Skip to main content

  • Comment Detail

  • Date: 10/24/14
    First Name: Craig
    Last Name: Coffman
    Organization: Security State Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Comments/RIN 2590–AA39

    To Whom It May Concern:

    I am a bank officer of a current member of the Federal Home Loan Bank of Des Moines. The above listed subject is a proposal by the Federal Housing Finance Agency that I believe creates a detrimental impact on the member banks as well as the Finance Agency itself.

    My bank currently has a substantial volume of mortgage assets; however, it my 30 year tenure with the bank, this concentration changes with the economic environment. I would hate to lose my FHLB membership based on the above proposed regulation enforcement that could take this membership away for our non-compliance in mortgage assets. My bank currently borrows a fair concentration of funding on a daily basis from the FHLB. A membership exclusion would create difficulty in repayment and refunding my current position of borrowings. It would also negatively impact my availability of future funding sources provided by FHLB. Likewise, many banks may be in my same circumstance which may adversely affect them and the FHLB as well.

    Please consider a ‘no’ vote on this proposed regulation for these reasons.