Comment Detail

Comment

The Federal Home Loan Bank (FHLB) provides an efficient and dependable source of liquidity to banks for meeting the funding needs of the communities we serve. I would ask the Federal Housing Finance Agency (FHFA) to carefully consider any potential negative affects to the FHLB System throughout the review process. The need for the myriad of loan funding options is critical to the asset liability management of our member banks. The FHLB System provides banks of all sizes the opportunity to serve our customers and community in a competitive, dependable and timely manner. I would ask the FHFA not to disrupt the efficiency and cost effectiveness of this valuable funding source to our banking system through burdensome tracking requirements and ongoing mission-related testing. In addition, I believe there is a need for the FHLB System to be available to all banks that meet the current eligibility requirements in order to provide stabilized and competitive pricing to smaller member banks through the diversification and consistency of earnings supported by larger members utilization. The one factor that I do believe should be considered to further enhance the overall funding process and collateralization of member borrowings is the acceptance of electronic signatures by the FHLB.

Thank you for your time and consideration of the comments noted above. I hope that the FHLB will be remain a valuable and efficient source of funding for our banking system and the communities we serve after the FHFA review has been completed. The stable funding source of the FHLB System is one factor that allows for banks to effectively manage liquidity through stressed markets and various funding challenges.

Respectively,

Dwayne A. Falk
President/CEO
Table Rock Community Bank