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  • Comment Detail

  • Date: 01/02/15
    First Name: Carey
    Last Name: Chapman
    Organization: Fidelity Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    As a long-time member of the FHLB Atlanta and frequent user of FHLB advances I would like to urge the FHFA to reconsider its proposal to limit membership based on the mortgage-related assets as stated in associated NPR. Fidelity Bank is very active in residential mortgage lending originating over $2 billion in 2014 alone. The majority of the loans originated by Fidelity Bank are sold to either FNMA or FHLMC and not held on balance sheet. As a result, there is the potential that on a given date the total residential mortgage-related assets ratio may fall below the proposed 10%. Fidelity Bank pledges these held-for-sale loans to the FHLB as collateral to borrow against and meet short-term funding needs related to the funding of these residential loans. If Fidelity Bank loses access to this funding source, we may be forced to reduce our commitment to providing funding for residential lending which, in aggregate with other similar banks, could have a negative impact on available funding for the housing market.