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  • Comment Detail

  • Date: 11/12/14
    First Name: Brandon
    Last Name: Taylor
    Organization: Legacy Bank and Trust & Century Bank of the Ozarks
    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:

    I am Brandon Taylor, Chief Financial Officer of Legacy Bank and Trust and Century Bank of the Ozarks. Our Banks combine for over 300 Million in assets with over 100 employees distributed across 8 branches in Southern Missouri. The Federal Home Loan Bank of Des Moines is critical to our success. The easily accessible, low cost funding our membership in the FHLBDM provides is our primary source of alternative funding that is used to provide essential credit to our communities.

    I am writing to express my concerns about the notice of proposed rulemaking regarding membership eligibility in Federal Home Loan Bank (FHLBanks) put forward by the Federal Housing Finance Agency (FHFA). The proposed rule includes significant and unnecessary changes to long-standing membership rules for the FHLBank system. The proposed changes are inconsistent with Congressional intent and the Federal Home Loan Bank Act (FHLBank Act). For these reasons our Banks vehemently oppose this proposed rule.

    Broadly speaking, the FHLB Des Moines serves as a critical source of liquidity for financial institutions in Iowa, Minnesota, Missouri, North and South Dakota. They have proven to be a reliable and competitive source of liquidity for all of our financing needs in all economic environments. This rule, if adopted, would remove the certainty that the FHLB Des Moines can be counted on to be a reliable and affordable source of liquidity in all market conditions.

    Without access to our FHLBank, the credit available to communities in our region will be unnecessarily impacted. We believe this proposed rule is a solution in search of a problem. Because the proposed rule outlines no safety and soundness concerns-and because there is no legitimate public policy goal of the proposed rule- Legacy Bank and Trust and Century Bank of the Ozarks strongly recommends that you withdraw the proposed rule. Thanks for taking our comments into consideration.

    Sincerely,

    Brandon Taylor
    Chief Financial Officer
    Legacy Bank and Trust & Century Bank of the Ozarks