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  • Comment Detail

  • Date: 11/10/14
    First Name: Denis
    Last Name: Fokken
    Organization: First Dakota National Bank
    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

    Re: Notice of Proposed Rulemaking and Request for Comments- Members of the FHLBanks (RIN 2590-AA39)

    Dear Mr. Pollard:

    Our institution serves the needs of our mostly rural customers in south east South Dakota and Northern Nebraska and has roughly $1.1 billion in assets. We work hard to serve the needs of our customers and are very concerned about the health and welfare of individuals and businesses in the area that we serve.

    We value our relationship with the Federal Home Loan Bank of Des Moines as it provides us among other things an important source of liquidity and an outlet to sell mortgages. We would be opposed to any regulation that would put this relationship in question and in turn hinder our ability to serve our community.

    We see this NPR as adding unnecessary regulatory burden to our organization. We feel very strongly about serving the housing needs of our customer base. While this NPR may be intended to encourage that housing needs are met, please understand that we already take an active role in understanding and serving that aspect of our customers’ needs. This regulation would impose additional burden that could be a distraction from rather than an incentive to serve these housing needs.

    While we currently have a significant amount of housing assets on our balance sheet today, the effect of this rulemaking, if successful, would impose limits on how we may be able to structure our balance sheet and manage our risks in the future. As such we would like to discourage the pursuit of this NPR.

    If you have any questions or comments for our bank, please don’t hesitate to contact me.

    Sincerely,

    Denis Fokken
    CFO
    First Dakota National Bank
    225 Cedar Street
    Yankton, SD 57078