Comment Detail

Comment

Dear Federal Housing Finance Agency Directors,
Federal Home Loan Bank Des Moines is a valued partner for Iowa Trust & Savings Bank. Iowa Trust is involved in single family construction lending, financing the developers who build homes purchased by families. It is a specialized field that has provided the opportunity to fulfill the dreams of home ownership to many families. This part of the financing equation is vitally important in the goal of home ownership and is often overlooked. Iowa Trust is able to accomplish the funding of single-family construction real estate loans by substituting other FHLB 'eligible' collateral.

The FHLB system was created by Congress. Congress is responsible for the mission, not the FHFA. Congress has specifically required and authorized the FHLB mission outlined in the Federal Home Loan Bank Act. This mission is to provide liquidity to FHLB members like Iowa Trust & Savings Bank, supporting housing and community development. Congress has also authorized the membership types of eligible institutions and requirements for members to access liquidity and other products and services.

The FHFA directors contemplate an incentive system that creates 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. Iowa Trust has a strong connection to the FHLB mission as Congress intended, and Iowa Trust should continue to have the same access to FHLB liquidity, on equal terms. The RFI only serves to provide the FHFA directors cover while looking to solve a problem that doesn't exist and inject partisan political views.

Thank you for your time and consideration.

Kris M. Ausborn, CEO
Iowa Trust & Savings Bank
FDIC No. 18400