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  • Comment Detail

  • Date: 10/28/14
    First Name: Mark
    Last Name: Baron
    Organization: FIeldstone Credit Union
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I strongly urge the Federal Housing Finance Agency to NOT change the FHLB membership rules as it pertains to requiring members to hold at least 10% of assets in residential mortgage loans on an annual basis, and as it pertains to requiring members to hold 1% of assets in home mortgage loans.

    As a relatively smaller financial institution, our FHLB membership is a valued potential source of liquidity. Having requirements such as those shown above can easily result in many financial institutions no longer being able to maintain membership in the FHLB. Why should the FHLB be put in the position of expelling institutions that want to be members, that want to be able to utilize them as a liquidity source? Isn't a primary purpose of the FHLB to be able to offer liquidity to institutions that need it? It seems to me that making the proposed changes will stop the FHLB from being able to do what it exists to do... provide funding to financial institutions. Please do not make these proposed changes!