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  • Comment Detail

  • Date: 10/28/14
    First Name: Robert
    Last Name: May
    Organization: Banterra Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I represent a $1.3 billion community bank that has been a member of the FHLB for many years and routinely accesses our current line of $88 million (Chicago FHLB). Under your new rules we could no longer be a member. Our residential mortgages are largely sold on the secondary market due to customer demand. We service over $175 million sold to Freddie Mac and have originated another $50 million sold without servicing. More importantly we hold about $80 million on the bank's books, but this amount would be insufficient to meet your requirements. These loans are to individuals that did not qualify for secondary market mortgages. We support these loans with funding from the FHLB line. As a result of your purposed rule we would have to reduce our in house residential mortgage program significantly.