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  • Comment Detail

  • Date: 01/11/15
    First Name: Jerry
    Last Name: Pistolo
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA39

  • Comment

    Dear Sir,

    Please withdraw your proposed rule.

    Your support for removing existing captive members and prohibiting new ones from joining the banking system is flawed. Captives and their owners provide 1) greater stability to the system, 2)diversification to the member base, 3)strengthen the banks' balance sheets and 4)meet the mission through the support of secondary markets. As there is a need to move away from government support and guarantees it is more imperative that the Federal Home Loan Banks expand their membership base.

    Captives also provide a lower risk of default than any other member type.

    I will not go into whether the FHFA has the right to make these changes as others have challenged this in their comments.

    Respectively,

    Jerry S. Pistolo