Comment Detail

Comment

Dear FHFA members. Thank you for providing the space to comment on the role of the FHLB on the financial system. We have developed a great relationship with the FHLB of Atlanta for several years and I would like to comment on different stages were they help us to manage financial risk:

1) Financial Crisis 2007-2008 / Beginning of Covid Pandemic March 2020: FHLB has provided critical funding to keep liquidity flowing through the financial system, even during the worst and more volatile times in financial markets, there was a liquidity available through FHLB advances.

2) Asset and Liability Management: the access to medium- and long-term funding from the FHLB has been critical to instrument interest rate hedging to our balance sheet. Small and medium financial institutions, in many cases, lack of access to the interest rate derivatives market and the possibility of getting term funding from FHLB has become one key element to hedge interest rate risk. Small and medium financial institutions have limited access to long-term bond issuances that allow the creation of long-term funding, FHLB has been instrumental in providing these tools for hedging purposes.

We value the liquidity and interest rate risk management tools provided by the FHLB and we believe doing business counting with their support -particularly between small and medium financial institutions- supports the mitigation of financial risks.

Thank you