Comment Detail

Comment

This letter of comment is in response to the FHFA's request for input for public comment on the mission of the Federal Home Loan Bank system.

Simply speaking, Congress is solely responsible for the mission of the FHLB, not the FHFA. What Congress has specifically required and authorized is the mission as outlined in the Federal Home Loan Bank Act, which is to provide liquidity 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 request for input 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, including the institution I manage on a daily basis, 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 FHLB system and its mission, and any changes to the system's mission should be determined by Congress, not the FHFA. Also, please understand how critical the Federal Home Loan Bank liquidity is to my financial institution, and as such I urge the FHFA to ensure that all current members continue to have the same access to it as they do today.

It's simple - your agency needs to stay in its lane and allow Congress to continue to do its job.