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  • Comment Detail

  • Date: 07/12/24
    First Name: Bruce
    Last Name: Hoyer
    Email: bhoyer@beltvalleybank.com
    Organization Type: other
    Organization: Belt Valley Bank

  • Comment

    Congress created the FHLBank System and its mission, and any changes to the System’s mission should be determined by Congress, not the FHFA. What Congress has specifically required and authorized is already the mission as outlined in the Federal Home Loan Bank Act, which is to provide liquidity to its members 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. Belt Valley Bank is just a small $80MM bank with only 1 office located in Central Montana. Without the help of FHLB, our bank would not be able to fund the housing construction projects that we currently do. FHLB has been there for us for years to allow us to keep up with our loan demand. Any changes to the structure of FHLB could seriously jeopardize our ability to take care of our small rural community. The proposed changes to FHLB structure will have unintended consequences on the community banks that the FHLB supports. What our bank borrows is just a small drop in the bucket as far as the FHLB System goes, however, those funds are what keeps us going and FHLB treats us with the utmost respect and as a valued customer. They are always there for us and help guide us through our challenges. Thank you for your consideration.