Comment Detail

Comment

I am writing with the deepest concerns regarding the implementation of the proposed rules that would impact the future FHLB Bank System and future borrowings of larger Financials. With the volume of support and low-cost funds the FHLB has provided to over 6,000 financials to keep the costs of funds low and lower interest borrowings is essential in the future success of banks and credit unions across the country. NSFCU has heavily relied on the availability of these funds as future borrowing capacity if so need and with a lower cost of funds would allow us even in the tightest of economies, which we are currently in and have been for quite some time to borrow funds at the lower rate and still maintain a break-even or marginal cost of funds as it's associated with lending to our members. Particularly, as we approach potential liquidity issues and concerns across the entire country, borrowing capacity becomes more prudent and a valid concern. Borrowing at a low cost to ensure our financial institution can still be marginally profitable allows us to pass savings of any sort on to our members and maintain current expense ratios, loan-to-share ratios, liquidity margins, etc. I strongly disagree with the proposed changes to the FHLB future limitations that are being imposed.