standing, including Community Development Financial Institutions, to lose their memberships. In such a scenario, the consumer loses access to capital and our communities and economy suffer.

The FHFA has requested comments on the proposed rule by November 12 (within 60 days of publication in the Federal Register). Because the proposed rule will have significant impacts on the housing finance system, it merits more careful and deliberate consideration. Therefore, I respectfully request that FHFA extend the comment period from 60 to 120 days.

Respectfully submitted,

Jeff Judd
Member, Affordable Housing Advisory Council for FHLBank of Seattle
Executive Vice President of Real Estate, Cook Inlet Housing Authority