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  • Comment Detail

  • Date: 12/22/14
    First Name: Rusell
    Last Name: Carothers
    Organization: The Citizens Bank of Winfield
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Dear Mr. Pollard,

    I appreciate the opportunity to comment on the Federal Housing Finance Agency’s proposed rule RIN2590-AA39 Members of the Federal Home Loan Banks. As a long time member bank of the Atlanta Federal Home Loan Bank – Served twelve years on the Atlanta Federal Home Loan Bank Board (Longest serving director to date), having served as Vice Chairman of Audit, Chairman and Vice Chairman of the Government Relations Committee and as a member of the Credit and Member Services, Enterprise Risk and Operations, Executive, Finance, Governance and Compensation, Housing and Community Investment, Human Resources Committees, I am very concerned about the unintended consequences that will occur from this proposal as has happened to the smaller rural community banks as a result of changes brought about in the Dodd/Frank Bill and some regulations implemented by the Consumer Protection Agency that have hampered the ability for the smaller rural banks to continue servicing their trade areas. The unintended consequences as I see it will further limit membership of small community financial institutions in the Federal Home Loan Bank system, increasing membership requirements both for existing and prospective members. The Atlanta Federal Home Loan Bank has furnished our bank availability and reliability of liquidity on which we have depended. If this proposed rule is enacted it will make it more difficult for community financial institutions, which makes up the majority of the membership, to deliver credit to their communities. FHLBank member banks serve the housing needs as well as small business needs, consumer needs etc. Reduce liquidity at the FHLBanks will further hurt an economy trying to come out of recession. All of these tie back to furnishing the economic foundation for housing opportunity. As mentioned above, the unintended consequences will hurt way more than the intentional change would help.

    Speaking from my twelve years of service at the Atlanta Federal Home Loan Bank, we fixed our problems as we worked through the recession and we worked with the other FHLBanks in the system in conjunction with our regulator to make any changes that were needed. As far as I could tell I left a well oil, smooth running machine. I was always taught if it is not broke don’t mess with it. I firmly believe this to be the case and I hope and pray that you don’t put this proposal in place. My concern is that it will eliminate a number of the smaller community financial institutions and leaving the Too Big Too Fail and larger banks dominating the system. That will not be good for the overall economy.

    Thank you for allowing our bank to comment.

    With the best intentions for the good of all,

    Russell Carothers
    Chairman and CEO
    The Citizens Bank
    Winfield, Alabama