Comment Detail

Comment

You say you are specifically interested in receiving feedback in six key areas:

The FHLBanks’ general mission and purpose in a changing marketplace – You should not abandon your mission by substituting the political winds in place of what has been the mission, which has been well served. Don’t be fooled by ‘new’ players and technology. Banks closed 3,324 branches last year, according to a tally by S&P Global Market Intelligence. When small towns lose banks, the town loses. You cannot substitute the non-taxpaying Farm Credit entities (and their scope creep) and payday loan shops for what Community Banks do to help rural America survive. Do not cut off Community Banks from the established system. Do not let yourself have scope creep to destroy rural banks.

FHLBank organization, operational efficiency, and effectiveness – The services the Des Moines Branch provides to Community Banks and thus the communities they serve are invaluable. Please do not disrupt the working model they have.

FHLBanks’ role in promoting affordable, sustainable, equitable, and resilient housing and community investment – The role as played today works very well to fund affordable, sustainable, equitable, and resilient housing and community investment. Do not break it.

Addressing the unique needs of rural and financially vulnerable communities – Again, continue to work with and support Community Banks in these markets. They cannot be replaced.

Member products, services, and collateral requirements – These seem prudent and sufficient today. Do not stretch the system trying to be on the bleeding edge.

Membership eligibility and requirements - These seem prudent and sufficient today. Do not stretch the system trying to be on the bleeding edge.