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  • Comment Detail

  • Date: 10/14/22
    First Name: Tyler
    Last Name: Bender
    Email: tbender@mwregionalbank.com
    Organization Type: other
    Organization: Midwest Regional Bank

  • Comment

    I am the President of Midwest Regional Bank, based in Clayton, MO. We are a community bank with $900 million in assets and a client of the Federal Home Loan Bank of Des Moines.
    The FHLB Des Moines provide vital access to liquidity for our institution. The line they provide us allows us to have the flexibility to serve our communities more efficiently. Without their services, we would be significantly hindered in what we do. They are a true partner of community banks and communities in general. We use our line with them whenever we need to fund loans for local businesses quickly. It helps to provide funding in the short term while we secure long-term funding mechanisms.
    It would be a fatal mistake of the FHFA if it were to limit or compromise the regional structure of the FHLB system. The current setup allows for local input on what is going on in their regions. Taking this away or moving to limit the cooperative structure of the system would serve no other purpose than to restrict local dialogue and input to transfer more power towards a centralized location like Washington. This would destroy its character and eventually completely change its usefulness.
    Non-depository entities should not be allowed to access the programs or services either. The FHLB is a reputable organization that deals with examined and insured institutions. Opening the facilities to non-depository agents will result in greater reputational and economic risks. Outside players who don’t have to submit to regulatory scrutiny could manipulate and ultimately hurt the FHLB.
    The grassroots leadership structure must be maintained. Concentrating the leadership and employing lifetime bureaucrats will push the organization away from those they are supposed to serve and favor special interests. The current structure is efficient and instills great pride in the membership.
    We started our relationship with the FHLB Des Moines because of its structure and leadership. We continue to use them because they are friendly and efficient, and we understand who and what we are as a community bank. I ask that you please consider all these concerns seriously. Your changes will significantly impact communities and individuals.

    Sincerely,

    Tyler M. Bender