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  • Comment Detail

  • Date: 12/08/14
    First Name: Jenalee
    Last Name: Stucky
    Organization: Vintage Bank Kansas
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    ATTN: General Counsel Alfred M. Pollard
    RE: RIN 2590-AA30

    I am the Chief Operations Officer for Vintage Bank Kansas. We are a small community bank. We are growing and attempting to get to a size that will allow us to adequately handle the required infrastructure to compete in today's financial world and still maintain our place in small communities as a community bank. We currently have three branches, two of which are in communities of less than 1200 citizens. In those communities, we participate in local parades, have the entire town in for a holiday soup luncheon, and we support our local schools through contributions and by being a visible part of their success. We also provide home loans in these communities, however, this proposal would put a burden on us to hold a certain percentage of our assets in home mortgage loans.

    We currently use the Federal Home Loan Bank for borrowings that are amortized and matched to farm loans. In addition we have used the FHLB for overnight borrowings for short term funding needs and for fixed term borrowings to assist us in maintaining and managing the asset/liability position of the bank in an effort to maintain earnings stability in the event interest rates change significantly. The rates that we are able to receive on these borrowings are significantly less than those we can achieve through other sources and IF we did not qualify for this our income would be significantly affected.

    Why would the FHFA implement a proposal that is contrary to the actions of Congress, which has always worked to expand the FHLB membership? Please reconsider this proposal as it will adversely affect community banks who strive to bring the same financial products to small communities as are available in larger more urban areas. This is no easy task with a smaller asset base than our larger counterparts but generally the same regulatory burdens and costs associated with maintaining profitability and/or growing in an ever increasing technology based industry.