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  • Comment Detail

  • Date: 06/25/24
    First Name: Arianne
    Last Name: Holicky
    Email: arianne.holicky@fnbmn.bank
    Organization Type: organization
    Organization: First National Bank Minnesota

  • Comment

    The mission of the FHLBanks has been to provide liquidity to banks so they can support housing and community development. This is an integral part of community banking. Congress is responsible for their mission

    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 system in place gives access to all community banks. There is no need to change this and cause restricted access or discriminate against community bank members.

    All of their current 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.

    Any changes to the System’s mission should be determined by Congress, not the FHFA. The liquidity for community bank's is critical to our institution and to all institutions across the United States to provide and invest into their communities. We want to make sure that all current members continue to have the same access to it as they do today.

    For over 90 years, the Federal Home Loan Bank System has served as a reliable and critical source of funding to us through all of the economic cycles and has provided important financial stability to the broader financial system. The System works well and has proven so repeatedly.