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  • Comment Detail

  • Date: 12/23/14
    First Name: Kenneth
    Last Name: Littlefield
    Organization: Central Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    The Federal Housing Finance Agency (FHFA) is proposing to revise its regulations governing Federal Home Loan Bank (Bank) membership primarily to: (1) require each applicant and member institution to hold one percent of its assets in “home mortgage loans” in order to satisfy the statutory requirement that an institution make long-term home mortgage loans; (2) require each member to comply on an ongoing basis, rather than on a one-time basis as at present, with the foregoing requirement and, where applicable, with the requirement that it have at least 10 percent of its assets in “residential mortgage loans”.

    We believe this will damage the community banks who rely so much on the FHLB to finance home loans. This system has work well for many years and there is no reason to change the rules for being a member of the FHLB. This also does not consider banks that make and sell loans, moving them off their balance sheet. Finally, banks have to have home loan mortgages to pledge to borrowing so the rule is not necessary. I strongly encourage you not to enact this rule.