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  • Comment Detail

  • Date: 12/15/14
    First Name: Daryl
    Last Name: Wilton
    Organization: Cornerstone Bank
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA39

  • Comment

    Institution that exceeds the initial threshold for FHLB membership because of size and make up of loan portfolio. Portfolio makeup is 50 % agricultural, 40% of commercial, 5% residential and personal. Many of our ag real estate notes that we have would contain personal residences but would not qualify as eligible collateral under the proposed guidelines. Please consider raising the threshold from $1.1 billion to $10 billion or please do not institute these changes.