Comment Detail
Date: 02/22/23 First Name: Michael Last Name: Garrett Email: mgarrett@cacu.com Organization Type: other Organization: CommunityAmerica CU Comment
The FHLB has been operating well, and providing reasonable and consistent member value for decades. Change based on conjecture or for change's sake, is unwise and unneeded, as well as a waste of time and resources for everyone. Thoughtless decisions, like excluding larger members for one, which would reduce economies of scale, and raise costs for the remaining threatens the value of the FHLB model. Adding unneeded layers of funds tracking and member testing , has similar cost implications, that just aren't warranted adding. And forcing the FHLB to take on additional risk, seems counterintuitive to the entire point of the FHLB system - stability - for the rest of the financial system.
While it seems like some of the points, at initial glance, might have merit, upon deeper inspection, it appears not enough thought was put in and the potential issues (or impacts therein) were not really understood.
Or maybe this is just a witch-hunt by someone trying to fulfill a vendetta or make a name for themselves or their political party. Either way, drastic changes to a long established, well-functioning system is simply erroneous, wasteful and sad.