Comment Detail

Comment

On May 16, 2024, the Federal Housing Finance Agency (FHFA) issued a Request for Input (RFI) inviting interested parties to provide written input, feedback, and information, by no later than July 15, 2024, on the FHLBank System’s mission statement, the methods for measuring and evaluating mission achievement and the financial incentives for members with a strong and demonstratable connection to the mission of the FHLBank System. The RFI raises issues fundamental to the operation of the FHLBanks, the grounds for membership in the FHLBanks, and the FHFA’s regulation of the FHLBanks. The potential changes covered by the RFI could have, if adopted, a profound impact on the future of the FHLBanks, their regions and, particularly, their members who rely on the FHLBanks to ensure the liquidity of the U.S. mortgage market.
FHLBank members – banks, credit unions, insurance companies, and community development financial institutions – actively and continuously depend on, plan for, and incorporate FHLBank liquidity into their financial strategies. FHLBank advances and mortgage finance activity play a critical role in supporting community economic development, mortgage lending activity, maintaining mortgage market liquidity across varying economic cycles, and reducing mortgage costs. The ability of members of all sizes and varying charter types to rely on ready access to FHLBank liquidity maintains the diversity and vibrancy of the U.S. financial system.
Because FHLBanks provide member institutions with ready access to advances, members can confidently support the borrowing needs of their customers, which in turn helps support economic growth and prosperity in communities. This includes homeowners’ access to competitively priced fixed-rate mortgages (such as the popular 30-year, fixed-rate mortgage), as well as broadens access to credit that supports job creation and economic growth.
FHLBank advances are collateralized primarily by loans secured by real estate. These are typically one- to four-family residential mortgage loans, along with other types of housing and real estate-related collateral such as mortgage-backed securities, commercial real estate loans, and U.S. government and agency securities. This strong link to housing helps FHLBank members provide funding for housing and economic development in their districts.

Our bank along with most other community banks that I've spoken with rely on FHLBanks. Without them we would be put at a significant disadvantage in relation to our larger competitors. We are able to offer residential mortgages as well as borrowing funds. Both are priced to help us compete and provide a fair product to our customers. As the old saying goes, "No need to fix something that ain't broke."
Sincerely,
Matt Morrow
President CEO
Citizens Federal Savings Bank
Leavenworth KS