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  • Comment Detail

  • Date: 11/19/14
    First Name: David
    Last Name: Carlson
    Organization: Greater Iowa Credit Unoin
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    November 19, 2014

    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)

    Attn: Mr. Pollard:

    I am David E Carlson, EVP/CFO, BSAO of Greater Iowa Credit Union. Greater Iowa is a $355 million dollar institution with 7 branches in Iowa. Greater Iowa provides lending options to our members across 33 counties in the state of Iowa. Our lending options are diversified and include: car loans, commercial loans, credit cards, personal loans, home equity and mortgages. This variety of lending is possible as a result of the alternative funding types and terms furnished by a healthy and growing FHLB system to our credit union.
    The FHLB Des Moines serves as a critical source of liquidity for our institution as well as other financial institutions in Iowa and other states. They have proven to be a reliable and competitive source of liquidity for all of our financing needs in all economic environments. The FHLB of Des Moines also provides a longer term source of funding that institutions such as ours need to help balance their interest rate risk. This rule, if adopted, would remove the certainty that the FHLB Des Moines can be counted on to be a reliable source of liquidity in all market conditions.
    Access to advances is critically important to our credit union because FHLBank liquidity allows us to offer competitive rates and longer term loans to our members that we might not otherwise be able to offer. This is our main liquidity source in times of need. Additionally, having a credit line and borrowing capacity with FHLB Des Moines promotes the safe and sound management of our institution.
    It appears that this proposed regulation is primarily aimed at eliminating insurance companies from FHLB membership at a time when housing finance is at risk with only a small private secondary market and Fannie and Freddie in conservatorship. The insurance companies purchase housing finance loans and are a necessary partner with the FHLB. This is the time to encourage the development of additional markets for both single and multifamily mortgages. Financial institutions are being discouraged from holding mortgages meaning that we need to see the development of new outlets. The FHLBanks are a logical place to create these new models. As a credit union we need the FHLB as a trusted partner to help us develop these new markets. Why would you eliminate opportunities rather than work with us to develop new systems of finance?
    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. Thank you for taking my comments into consideration.
    Sincerely,

    David E Carlson,
    EVP/CFO
    Greater Iowa Credit Union