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  • Comment Detail

  • Date: 12/04/14
    First Name: Gary
    Last Name: Lozano
    Organization: FHLB Des Moines Advisory Council
    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, Eighth Floor
    Washington, D.C. 20024

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

    Dear Mr. Pollard,

    I am a sixty-four year old member of the FHLB Des Moines Advisory Council. I am a city planner, having spent the first twenty-five years of my career working for local government and the last thirteen years as a planning consultant. I am currently employed by a Des Moines architecture and planning firm. My career has been focused on housing, neighborhood revitalization and central city and small town economic development. I am fortunate to have completed planning projects in each of FHLB Des Moines’ five states and strive to bring a broad community-wide and even regional perspective to our work at the Advisory Council.

    Having spent my career writing plans for communities, I know that they are essentially worthless without strong implementation efforts. Through site visits to each of our member states, I have seen first-hand the positive contributions made to community housing, neighborhood revitalization and economic development efforts by FHLB lending through local financial institutions. While the FHLB-funded projects I have toured are important components of community revitalization in and of themselves, many also become catalysts encouraging additional private investment in the area. I learned long ago that it is private sector investment that underlies successful revitalization efforts. FHLB lending is an important component of this investment.

    I am therefore very concerned that your agency’s proposed rules would adversely impact the number of FHLB member institutions and decrease the resources available to communities to address the serious issues they face. If current FHLB members cannot be certain that their FHLB membership will continue and ongoing mortgage asset tests discourage new members, this can only have negative impacts on the tough job of dealing with affordable housing, neighborhood deterioration and economic decline.

    I urge you to take the broad community impact of these proposed new rules into consideration as you go forward in this process. I believe that these impacts are of such significance that it is Congress’ role, and not the FHFA’s to implement such a fundamental change. Thank you for your consideration.

    Sincerely,

    Gary Lozano, Member, FHLB Des Moines Advisory Council
    Senior Partner, RDG Planning & Design, Des Moines, Iowa
    1069 Polk Blvd.
    Des Moines, IA 50011