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  • Comment Detail

  • Date: 04/12/16
    First Name: Greta
    Last Name: Heiman
    Organization: United Bank & Trust
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA69

  • Comment

    We have been selling mortgage loans to the Federal Home Loan Bank through the MPF Traditional Program for 6 years and it’s been a valued partnership. One of the items our organization struggles to understand is why employee loans would not accepted for sale unless the board of directors of the Bank has specifically approved such purchase by resolution. Employee loans are underwritten the very same as any other borrower who applies. They must qualify and meet the guidelines set forth to close a loan through the MPF program. Our bank still holds risk in employee loans just as we would with any other borrower. Please consider a compromise to this rule to allow employee loans to be considered for sale through the MPF program. We feel with each lending institution, there are underwriting policies and guidelines in addition to MPF program underwriting and guideline standards that must be met for any borrower(s) to qualify through this program. Moving forward with this proposed restriction will only force employees to go elsewhere when looking for a similar products, which seems quite counter-productive. The MPF product as a whole has a great structure overall, in which banks must maintain some sort of risk in every loan sold through the program. We feel our directors, officers, employees, attorneys or agents of the institution should also be able to find a great fixed rate product just as any other borrower would be able to by utilizing what the MPF program has to offer.