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  • Comment Detail

  • Date: 12/12/14
    First Name: Carol
    Last Name: Fehrle
    Organization: Quail Creek Bank, NA
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Our financial institution strongly opposes the proposed rule focused on Federal Home Loan Bank membership. Depending on how much of the proposed rule takes effect, a number of banks, several credit unions, and a few insurance companies could lose their membership in FHLBank Topeka. This would result in as much as $1.54 billion in lost advances to existing members. Profits could drop by $5.1 million and their contribution to their Affordable Housing Program (AHP) could decrease by $510,000.

    Although our bank would still currently pass the requirements of the FHFA's proposed rule, we are concerned because the result is that it would be more difficult for financial institutions to obtain or maintain access to liquidity through FHLBank advances. We believe a strong FHLBank with a broad membership base benefits all FHLBank members. As clearly stated above, the proposed rule would work to the detriment of the member banks FHLBank Topeka serves.

    Thank you for your consideration in reading these comments.