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  • Comment Detail

  • Date: 09/27/22
    First Name: Rob
    Last Name: Nelson
    Email: robn@financefactors.com
    Organization Type: other
    Organization: Finance Factors

  • Comment

    Dear Director Thompson,

    Thank you for the opportunity to comment on the future of the Federal Home Loan Bank of Des Moines and the FHLBank System at large. As the President and COO of a community financial institution that has been serving Hawaii for 70 years, I am keenly aware of the role that the current FHLBank model plays in enabling my institution to serve the communities we serve.

    On the Hawaiian Islands, deposit growth alone is not enough to provide the liquidity we need to meet the loan demand of working families in our communities. FHLBank of Des Moines strengthens our ability to serve our community. We would see significant impact to our lending if we did not have access to the FHLBank advances that we currently have.

    The current FHLBank of Des Moines region is already large enough as it is. Hawaii is a very unique place and if we expand the regional coverage further our unique needs will be lost to the pull of other states in the lower 48.

    The current FHLBank members benefit greatly from the lower risk profile of safety and soundness examined institutions. Please keep this in mind when considering allowing other types of institutions to join membership.

    Lastly, please consider revising the positive tangible equity requirement which is not consistent with other regulators.

    Mahalo,
    Rob Nelson
    President & COO
    Finance Factors