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  • Comment Detail

  • Date: 03/08/23
    First Name: Scott
    Last Name: Kaulukukui
    Email: skaulukukui@hickamfcu.org
    Organization Type: N/A
    Organization: Hickam FCU

  • Comment

    Located in the middle of the Pacific Ocean on the island of Oahu, Hickam Federal Credit Union (HFCU) has depended on the FHLB-Des Moines (FHLB) as a reliable partner to help us, especially during these challenging times. Some of the proposed changes recommended by the Federal Housing Finance Agency (FHFA) would be detrimental to our credit union. There are two changes that concern HFCU: the Required Tracking of Advance Proceeds and Ongoing Mission Asset and Collateral Tests.

    By requiring the tracking of advances, it would put additional work on our already short-handed staff. Additionally, the decision to borrow sometimes come at the last hour and the current process makes it quick and efficient. Adding additional elements to the process would hinder productivity. Workforce challenges continue to affect everyone in today’s environment.

    If our credit union were required to track mission-related assets, it would result in additional costs to our credit union - as those monies could be better spent assisting those in our community who need financial assistance.

    Thank you for the opportunity for FHLB’s members to provide commentary on the proposed changes.