Comment Detail
Date: 03/28/23 First Name: Tracey Last Name: Pierce Email: tpierce@dellsbank.bank Organization Type: other Organization: Bank of Wisconsin Dells Comment
The funding access that the Federal Home Bank allows it's member banks is very valuable to our community. The access to funding allows the bank to manage interest rate risk, fund local projects for both affordable housing and small business lending. The stability of this funding source is very important. It is imperative to keep these sources available. One way to help keep access to this funding is to have the FHFA to match regulatory capital requirements for banks given community banks only fair value their securities portfolio which only represents 12%-20% off assets usually puts AOCI at our size institution at a disadvantage especially if we have low cost of funds or high yielding loans. Even if there was an adjustment to tangible capital requirements to hair cut the AOCI both on the loss and gain side would be helpful.
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