Comment Detail
Date: 04/15/16 First Name: Jason Last Name: Sasena Organization: Kinecta Federal Credit Union City: N/A State: N/A Attachment: N/A Number: RIN-2590-AA69 Comment
As one of the leading credit union’s in terms of residential mortgage production, we greatly value our membership in the FHLB San Francisco, which has proven to be a reliable source of liquidity and a key partner in helping us better serve our members and our communities. The MPF® Program has been a particularly valuable alternative to the secondary market for us. It allows us to share the risks of our long-term, fixed-rate mortgages. In so doing, it helps us remain competitive in our local market. Without this program, we may not able be to offer 15-, 20- and 30-year mortgages that many of our members prefer.
While we support the FHFA’s effort to revise the AMA regulation, we believe the final rule should be further revised to allow the FHLB of San Francisco and other FHLBs additional flexibility to develop and enhance new MPF products and features. In today’s changing housing finance market, these programs must be able to evolve as market developments require. Specifically, we believe the Finance Agency should address the following comments in the final rule.