Comment Detail
Date: 02/21/23 First Name: Rob Last Name: Nelson Email: robn@financefactors.com Organization Type: other Organization: FINANCE FACTORS Comment
As President of a FHLBank member institution I am deeply concerned with regard to several of FHFA's proposed changes to the FHLB system. Specifically, limitations of larger members would be concerning since larger members afford the system more stable pricing and a diverse investor base. This change would not provide positive benefits to all members. Also, I am concerned about required tracking of advance proceeds. As President of a small, local CFI, this tracking requirement would be extremely difficult and cumbersome. I have experienced so many ways that regulatory burden is already preventing my staff and organization from focusing on our mission of helping home loan borrowers that other lenders do not serve. Let financial institutions focus on serving their communities rather than constraining us unduly while credit unions and non-bank lenders get to compete with unfair regulatory loopholes. Thank you for your consideration as you complete your review of the FHLB system.
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