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  • Comment Detail

  • Date: 12/10/14
    First Name: Kurtis
    Last Name: Schmidt
    Organization: Western Heritage Credit Union
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I am writing to express my own and my Credit Union's opposition to the proposed Federal Home Loan Bank rule. While the rule does not appear to directly affect my institution, it nevertheless creates unnecessary complexity to a process that best I can tell is not broken. If passed, and because my institution views the FHLBank as an important source of funding, it would create uncertainty for us as to the availability of our future access to the FHLBank. We are a small $75 million FI with limited staff, and whenever rules that affect critical services pass we have to spend even more time educating ourselves as to the rules impact on our operations. I hope my comment serves as insight to the FHFA as to the impact any rule (whether we are directly affected or not) has on small FIs with limited resources. Please don't waste our time making rules that don't solve real problems.

    Thank you,

    Kurt Schmidt
    CEO - Western Heritage Credit Union