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  • Comment Detail

  • Date: 11/09/14
    First Name: Thomas
    Last Name: Damkroger
    Organization: First State Bank Nebraska
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Alfred M. Pollard, General Counsel
    Attention: Comments/RIN 2590–AA39
    Federal Housing Finance Agency
    400 Seventh Street SW
    Washington, D.C. 20024

    Mr. Pollard,

    I'm aware of your proposed rule regarding eligibilty in the Federal Home Loan Banks and have some concerns.

    I write as CEO of a community bank with over $420 million in assets and over 120 employees. We serve both urban and rural communities and anticipate continued growth over the short and mid term.

    Initially, I am most concerned about the lack of clear justification for the proposed rule.There is no reference to safety or soundness nor do you articulate an inadequacy in the current membership requirements.

    In addition to the absence of justification for the rule, the actual outcome of your proposal would have a chilling effect on new FHLB membership and could even cause several banks to lose their membership.

    FHLBanks have been a critical source of liquidity. I am concerned your proposal would remove them as a resource for community banks. In the alternative, I would encourage you to look for ways to increase economic activity in the small business and housing sectors along with removing onerous regulations.

    With consideration to the aformentioned points, I respectfully request a withdrawal of the proposed rule.

    Thank you,

    Thomas G. Damkroger
    CEO First State Bank Nebraska