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  • Comment Detail

  • Date: 12/12/14
    First Name: Mark
    Last Name: Ingalls
    Organization: Dedham Institution for Savings
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    I appreciate the opportunity to submit this comment on the proposed rule changes to the Federal Home Loan Bank membership requirements.

    The proposed changes would impose additional regulatory burdens on FHLBank members due to ongoing compliance and membership requirement and also add an element of uncertainty to FHLBank membership. Members would be required to manage their balance sheets to make certain they hold appropriate assets to meet the proposed membership requirements to retain access to FHLBank funding. In short, the proposal will hinder certain member’s ability to effectively manage their asset allocation.

    Dedham Institution for Savings is well-positioned at this time to meet the requirements for the proposed ongoing membership changes. However, the Bank derives substantial benefit from its membership in the FHLBank, and the diversity of membership benefits all members of this cooperative. The proposed changes will limit membership therefore weakening it and will negatively affect the ability of the Boston bank to reliably and safely serve remaining members. Further, the FHLBanks would be viewed by existing and potential members as a far less reliable funding partner due to the resulting volatility in its membership.

    In addition to supplying products to meet our liquidity needs, the FHLBanks provide funding for low- and moderate-income housing in the country. The Affordable Housing Program is funded by 10 percent of each FHLBank’s net profits annually. FHLB Boston members have been awarded more than $422 million in total subsidies and subsidized advances to create or preserve more than 25,000 affordable rental and ownership units in New England. The adverse impact the proposed rule would have on the Boston bank’s ability to grow and even maintain existing levels of advances would directly lead to reduced funding of the AHP, and in turn, fewer safe, decent and affordable housing options for our communities.

    Finally, I wish to emphasize how important reliable access to FHLB Boston is to our financial institution. The FHLBank business model has been a success for over 80 years and must stay strong and stable so that the financial recovery can continue.

    For these reasons, I request that the proposed rule be withdrawn. Thank you for the opportunity to submit a comment.