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  • Comment Detail

  • Date: 11/03/14
    First Name: Adrian
    Last Name: Johnson
    Organization: Lincoln Savings Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I am Adrian Johnson First VP of Asset Liability Management for Lincoln Savings Bank. Our institution provides lending across all of our communities for any and all needs, including, Ag, Commercial, Mortgage and Small Business. The proposed regulation on FHLB membership creates many concerns for our financial institution.

    The FHLB system is a primary source of funding for our institution to support loans of many various types. This change is contrary to our primary regulators repeated requests in reducing holdings of long term fixed rate mortgages, due to the inherent Interest Rate Risk. In addition, the revised membership rules would decrease our flexibility to manage our borrowings and impact our access to funding along with increasing our costs. In sum, this rule could restrict our communities access to borrowing, as well as increase costs, which would be counterproductive to economic growth.

    Because the proposals would harm FHLBank members and hurt housing, credit and economic growth, we ask that the FHFA withdraw the new membership rules contained in its September 12, 2014 Notice of Proposed Rulemaking and work with FHLB members to preserve the FHLBs as a reliable partner of its members that benefits local lending institutions, communities, housing, homeownership and the nation’s economy.

    My institution and I appreciate your consideration of our objections to the revised membership rules.

    Thanks
    Adrian Johnson