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Comment

Re: FHLBank System at 100: Focusing on the Future

Dear Director Thompson,

On behalf of Opportunity Bank of Montana, I am pleased to submit comments concerning our long-term partnership with the FHLBanks, and to offer insight on the impact the FHLBank System has made in serving community-focused financial institutions like ours.

Over my 40-year career, I have developed a deep appreciation for the role of FHLB Des Moines as a steadfast source of liquidity for Opportunity Bank of Montana. As you conduct your review of the FHLBank System, please know that I – and the hundreds of community banks that partner with the System – consider the FHLBanks a successful model that has existed for more than 90 years. We hope the System will continue to operate for many decades to come. Here are a few examples of our remarkable partnership with the FHLB Des Moines:

Contingent liquidity provider

At the Opportunity Bank of Montana, there are times when we are flush with cash and times when it is hard to come by. There are times we have strong loan demand and times we don’t. No matter what is happening in the financial system as a whole, FHLB Des Moines helps keep credit affordable and accessible to families, farms, and local businesses. FHLB Des Moines is one of the primary tools in our toolbox that give Opportunity Bank the confidence to keep lending to our customers in all economic cycles.

Making home ownership possible

That backstop of support from FHLB Des Moines allows Opportunity Bank to spend our time on what matters most to us – our communities and the families that live there. Nothing does more for a community than residential loans. Through our partnership with FHLB Des Moines, we can provide homeownership options for our customers with a range of programs, including:

1) Home$tart® Program: Over the last decade, we have been able to confidently serve 143 borrowers in need of down payment assistance with a total of $855,467 in grants. We are proud to have been able to distribute these grants throughout the state, from large cities to rural communities. If not for the collaboration between FHLB Des Moines and Opportunity Bank, the dream of becoming a first-time homebuyer would not come true for many of these families.

2) Residential Loan Programs: We are proud to be a bank that helps everyone – not just those that fit the parameters of a traditional, conforming loan. With FHLB Des Moines, we can create specialized products that are unique to us and our customer base. For example, we serve a large number of government employees that are paid bi-monthly. We were able to develop a loan product featuring bi-monthly payments to stay consistent with their cash influxes.

For nearly a century, FHLB Des Moines has supported community banks like Opportunity Bank of Montana, allowing all of us to better serve our communities. We would not be able to offer these programs to our community if we didn’t have access to their products and services. Earlier this year, we congratulated FHLB Des Moines for reaching its milestone 90-year anniversary, and we look forward to our continued partnership as the System enters its next decade of serving as a reliable source of liquidity for community banks like us.

Thank you,

Pete Johnson
Chief Executive Officer
Opportunity Bank of Montana