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  • Comment Detail

  • Date: 01/16/19
    First Name: Mary
    Last Name: Isaacs
    Organization: Altra Federal Credit Union
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA82

  • Comment

    We support all of the proposed changes as they appear to further the mission of the FHLB system and allow them more flexibility. This should lead to a better chance of meeting their goals. As a credit union that consistently operates with a high Loan to Share ratio, we rely on the FHLB of Chicago's competitive advance rates to fund our member mortgage loans at affordable rates and terms. We are proud to be part of a system whose mission supports affordable lending to all. In particular allowing the housing goals to be established in advance and not retroactively seems to make perfect sense. We also fully support allowing flexibility in the allocation of the different housing goals and replacing separate goals with one overall measurement of performance. None of the proposed changes would appear to add any risk to the FHLB system or do anything other than improve on what is already working pretty well.