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  • Comment Detail

  • Date: 06/25/24
    First Name: Michael
    Last Name: Garrett
    Email: MGarrett@cacu.com
    Organization Type: organization
    Organization: CommunityAmerica Credit Union

  • Comment

    Congress created the FHLB & it's mission; Congress should be determining any changes to that mission, not the FHFA. The FHLB's scope is much larger than just the housing market - the FHFA scope. Housing aside, the FHLB has been a critical liquidity mechanism for banking. CommunityAmerica Credit Union (CACU) has been a partner of the FHLB for both liquidity and housing activities for decades.

    The FHLB has been (and continues to be) a key partner for CACU. As an example, they offer a mortgage loss risk-sharing option that FNMA & FHLMC do not. The ability to take out structured debt options (callable, symmetrical prepayments, amortizing, etc...) at the FHLB offers much flexibility than the Federal Reserve Bank to satisfy CACU's funding needs at various times. CACU doesn't see the need to alter how the FHLB works, nor its products, nor its mission. The old phrase, "if it ain't broke, don't fix it", seems appropriate here.

    Bottom line, while nothing is perfect, and there might be room for incremental change or improvement, the FHLB has been operating as a successful cooperative for decades, helping their members thrive and allowing them access to valuable products and services. Anything that threatens community institutions (including CACU) having this same continuing access to those FHLB products and services is only adding unneeded complication and risk into the banking system. CACU desires less change to the FHLB, as opposed to more, in this matter, so that our access to FHLB products and services is not diminished.