Comment Detail

Comment

I believe you should follow the Congress since it is responsible for FHLB mission, not the FHFA. Follow the mission as outlined in the Federal Home Loan Bank Act, which is to provide liquidity to members in support of housing and community development.

Congress authorized the types of institutions eligible for membership and the requirements for them to access liquidity and other products and services.

Membership categories or tiers where access is different for diverse types of members is not authorized or intended. Do not restrict access or discriminate against any member. All members have a strong and demonstrable connection to the mission as Congress intended, and they should continue to have the same access to FHLB liquidity, on equal terms.

If your goal is to destroy access to funding/liquidity for community banks and the very communities they support, breaking the existing mission with something dreamed up in Washington, your RFI seems to outline how to do the damage. Just imagine the devastation in the United State of American if your tone outlined in the RFI was in place during any of the financial disruptions of the past few years.