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  • Comment Detail

  • Date: 12/08/14
    First Name: LuAnn
    Last Name: Doerr
    Organization: Brunswick State Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    The proposed requirement for community banks regarding the maintenance of a percentage of their assets in home mortgages will prevent some community banks from maintaining membership in a FHLB. Smaller community banks may not offer home mortgages due to the difficulty in underwriting them under the current regulations. They do not have enough staff trained to properly offer these loans; they may not have sufficient demand to justify the additional staff and expense of offering these products; they may not be able to compete with larger institutions regarding rates and options; and the portfolio of these loans would still not meet the required percentages if they were offered.

    The proposed requirement puts an additional burden on smaller community banks and limits their ability to access inexpensive funding to provide for the banking needs of the communities they serve.