Comment Detail

Comment

Many of the rules being suggested by FHFB affects a non-CFI ogranization such as Metro Community Development, a non-profit Community Development Financial Institution in a very negative way. It takes away the opportunity of accessing Affordable Housing fund resources to struggling communities of Flint MSA and Saginaw MSA, our Target Market Area. The FHLBI was very helpful in assisting us to become a member institution. That membership opportunity is being taken away by the proposed new rule. It is difficult for us to maintain 10% of assets in mortgage loans.
FHLBI provides many opportunities for us to access both capital and grant funds which are in turn leveraged with home mortgages, micro and enterprise loans. The proposed new rules minimizes and in some cases eliminates these opportunities.
Ongoing asset tests fail to recognize the many ways members support housing finance, including loan
sales into the secondary market and community investment using the FHLBs’ affordable housing and
community investment programs.
• Asset tests are arbitrary, hinder sound balance sheet management and disadvantage seasonal
community lenders and mortgage banks that sell production.
• Ongoing tests are unnecessary
* FHLB collateral policies are self-reinforcing and create incentives
for supporting mortgage finance and community and economic development.
FHFA is setting a negative precedent to define a business model and is eliminating existing members from membership – which business model will be re-defined next?
• Reducing FHLBI’s membership base negatively impacts profitability, income, member dividends and the availability of AHP funds.
• Lower AHP funds negatively impacts our communities.
• The proposal is especially harmful to Michigan.

Please reconsider the rules and make the system be more functional, productive and helpful to low-income communities.

Thank you.