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  • Comment Detail

  • Date: 11/17/14
    First Name: Christopher
    Last Name: Lindell
    Organization: Guaranty Bank & Trust
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I am Chris Lindell, President & CEO of Guaranty Bank & Trust. Our institution provides lending across all of our community with a focus on commercial real estate, mortgages and other credit needs in our community. Guaranty Bank is a member of the FHLB Des Moines. Proposed rule RIN 2590-AA39 appears to us to be complicated and an expensive regulatory structure that simply adds regulatory burden to fix something that is not broken. The proposed regulation creates many concerns for our financial institution.

    The FHLB Des Moines is there for us, in all economic environments, serving as a competitive source of liquidity for all of our financing needs including housing, agricultural, commercial and consumer lending. The proposed rules would negatively impact the reliable provision of that liquidity in a great number of ways. If made law, the rules would:

    • make continued access to FHLB advances and mortgage purchase programs contingent on arbitrary regulatory determinations;

    • change the FHLB system by removing the certainty that FHLB will be a reliable source of liquidity in all market conditions;

    • restrict our access to the secondary mortgage markets;

    • conflict with concerns of financial regulators that institutions reduce holdings of long-term fixed rate mortgages and sell them in the secondary market;

    • impose regulatory burdens on us as FHLB members, raising our costs and the costs to communities we serve;

    • decrease the flexibility we need to manage our balance sheets in response to changing market conditions;

    • make membership in our FHLB less attractive.

    Because the proposals would harm FHLB bank 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.