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  • Comment Detail

  • Date: 10/12/22
    First Name: Tom
    Last Name: Marantz
    Email: tmarantz@bankwithbos.com
    Organization Type: fhlbank
    Organization: Bank of Springfield

  • Comment

    I wish to express my thoughts regarding the Federal Housing Finance Agency’s comprehensive review of the Federal Home Loan Bank System. Policy makers are considering discussions to modify the system’s regional and cooperative structure; permit non-depository entities to have access to FHLB programs and services; and consolidate the system without input from leadership of its member-owners. I find these changes alarming and not consistent with ensuring a strong, stable, and reliable source of funding for community banks.

    As you are aware, the Federal Home Loan Bank system was established in 1932 by Congress to support mortgage lending and related community investment activity in the wake of the Great Depression. It continues to fulfill this vision that Congress had decades ago and continues to meet its mission of providing member institutions to support housing finance and community investment. It is privately capitalized and does not receive any taxpayer assistance. The system banks are jointly and severally liable for all system consolidated debt. Given this history and framework, the FHLB system has without a doubt answered the call as mandated by Congress decades ago. The services and products have not only helped BOS management but many other banks. FHLB also helps in the communities of its members by providing grants and donations to help small business and underserved individuals. Engaging in a complete overall of this system that has served the banking industry so well over decades requires all stakeholders input with proposed changes thoroughly vetted. I believe the system was designed correctly and it has worked efficiently for the banking industry. Again, I have strong reservations regarding major changes.

    I will be following the discussions and meetings on this topic with a keen eye toward keeping this efficient system for community banks. I am hopeful any changes will not diminish the role of the FHLB in community banking. I appreciate your time and hope you will give my comments consideration.

    Sincerely,

    Tom E. Marantz
    Chairman of the Bank of Springfield