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  • Comment Detail

  • Date: 12/08/14
    First Name: Steven
    Last Name: Michel
    Organization: Henderson State Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    The proposal to require an arbitrary amount of residential mortgage loans on our books to qualify for FHLB membership will cause our bank, and many smaller ag banks like us, to lose a crucial funding source to fund the loans that we make to fund agriculture, ag businesses and our main street businesses. Banks in rural communities do not have the opportunity to originate a lot of residential mortgage loans, because of the small population base in our market areas. Furthermore, we all used to make the residential mortgage loans that were available, but the more recent onerous regulations governing residential mortgage lending has made it unrealistic and costly for us to be able to abide by all those regulations for the one or two times per year we might have the opportunity to make a residential mortgage loan. It makes much more sense to take applications here from our customers and send them on to a bank or financial services company who is set up to handle this type of loan. In that way, we can focus our capital and resources originating the types of loans in which we have the expertise. I hope you will rethink this proposal and allow we smaller rural banks to do what we do well, by not eliminating our largest source of wholesale funding. Thanks for this opportunity to comment!