Comment Detail

Comment

Thank you for the opportunity to provide input on the FHLB System 100 review. I am the CEO of ChoiceOne Bank located in Sparta, MI. We are a member bank of the FHLB Indianapolis (FHLBI). The FHLBI is integral in the operation of our bank, both as a contingent source of funding and also as a partner in in providing grants to our local communities for affordable housing.

Outside of our local deposit base, we use funding through the FHLBI to continue to lend when needed, while running a safe and sound bank. While it is always a good opportunity to seek to improve an organization, I do not feel a wholesale change in the operation of the FHLB is warranted or prudent. Community banks, such as ourselves, rely on the FHLBI as a reliable source of funding in good times and in bad, so it is important to maintain the safety and soundness of the system. I think it is important to have members make up the majority of directorship within the FHLB. Member Directors know the needs among the membership and also are deeply invested in the success of the FHLB system. I also think it is important not to allow new types of institutions for membership within the FHLB system that are not highly regulated as current banks and credit union members are. I think this is important to maintain the safety and soundness of the FHLB system.

Not only do we rely on the FHLBI for funding, but also wish to see the FHLBI remain strong, so profits can continue to be used for affordable housing grants. Our community bank was able to help 22 families in 2022 with grants obtained through the FHLBI.

I believe the events of the last week, show again how important contingent funding supports the needs of community banks like ChoiceOne in supplying needed liquidity, so we continue to provide affordable funding to our local areas.

Thank you,

Kelly Potes
CEO
ChoiceOne Bank