Skip to main content

  • Comment Detail

  • Date: 06/21/24
    First Name: Kenneth
    Last Name: Urmie
    Email: kurmie@midwestone.com
    Organization Type: organization
    Organization: MidWestOne Bank

  • Comment

    Congress is responsible for the FHLB mission, not the FHFA. What Congress has specifically required and authorized is that their mission as outlined in the Federal Home Loan Bank Act, which is to provide liquidity to its members in support of housing and community development. Further, Congress has authorized the types of institutions eligible for membership and the requirements for them to access liquidity and other products and services.
    The RFI also contemplates an incentive system that could create membership categories or tiers where access is different for different types of members. Congress did not authorize this nor did they intend to restrict access or discriminate against any member. All FHLB members have a strong and demonstrable connection to the System’s mission as Congress intended, and they should continue to have the same access to FHLB liquidity, on equal terms.
    Congress created the FHLBank System and its mission, and any changes to the System’s mission should be determined by Congress, not the FHFA. Federal Home Loan Bank liquidity is critical to our institution and so we urge the FHFA to ensure that all current members continue to have the same access to it as they do today.
    Thank you, Ken