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  • Comment Detail

  • Date: 12/08/14
    First Name: Chad
    Last Name: Johnston
    Organization: Farmers State Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I am writing today to voice my concern on the proposed rule governing FHLB membership. We are a small community bank in rural Nebraska. We are members of the FHLB and we use it from time to time for liquidity needs. This is a very important funding source to our bank. The proposed rule would have a significant effect on the bank and our ability to meet short term funding needs.

    As a bank, we do all kinds of lending to support our community and our rural area. The majority of our loans are agricultural related loans including loans to farmers and ranchers for their real estate. These loans often are on real estate that includes their primary residence. They are not classified residential real estate loans, but instead are agricultural loans. We make residential real estate loans in our market, but due to the age and condition of a lot of the houses in our communities, these loans are very small. We will never have a large residential real estate portfolio due to our geographic location, but we do need to be members of the FHLB so we can continue to support our communities and rural area.

    I hope that you will consider these comments in your final decision making process. The FHLB was created to be used the way we are currently using it. If that is changed, it will have a drastic effect on many small banks in rural communities. Thank you for your consideration on this matter and I hope that you will leave membership rules as is.

    Sincerely,
    Chad Johnston
    President