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  • Comment Detail

  • Date: 09/24/14
    First Name: Ken
    Last Name: Fenno
    Organization: Manhattan Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    1. This is a very short time-frame for study to submit a meaningful comment regarding the proposal. Please extend the time frame to 120 days.

    2. The ongoing proposal of 10% of assets is a little to strong for small institutions like ours. There is fierce competition for mortgages in our market place and so it is not always possible to have 10% of assets in residential mortgages. 4 or 5% would be a more reasonable number.

    The Federal Home Bank provides the possibility of short and long term liquidity to help with seasonal fluctuations and economic fluctuations in our more rural setting. The availability of this liquidity actually encourage us to make and hold more residential loans "in-house", because we know that source of funding is available if needed.

    We appreciate your careful and consideration of the unintended consequences of the proposal.

    Sincerely
    Ken Fenno
    CEO