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  • Comment Detail

  • Date: 03/08/23
    First Name: Rob
    Last Name: Woods
    Email: rwoods@savibank.com
    Organization Type: other
    Organization: SaviBank
  • Comment

    We are very concerned about any proposals that would require tracking of specific advance usage. Community banks are already burdened with a large amount of government reporting, but even more than that, we don't borrow from FHLB for specific projects or use. It is used in conjunction with local deposit to fund all of our lending. To try to document where a specific advance was used would be nearly impossible.