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  • Comment Detail

  • Date: 12/03/14
    First Name: LEO
    Last Name: SCHILTZ
    Organization: SHARE AND IMPACT BANK
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    IMPACT BANK
    24 N. MAIN
    Caldwell, Kansas 67022

    12/3/2014

    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 FHLBanks (RIN 2590–AA39)

    Dear Mr. Pollard:

    Our organization has utilized FHLBank Topeka’s Joint Opportunities for Building Success (JOBS) program to benefit our community. Our bank has sponsored the JOBS grant for various organizations for projects to help startup businesses, community strategic planning and projects to help maintain businesses, all for growing employment in our community. Over the years we have sponsored $75,000 in JOBS grant funding. Our community and businesses have benefitted from the funding made available through JOBS, and we view FHLBank Topeka as a valuable community development partner. We’re deeply troubled that the Federal Housing Finance Agency’s (FHFA) recently issued proposed rule impacting FHLBank membership could diminish FHLBank Topeka’s ability to contribute to programs like JOBS.

    FHLBank Topeka’s JOBS program is designed to promote economic development initiatives that assist member institutions in promoting employment growth in their communities. FHLBank Topeka contributes up to $1 million annually to JOBS. It’s possible that funding for the JOBS program could be at risk if FHFA’s proposed rule is fully implemented. Such an outcome would further exacerbate the economic hardships many in our region are facing.

    FHFA’s proposed rule would result in an unknown number of banks, thrifts, credit unions and insurance companies losing their membership in FHLBank Topeka. This would almost certainly result in a decrease in FHLBank lending volume as well as a corresponding reduction in FHLBank profitability. A decline in FHLBank Topeka’s profitability could have a negative impact on the level of funding available for JOBS.

    We need programs like FHLBank Topeka’s JOBS program to keep small and medium-sized communities in our region thriving. That’s why we encourage FHFA to consider the individuals, families and communities that will be unnecessarily harmed by your proposal. We respectfully request that FHFA withdraw the proposed rule immediately. Thank you for taking our comments into consideration.

    Sincerely,

    Leo J. Schiltz
    Executive Vice President
    Comments