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  • Comment Detail

  • Date: 12/15/14
    First Name: HERB
    Last Name: ENSLEY
    Organization: COLLEGIATE PEAKS BANK
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    We believe that the proposal requiring FHLB members to own long-term mortgages, or risk loss of FHLB membership, is ludicrous. The proposal contradicts our basic principles of interest rate risk management. This is absolutely the worst time (last 3 years) to be making long-term mortgages. We saw it with the S&L debacle years ago. Apparently the folks who propose this are either too young to remember, or have an extremely short memory. We would be subject to Regulatory criticism for incurring long-term interest rate risk. Additionally, our line of credit at FHLB is an important component of our Liquidity management program and our Contingency Funding Plan. In short, the proposal would be a "double whammy" to our Bank and we strongly oppose the proposal.