Comment Detail

Comment

Mountain America Credit Union (MACU) has enjoyed a long partnership with the Federal Home Loan Bank of Des Moines (FHLBDM). One of the key reasons is that the FHLB system banks provide secure operational credit lines to credit unions that are just as dependable in hard times as in good times.

FHLBDM has been our preferred lending partner over the years for several reasons:
• While credit facilities through other providers may appear dependable, when economic turmoil hits the lines are cut indiscriminately. These primary sources can be notoriously unreliable when our credit union needs them most.
• FHLBDM operates on a clear collateral pledge that has been upheld through repeated economic downturns, providing critical support to its members in their times of greatest need. Other lenders cut credit lines in these moments of uncertainty, adding fuel to the crisis.
• The FHLB model has proven time and again that it is a pillar of strength and stability to the financial markets when the economy is struggling.
• The ability to pledge mortgage loans as collateral to FHLBDM encourages credit unions like MACU to continue making much-needed mortgage loans to the underserved communities we support.

Without the ability to borrow against these loans, tighter credit standards and higher interest margins would be required, meaning many low- and middle-income families would quickly be priced out of the market, especially as home prices continue to rise. Every mortgage loan pledged as collateral to FHLBDM directly supports credit unions’ continued efforts to shelter American citizens, and help them build personal wealth and financial prosperity and stability. To needlessly tamper with this model jeopardizes housing security for millions of US citizens.

I would encourage FHFA to not impose any additional requirements or restrictions on the way we partner with FHLBDM.